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19-101844
lio CITY OF Federal Way 1pftkz:�� Centered on Opportunity Mr. Jeff Washington I.Joyd Enterprises Inc. P.O. Box 3889 Federal Way, WA 98063 CITY HALL 33325 8th Avenue South Federal Way, WA 98003-6325 (253) 835-7000 www. cityoffederalway. com Jim Ferrell, Mayor April 25, 2019 Re: File 0' 101844-00-UP; PROCESS I `DIRECTOR'S APPROVAL' Bucky's Contaminated Soil Removal Site Plan, 30924 Pacific Highway South, Federal Way Mr. Washington: The Community Development Department has completed review of your Process i Master Land Use (NEU) application received April 18, 2019, located at 30924 Pacific Highway South. The Process I application is hereby approved with conditions, pursuant to the findipgs, conclusions, and conditions noted below. FINDINGS OF FACT 1. The property is zoned Community Business (BC). The applicant proposes to clean-up 200-cubic yards of contaminated soil at an auto -repair business to meet Model Toxic Control Act (MTCA) Method B clean- up levels. The existing permitted vehicle -service use willremain on site. 2. The area of work is approximately is 275 square -feet, plus or minus. 3. The 2016 King County Surface Water Design Manual outlines requirements for flow control and water quality requiring an enginecring permit (`EN'). 4. The scope of proposed site improvements, limited to 200 cubic yards of cut/fill, is shown on the May 2018 remediation plan prepared by Geo Associates, LLC. 5. The proposal does not have an adverse impact to the amount of required landscaping, parking, buffering from critical areas, open space, or public areas, and does not change pedestrian connections, utilities, or easements. CONCLUSIONS OF LAW 1. The proposed land modifications are not excrapt from permitting as they do not meet the criteria set forth in .Federal Wag Revised Code (FWRC) 19.120.030, "Exemptions." The proposed soil removal, excavation, and fill exceeds 100 cubic yards. As such, the soil remediation project shall be processed using a Process I land use application, as the improvements and/or addition do no exceed FWRC 19.15.030(1) thresholds. 2. The activity is categorically exempt from the State Entdranrnenfal PoligArt per WAC 197-11-800. Cut and fill quantities will not exceed threshold exemptions of FWRC 14.15.030. 3. The proposal is located in the ten-year capture zone. The proposed grading activity intends to remediate contasninated.soil pursuant to State Department of Ecology requirements; therefore, a Hazardous Materials Inventory Statement is not required. Doc 1, ll 79056 1'J-IU�Rd•I.00-UP Mr. Jeff Washington Page 2 of 2 April 25, 2019 4. The proposed grading and imported fill impacted as shown on the remediation site plan meets "Clearing and Grading Regulations" set forth in FWRC 19,120.070-120. 5. The proposed improvements meet Pi:ocess I purpose criteria set forth in FWRC 19.55.020, including compliance with applicable -provisions of FWRC Title 19, "Zoning and Development," and health, safety, and welfare standards. APPROVAL CONDITIONS 1. The applicant shall receive engineering permit approval prior to the start of work and erosion control shall be installed and soil stabilized for the duration of the earthwork activity, with final inspections by the Public Works Department. Contact Cole Elliott, P.E. for more information at talc_rlfic�lt[t3cittc►f:fecicaalwn}�.s-t3�n. 2. The applicant shall contact South King Fire & Rescue regarding fire permits to remove storage tanks. 3. If any water or sewer utility conflicts are encountered during permitted activities, the applicant should promptly contact Lakehaven Water & Sewer for additional information at 253-941-1516. 4. Clearing and grading activities are also subject to review under Appendix Chapter J of the International Building Code pursuant to FWRC 19.120.030. APPEALS The effective date of this decision is April 23, 2019, Pursuant to FWRC 19.55.050, any person who received notice of the administrative decision may appeal this decision to the Federal Way Hearing Examiner within 14 calendar days after issuance, by May 8, 2019. Any appeal must be in the form of a letter with the established fee. In that you are the only party of record and you have submitted a signed request to waive the appeal period prior to this decision, the appeal period is hereby waived. Waiver of the right to appeal does not affect the effective date of this decision. CLOSING This decision does not waive compliance with future City of Federal Way codes, policies, and standards relating to this development. Should you have any questions contact Associate Planner Leila Willoughby - Oakes at 253-835-2644, or lrila.�vilfoughlay-nak SC�t�ci�<<nFfc dcs:tlway.co n. Sincerely, L erinn Davis Community Development Director enc: F,N Application c: Leila Willoughby -Oakes, Associate Planner Approved Remcdiation Site Plan Cole L^'lliott, P.E., Development Services Manager Chris Cahan, South King Fire & Rescue 19-101844-00-uP D- U-1 79056 a B-12 TEMPORARY I SHORING B-3 B, N r B-2 r CLOSED -IN -PLACE B-9. UST �ti r• + B-1 B-2 -7 B-1 B-4 w' I B- 2B B-7 Vic;a B-3 16 i t - - B-6 APPROXI MATE '.."- EXCAVATION I LEGEND ) B-1 ZGA BORING - Petroleum hydrocarbons not detected above MTCA A cleanup levels. t� B-1 ZGA BORING - Petroleum hydrocarbons detected above MTCA method A cleanup levels but not exceeding MTCA Method B cleanup level. ® B-1 ZGA BORING - Petroleum hydrocarbons detected above MTCA Method B cleanup level. ® B-1 AEROTECH BORING - Petroleum hydrocarbons not detected above MTCA method A cleanup levels. B-1 AEROTECH BORING - Petroleum hydrocarbons detected above MTCA Method B cleanup level - Exceeds site -specific MTCA method B cleanup levels of 2,151 parts per million for cumulative total petroleum hydrocarbons. ' Exceeds MTCA method A cleanup levels for gasoline, diesel or oil -range petroleum hydrocarbos, but below site specific method B cleanup level. ---- Approximate property boundary. A A CROSS SECTION A -A' (FIGURE 3) B1 B, CROSS SECTION B-B' (FIGURE 4) Estimated lateral extents of petroleum contaminated soil were established based on a review of available laboratory data compared to Method A cleanup standards for unrestricted land use established under Chapter 70.105D RCW and its implementing regulations, the Model Toxics Control Act (MTCA), chapter 173-340 WAC. U LIMITS � �ED-1 B- N Q t�no�. a►nd M044L .,- A' B-10� i V G � B-5a •� �� City f Federal Way kept. ®f 't� 't►�beveQ iT erg B-5b RECEIVED Permit 14 �0 q �-o —�i, MW-4 B �APR 2019 Date L� psi CrTY OF FEDERAL WAY I jvYeIt0MM NrTy DEVELOPMEfF REFERENCES: (1) Remedial Investigation, Prepared by Aerotech, Dated February 2, 2018 (2) King County Assessor Parcel Viewer: (3) ZGA Field Measurements ,, �j� OPWI pF Confirmation soil sample locations. 10 0 5 10 SCALE IN FEET BUCKY'S COMPLETE AUTO CARE 30924 Pacific Highway South Federal Way, Washington REMDIAL EXCAVATION PLAN FOR METHOD B CLEAN UP _DATE: MAY 2018 Job No. 1973.22 Zipper Geo Associates, LLC FIGURE 19019 36th Ave. W., Suite E C-1 Lynnwood, WA 1 SHT.1 of 1 RECEIVED APR 18 2019 CITY OF FEDERAL WAY COMMUNITY DEVELOPMENT April 8, 2019 City of Federal Way Department of Community Development 33325 8th Ave South Federal Way WA 98003 RE: Bucky's Contaminated Soil Removal The property is located at 30924 Pacific Highway South in Federal Way. The owner has elected to clean up contaminated soils at the site to meet MTCA Method B clean up levels and achieve regulatory closure. Estimated start date for the project is July 15th 2019. Additional information and site history is located in the attached Cleanup Action Plan prepared by ZipperGeo. Summary of work is as follows: 1. Set up erosion control and temporary construction fencing. 2. Sawcut and remove asphalt in excavation area. 3. Excavate contaminated soils and haul to a landfill licensed to accept the waste. Excavation depth and testing will be directed by the project environmental consultant Zipper Geo. Estimated export quantity is 200 cubic yards. 4. Backfill the excavation with imported clean structural fill and compact. 5. Patch asphalt and restore to existing conditions. Sincerely, Steve Bauman Lloyd Enterprises, Inc. ke 0 �j CITY OF FEDERAL WAY[f I `C COMMUNITY DEVELOPMENT DEPARTMENT DEVELOPMENT REVIEW COMMITTEE TRANSMITTAL DATE: 4-22-19 ry ,n R &4, TO: Cole Elliott, Development Services Manager Scott Sproul, Building Official 1 Rick Perez, City Traffic Engineer�jt;-1�� Brian Asbury, Lakehaven Water & Sewer District ^� ' Chris Cahan, South King Fire & Rescue FROM: Leila Willoughby -Oakes, Planning FOR DRC MTG. ON: Please email any comments by May 9th, 2019 FILE NUMBER(s): 19-101844-00-UP PROJECT NAME: Bucky's Contaminated Soil Removal PROJECT ADDRESS: 30924 PACIFIC HWY S (Parcel No. 785360-0215) PROJECT DESCRIPTION: Process I to remove approximately 200 cy contaminated soil to meet Dept. of Ecology MTCA method B cleanup levels. Backfill excavation with clean structural fill and restore parking lot to original condition (on south east corner of bldg). Proposal is not exempt from Process I application per FWRC 19.120.030 (10)(d) as proposal exceed 100 cy of cut/fill. Clearing and grading activities are also subject to review under Appendix Chapter J of the International Building Code. LAND USE PERMITS: Process I - Director's Decision/Site Plan Review PROJECT CONTACT: Jeff Washington (or Steve Bauman) Lloyd Enterprises Inc. PO Box 3889 Federal Way WA 98003 Email: jeffw011oydenterprises.com MATERIALS SUBMITTED: MLU Application Project Narrative ampling Analysis Plan �1 Aerial Photo \,A , Site Plan ! L... RECEIVEGAASTER LAND USE APPLICATION DUARTAIENT OF Ct]MMUNETV DEVEI.01'Ni NT CITY OF k APR 18 2019 33325 $'a Avenue South Federal Way. WA 93003.6325 CITY OF FEI)E I 253-835-2607:Fax 253-835-2609 Federal ay COMMUNITY DEV L� qp Aye %v.v%v.cirvaffedera1,vay.com APPuCA,riON NO(s) / -V Date 4-12-2019 Project Dame Bucky's Contaminated Soil Removal Property Address/Location 30924 Pacific Highway South Federal Way _ Parcel Number(s) 785360-0215 Project Description Remove approximately 200 cy contaminated soil to meet Dept of Ecology MTCA method B cleanup levels. Backfill excavation with clean structural fill and restore parking lot to original condition. 11CM154 Type of Permit Required Annexation Binding Site Plan Boundary Line Adjustment Comp Plan/Rezone _ Land Surface Modification Lot Line Elimination Preapplication Conference X Process I (Director's Approval) _ Process II (Site Plan Review) Process III (Project Approval) Process IV (Hearing Examiner's Decision) Process V (Quasi -Judicial Rezone) Process VI SEPA w/Project SEPA Only _ Shoreline: Variance/Conditional Use Short Subdivision Subdivision Variance: Commercial/Residential Required Information BC Zoning Designation __' Comprehensive Plan Designation _Value of Existing Improvements $39,467 Q0 Value of Proposed Improvements /nlernalional Building Code (IBC): Occupancy Type —Construction Type Applicant Name: Jeff Washington Address: PO Box 3889 Federal Way WA 98003 City/State: Federal Way WA Zip: 98003 Phone:253-874-6692 Fax: Email: jeffw@lloydenterprisesinc.com Signature: Jeff Washington Agent (if different than Applicant) Name: Same as applicant Address: City/State: Zip: Phone: Fax: Email: Signature: Owner Name: Austin Family Properties LLC Address: 6201 South Tacoma Way City/State: Tacoma, WA Zip: 98409 Phone: Fax: Email: dauslini1Abuckv7.cv}n Bulletin #003 — Januvy 1, 2011 Pagc I oft k:\liand0ul,\N1is1cr Land tisc Application n CLEANUP ACTION PLAN SUCKY'S COMPLETE AUTO REPAIR ktIt n -,"ROVED L . NNING Ctv of Federal Way Dept. of Community Development Permit # fBy Date - Date 30924 PACIFIC HIGHWAY SOUTH FEDERAL WAY, KING COUNTY, WASHINGTON ZGA Project No. 1973.22 June 22, 2018 Prepared for: Farrell Property Investments FREE FREE 70twfir. Prepared bye l7� .�irfv sic consui?tin us OprtilyRpt�erGeo f;iS�4:1dt Cc M1w:`; 19r�`= June 22, 2018 Farrell Property Investments 17786 Des Moines Memorial Dr. Burien, WA 98148 Attn: Mr. Sean McKenna RE: Cleanup Action Plan Bucky's Complete Auto Repair 30924 Pacific Highway South Federal Way, King County, Washington ZGA Project No. 1973.22 Dear Mr. McKenna, Zipper Geo Associates, LLC (ZGA) is pleased to present this Cleanup Action Plan (CAP) for Bucky's Complete Auto Repair located at 30924 Pacific Highway South site. This CAP was completed at the request of the Pollution Liability Insurance Agency (PLIA) for its review and comment under it's Petroleum Technical Assistance Program (PTAP). This CAP was completed in general accordance the requirements described in the Washington Department of Ecology document "Model Remedies for Sites with Petroleum contaminated Soil," dated December 2017, Publication No. 15-09-043. If you have questions about the project or if we may be of service in any way, please contact us. Thank you for working with us on this project. We look forward to the opportunity of working with you again on future projects. Sincerely, Zipper Geo Associates, LLC Charles C. Cacek, LEG, M.Sc. Associate Geologist Sean W. Donnan, P.G., L.E.G., L.Hg. Principal $�� aRh n �a OEM Table of Contents 1.0 INTRODUCTION.................................................................................................................................1 1.1 Site Description........................................................................................................................1 1.1 1.2 Previous Investigations........................................................................ ..... ........................1 1.2 Project Objectives .............................. ..................... .......................... ............. ............. ........ 4 1.3 Reliance_. ...... ................. . ............. . ............................... I .................................................4 1.4 Cleanup Action Description.......................................................................................................... 4 1.4.1 Shoring...............................................................................................................................4 1.4.2 Remedial Excavation Areas ................................. .................................................... :....:........ 5 1.4.3 Construction Dewatering...................................................................................................5 2.0 CLEANUP ACTION IMPLEMENTATION PLAN................................................................................:.:...5 2.1 Cleanup Action Objectives...................................................................... .. ....................5 2.2 Cleanup Action Implementation Documents................................................................................5 2.3 Construction Activity Summary, Excavation and Landfill Disposal of PCS....................................6 2.3.1 Permitting and Approvals ........................................ ......................................................... .:..6 2.3.2 Site Preparation and Mobilization............... ............ :...:................... ............................ ....... 6 2.3.3 Monitoring Well Decommissioning.......................................................................................6 2.3.4 Shoring Installation ......................... ....................... ...•••............. I .................. I ........................ 7 2.3.5 Excavation Sequence............................................................................................................7 2.3.6 Construction Dewatering..................................................................................................7 3.0 COMPLIANCE MONITORING .........................................................................................................7 3.1 Protection Monitoring ................................ ............... ... .... .............. 1........................... .................... 8 3.2 Performance Monitoring ................................ ................ ..................................................... .....8 3.2.1 Soil Performance Monitoring .................. ......... ............................................. I ....... ... .. ......._.8 3.3 Confirmational Monitoring........................................................................................:..........:.......8 3.3.1 Soil Confirmational Monitoring......................................................................_... ..............9 4.0 DOCUMENTATION REQUIREMENTS........................._.......................................................................9 4.1 Documentation Management................:::...:.........._.............................,....,,.................................9 4.1.1 Waste Profiling ................................ ........... ... ................................................... :........... ........ 10 4.1.2 Waste Disposal Tracking.........................::.....:.:............................................._....................10 4.1.3 Compliance Reports............................................................. ....................... ........................ 10 5.0 REFERENCES ............................................... ......:.....:....... .................. ..................... ....... ............. ......11 APPENDICES Appendix A Figures Appendix B Tables Appendix C Sampling and Analyses Plan Appendix D Health & Safety Plan + Cleanup Action Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 ZipperGeo Gc•�puofrsskoriai Consul:ant� 1.0 INTRODUCTION 1.1 Site Description The Property is located at 30924 Pacific Highway South in Federal Way, King County, Washington. The Property is identified as King County Tax Parcel No.785360-0215. The Property is located within a mixed commercial and residential area in the City of Federal Way. The Property comprises 0.61 acres and is developed with a 5,062 square -foot one-story wood frame structure constructed in 1987, and a 6,002 square -foot one story wood frame structure constructed in 1946. The Property is currently occupied by Bucky's Complete Auto Repair, hair salon, and martial arts studio. r•3: ' _ T frr D S 1)XiI1'P61MT RD� \ 1 21 III :' ' �' ,. •• 1pr.r�.;:. _ t � � ''s _ � _ I �•{' s aurix sr "mod � � .•` .E �•}T_- E -��•� '� i�. *V -..ti_y... '1 "f Igor, If 5' J. Figure 1. Approximate location of the Property depicted on the USGS Poverty Bay, Washington 7 %-minute topographic quadrangle. 1.1 1.2 Previous Investigations ZGA reviewed the following previous environmental reports pertaining to the Property: • Phase I Environmental Site Assessment Report— Bucky's 3101h Street— 1626South 3101h Street and 31000 Pacific Highway South — Federal Way, Washington 98003; prepared by Partner Engineering and Science, Inc and dated December 29, 2017; ■ Limited and Targeted Phase 11 Subsurface Investigation — Austin Family Properties, LLC — 1626 — 310rh Street South (30924 Pacific Highway South) — Federal Way, Washington 98003; prepared by Aerotech Environmental Consulting, Inc. and dated February 2, 2018. Page 1 1 Cleanup Action Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 •.. -, ri;�(. '-'dhP.l1 CG[1511 �Fi1:'iiS • Remedial Investigation — Bucky's Complete Auto Repair, 30924 Pacific Highway South, Federal Way, Washington 98003; prepared by Zipper Geo Associates (ZGA), dated May 24, 2018. Technical Memorandum — Petroleum Contaminated Soil, Bucky's Complete Auto Repair, 30924 Pacific Highway South, Federal Way, Washington 98003; prepared by ZGA, dated May 24, 2018. Technical Memorandum — Conceptual Site Model, Bucky's Complete Auto Repair, 30924 Pacific Highway South, Federal Way, Washington 98003; prepared by ZGA, dated June 18, 2018. Graphical depictions of site conditions and analytical results are provided on Figures 2 to 8 (Appendix A), and analytical test results for all work completed to date are included in attached Tables 1 to 3 (Appendix B). As stated in the above referenced Aerotech Limited and Targeted Phase IlSubsur ace Investi otton report: Aerotech Environmental Consulting, Inc. (Aerotech) performed Phase ll Investigation on January 25, 2018 in Areas of Concern identified in the Phase I Investigation. Nine soil borings were advanced to a maximum of 10.5 feet bgs near tank locations, the clarifier and both west and south of the Bucky's building. Total Petroleum Hydrocarbon -Diesel constituents were detected in soil at one location 16 feet west of the west building, between depths of two and four feet bgs, with maximum concentrations of 5,000 mg/kg in dense silty sandy glacial till at a depth of four feet bgs. Refusal was encountered at 4 feet bgs, due to the density and gravel content of unweathered glacial till. With this exception, gasoline, diesel and oil constituents, as well as chlorinated volatile organic compounds, lead, PAHs, and PCBs were not detected in soil at soil borings advanced in the underground tank areas, the clarifier area, and at the locations of radar anomalies south and west of the west building.... Groundwater was not encountered above the maximum depth penetrated of 10.5 feet bgs. Data available at the Department of Ecology indicated that water may be present in the area at depths of 25 to 40 feet or more feet bgs. The thickness of till documented in the area would be expected to serve as an effective barrier to the vertical migration of petroleum constituents at the subject property... The suspect 550-gallon UST discovered underneath the customer lounge area during the radar survey on January 24, 2018 should be closed in place in accordance with state and federal regulations. The collection and analysis of soil samples will be necessary to document conditions in adjoining soils at that time, and to verify proper tank closure. If no plans for the disused UST north of Bay 2 are anticipated, we recommend that this tank be closed in place as well... Interior floor drains or catch basins should be carefully sealed with concrete and absorbent material should be available to clean up fluid spills... ZipperGeo completed a subsequent Remedial Investigation (RI) that included: Page 12 Cleanup Action Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 Zippe Geo <;eaprvi,,I' an-MOraiilo ,% • Advancing 4 push probe borings to depths of 4 to 12 feet bgs. • Advancing 14 hollow -stem auger (HAS) borings to depths of 15% to 40 bgs, four of which were completed as 2-inch ID PVC groundwater monitoring wells. • Analytical testing of soil samples collected from the push probe and HSA borings for petroleum hydrocarbon constituents, including five samples that were analyzed for volatile organic hydrocarbons (EPH) and extractable petroleum hydrocarbons (VPH) for the purpose of establishing a Site specific TPH threshold cleanup level. ■ Analytical testing of groundwater collected from the monitoring wells for relevant petroleum hydrocarbon constituents. The results of the RI were as follows: • Results of EPH-VPH analyses indicated TPH concentrations protective of direct contact ranging from 1,644 parts per million (ppm) to 2,233 ppm, with the intermediate concentration of 2,151 ppm, which was selected as the Method B cleanup level. • Soils samples collected from ZipperGeo borings B-7 and MW-1 (as well as from Aerotech boring B-8) exhibited cumulative TPH concentrations in excess of the above -mentioned Method B cleanup level. The samples did not exhibit significant concentrations of benzene, toluene, ethylbenzene, xylenes (BTEX) and other volatile organic compounds (VOCs). • Groundwater depths measured in the four monitoring wells (MW-1 through MW-4) ranged from 20.30 feet to 22.12 feet below tops of wells casings, with an assessed groundwater migration direction toward the northwest at the time of the most recent sampling event (May 1, 2018). • Groundwater samples collected from the four wells did not exhibit detectable concentrations of gasoline and oil -range petroleum hydrocarbons, BTEX, other VOCs, and dissolved lead. • Samples collected from wells MW-1, MW-3, and MW-4 exhibited diesel range petroleum hydrocarbon concentrations ranging from 56 parts per billion (ppb) to 200 ppb, all of which are below the MTCA Method A cleanup level of 500 ppb. ZGA's Technical Memorandum — Petroleum Contaminated Soil (PCS) provided estimates aerial extent and ranges of bank volume and tonnages of soil external to the building with the following criteria: • All soil with detectable TPH (1,425 to 2,375 tons); • Soil exceeding MTCA Method A cleanup levels (475 to 790 tons); and • Soil exceeding MTCA Method B cleanup levels (250 to 410 tons). ZGA's Technical Memorandum — Conceptual Ste Model (CSM) provided a detailed description of characteristics of the petroleum hydrocarbon release that included: • Confirmed and suspected source areas; • The chemicals of concern; Page 13 Cleanup Action Plan Bucky's Complete Auto Repair Project 2 1973.22 Zippe Geo June 22, 018 IL�j fiea��afmssien_el CnnSu 4{ra°� F� • Media of concern; • Contaminant fate and transport; and • Exposure pathways; The CSM provides a technical basis for developing enclosed CAP. 1.2 Project Objectives The purpose of the Cleanup Action Plan (CAP) is to describe the remedial alternative that will be implemented at the Property to satisfy the MTCA and achieve regulatory closure. The objective of the remedial alternative is to obtain a written determination issued by the PLIA that no further action is necessary on the Property. A Cleanup Action Report (CAR) will be prepared after the cleanup action has been completed. The CAP addresses the remediation of the chemicals of concern (COCs) present in soil beneath the Property and includes a discussion of the selected cleanup action and the steps required for implementation. Additional documents included in the CAP are the Sampling and Analysis Plan (SAP) and the Property -Specific Health and Safety Plan (HASP). 1.3 Reliance This report has been prepared for the exclusive use of Farrell Property Investments and any authorization for use or reliance by any other party (except a governmental entity having jurisdiction over the site) is prohibited without the express written authorization of Farrell Property Investments and ZGA. 1.4 Cleanup Action Description The cleanup action entails the source removal excavation within accessible areas of the Property outside of the existing building footprint. Residual soils exceeding the Site -specific Method B cleanup levels, if present after the targeted excavation is complete, will be managed in place through institutional controls in the form of a restrictive covenant. This remedial method meets the requirements set forth in WAC 173- 340-360(3) and WAC 173-340-370, as well the criteria for "Model Remedies for Sites with Petroleum Contaminated Soils" (Ecology Publication No. 15-09-043, dated December 2017). The cleanup action includes the following components. 1.4.1 Shoring Temporary shoring may be required to protect the safety of personnel working near the excavation and the perimeter footing the existing building and nearby underground utilities, and enable the removal of contaminated soil to depth of up to approximately 18 feet below ground surface (bgs). The temporary shoring system to be used has not been determined at this time, and may consist of foundation underpinning, slot -cutting and replacement with controlled density fill, use of trench boxes, or other techniques to remove as much PCS without damaging the existing building structure. Perched groundwater may be seasonally present above the base of the remedial excavation extent. Page 14 Cleanup Action Plan Bucky's Complete Auto Repair —7 a Project No. 1973.22 f L• p p e G eo June 22, 2018 Ge^pr €.hz_ .Innaf C o n sU :k•�r; is 1.4.2 Remedial Excavation Areas Remedial excavation areas are defined as the vertical and horizontal limit of soil exhibiting concentrations of COCs above the Site Method B cleanup level for total TPH that can be removed without damaging existing building. The planned remedial excavation area is shown on Figures C- 1 to C-3 in the attached Sampling and Analysis Plan (SAP) (Appendix Q. Excavation is required in proximity to borings B-7, B-8, and MW-1. The expected maximum depth of the remedial excavation area is estimated to be approximately 18 feet bgs, or to elevation. The remedial excavation areas may larger or smaller than that depicted on the figures depending on field conditions. 1.4.3 Construction Dewatering Near -surface groundwater may be present during excavation activities. Any surface water and shallow groundwater, if encountered, will be managed using a sump pump within the limits of the excavation. The water will be contained in a suitably sized above ground tank until appropriate discharge or disposal location is determined, or removed by a pump truck and disposed of off - Property. 2.0 CLEANUP ACTION IMPLEMENTATION PLAN This section provides a description of the cleanup action components that will be implemented to remediate soil beneath the Site containing concentrations of petroleum hydrocarbons exceeding the Site Method B cleanup level. 2.1 Cleanup Action Objectives The objectives of the cleanup action for the Site established in consideration of the future use of the Property include the following: ■ Three (3) additional quarters of pre-remediation groundwater sampling to confirm stable and MTCA Method A compliant results. ■ Excavating on -Property soil containing TPH concentrations in excess of the site Method B cleanup level without compromising structural elements of the existing building. ■ Manage any remaining non -compliant soils in place, if present, with institutional control in the form of an environmental covenant protective surficial cap (pavements). ■ Acquiring a No Further Action determination letter for the Site. 2.2 Cleanup Action Implementation Documents A SAP and Health and Safety Plan (HASP) were prepared as part of the cleanup action plan and are appended to this CAP. The purpose of the SAP is to ensure that the sample collection, handling, and analysis conducted after completion of the cleanup action will result in data that meet the data quality objectives for the cleanup action at the Site. The SAP includes requirements for sampling activities, Page 15 Cleanup Action Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 Z ppe Geo Gc�•nrmf�afs6onalCus••r Tt��ats including sampling frequency and location, analytical testing, documentation, and quality assurance/quality control (QA/QC) for compliance monitoring. The SAP also defines the data quality objectives and standard operating procedures for the cleanup action and details regarding sample collection and analysis, including sample collection procedures, analytical methods, QA/QC procedures, and data quality reviews (Appendix C). The purpose of the HASP is to outline the Site -specific health and safety requirements for the cleanup action. The HASP includes guidelines to reduce the potential for injury during implementation of the cleanup action, as well as incident preparedness and response procedures, emergency response and evacuation procedures, local and project emergency contact information, appropriate precautions for potential airborne contaminants and Site hazards, and expected characteristics of the waste generated by the proposed work (Appendix D). 2.3 Construction Activity Summary, Excavation and Landfill Disposal of PCS This section summarizes the construction activities and procedures included in the cleanup action. The excavation contractor will mobilize to the Property and set up operational areas necessary to implement the cleanup action. The estimated limits of the remedial excavation are shown on Figures C-1, C-2, and C- 3 in the SAP (Appendix C), and Site work will generally proceed as described in the following sections. 2.3.1 Permitting and Approvals Earthwork contractor or ZipperGeo or the will contact City of Federal Way and King County regarding permitting requirements for the project, which may include (but are not limited to) obtaining a construction permit, grading permit, construction stormwater permit, access agreements and other approvals. 2.3.2 Site Preparation and Mobilization Before initiating construction activities, temporary erosion and sediment control (TESC) measures will be installed, as deemed necessary. Once all TESC measures are implemented in accordance with the construction project plan, construction equipment and supplies will be mobilized to the Site. Protective fencing will be installed around the work area to prevent ingress -egress to the work area. 2.3.3 Monitoring Well Decommissioning All four (4) monitoring wells will be decommissioned prior to the cleanup action, after receipt of 3 additional quarters of groundwater sampling supporting and MTCA Method A compliant and stable results. The well will be decommissioned by a licensed well driller or underthe supervision of a professional engineer, in accordance with the Ecology Water Well Construction Act (1971), RCW 18.104 (WAC 173-160-460). The well will be abandoned in place using bentonite clay. Page 16 Cleanup Action Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 2.3.4 Shoring Installation Zppei coo Gr, pr Ff{?SIC�inlconyulan.s Temporary shoring will be installed, as necessary, to protect the building and adjacent utility corridors, if present. Specific temporary shoring techniques have not been determined atthis time but may include underpinning and focused slot cutting and use of CDF. 2.3.5 Excavation Sequence The excavation will begin after the completion of the following items: ■ Installing TESC measures as necessary. ■ Establishing site security and fencing. • Preparing ingress and egress pathways. ■ Remove surficial pavement and commence remedial excavation ■ Installing temporary shoring as needed (as the excavation proceeds). As estimated in the ZGA Technical Memorandum — Petroleum Contaminated Soil, we anticipate that approximately 250 to 410 tons of PCS soil will be excavated from the remedial excavation areas at the Site and disposed of at a Subtitle D landfill. ZipperGeo will use both existing analytical data and performance soil sample results collected from the impacted soil in the remedial excavation area to classify soil for proper off -site disposal. Soil will be visually inspected for staining, sheen, and odor. In addition to physical observations, a photoionization detector will be used to qualitatively measure VOCs in the soil. As the excavation proceeds vertically downward, the selected temporary shoring method (or methods) will be extended in accordance with the shoring wall design as deemed necessary. When confirmation sample results show that all soil exceeding the Site cleanup levels that can be removed without damaging the building the remedial excavation will be deemed complete. 2.3.6 Construction Dewatering Near -surface groundwater may be seasonally present above the base of the remedial excavation. If necessary, water that is generated from surface water runoff due to precipitation events and any groundwater seepage encountered during the excavation will either be; • Directed into a sump equipped with a submersible pump and pumped into a polyethylene, aboveground holding tank that will be stored on the Property before off - site treatment, if required, and disposal, or; • Pumped with a mobile pump truck and disposed of offsite. 3.0 COMPLIANCE MONITORING There are three types of compliance monitoring identified for remedial cleanup actions performed under MTCA (WAC 173-340-410): protection, performance, and confirmational monitoring. A paraphrased Page 17 Cleanup Action Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 Z pperG o Geo;�r:-kft•e. ar.ai�:an:•:i�.,�nts definition for each is presented below (WAC 173-340-410[1]). Additional details regarding procedures for sample collection, handling, and quality assurance procedures are included in the SAP and HASP, which are attached to this report as Appendices C and D, respectively. ■ Protection Monitoring. To evaluate whether human health and the environment are adequately protected during construction and the operation and maintenance period of an interim action or cleanup action. ■ Performance Monitoring. To document that the interim action or cleanup action has attained cleanup standards. ■ Confirmational Monitoring. To confirm the long-term effectiveness of the interim action or cleanup action once cleanup standards or other performance standards have been attained. 3.1 Protection Monitoring A HASP has been prepared for the cleanup action that meets the minimum requirements for such a plan identified in federal (29 Code of Federal Regulations 1910.120, and 1926) and state regulations (WAC 296). The HASP identifies all known physical, chemical, and biological hazards; hazard monitoring protocols; and administrative and engineering controls required to mitigate the identified hazards (Appendix D). 3.2 Performance Monitoring Performance monitoring includes the collection of soil samples from the sidewalls and floor of the remedial excavation areas and the collection of soil samples during excavation and removal of any previously unidentified contamination. 3.2.1 Soil Performance Monitoring Performance monitoring for soil will be conducted during remedial excavation activities and will be used to direct advancement of the excavation. Soil samples will be collected directly from the sidewalls and/or bottom of the excavation using stainless steel sampling tools. Soil samples collected at depths of less than 4 feet bgs will be collected manually. Samples collected at depths below 4feet bgs will be collected with the backhoe bucket unless engineering controls are in place that allow for manual sample collection at depths greater than 4 feet bgs. Non -dedicated sampling equipment will be decontaminated between uses. A detailed scope for monitoring, sampling, and analysis is discussed in the SAP (Appendix C). The analytical results will be used to assess when the points of compliance for soil have been achieved. 3.3 Confirmational Monitoring Confirmational monitoring will begin after the analytical data from the performance monitoring indicates that cleanup objectives have been achieved or when additional excavation will potentially damage the existing building and underground infrastructure. Page 18 Cleanup Action Plan Bucky's Complete Auto Repair `� Project No. 1973.22 f L• p pe rGec; June 22, 2018 3.3.1 Soil Confirmational Monitoring Confirmation al monitoring for soil will be conducted after completion of the remedial excavation to assess the concentrations of COCs in subsurface soil, to verify compliance with applicable cleanup standards, and to confirm the long-term effectiveness of the cleanup action. Soil samples will be collected from the bottom of the remedial excavation area to an estimated maximum excavation depth of 18 feet bgs. Discrete soil samples will be collected directly below and lateral to non -compliant pre-remediation and remediation performance soil samples. Additional conformational soil sampling locations will be established by field screening, as described in the SAP (Appendix C). Each sample will be analyzed for TPH-G, TPH-D, TPH-O, and BTEX. To confirm that cleanup levels have been achieved, the concentrations of COCs will be compared to Site specific Method B cleanup level and, if applicable, evaluated in accordance with the Ecology document Statistical Guidance for Ecology Site Managers (Ecology 1992). As detailed in the guidance, confirming whether the Property is clean is based on a comparison of the 95th percent upper confidence limit on the mean (UCL95) with the defined cleanup level. Each sample collected will be analyzed for TPH-G, TPH-D, TPH-O, and BTEX at detection limits low enough to detect compliance with the cleanup levels. The resulting data will then be tested for conformance with distributional assumptions (normal versus lognormal) and the UCL95 calculated based on the methods described in Ecology's 1992 guidance document. If the UCL95 for a specific chemical does not exceed the cleanup level, then the Property is considered clean; otherwise, it is still considered contaminated. The Property is considered clean when the UCL95 for each COC is less than its respective cleanup level. This statistical approach allows for post -sampling excavation to remove individual sample hot spots that cause exceedance of the cleanup levels and retesting to assess if the recalculated UCL95 exceeds the cleanup level. 4.0 DOCUMENTATION REQUIREMENTS Documentation of the cleanup action is necessary to meet MTCA requirements. The applicable and relevant documentation generated for the cleanup action will be submitted to Ecology for review and approval. Copies of the documents will be retained in ZipperGeo's files for a minimum of 3 years after completion of the cleanup action. 4.1 Documentation Management An established document control system to be implemented during the cleanup action includes the following elements, as appropriate: field report forms, excavation logs, sample summary forms, material import and export summary forms, sample chain -of -custody forms, waste inventory documentation, waste management labels, and sample labels. Disposal manifests for the waste generated during the cleanup action will be maintained and submitted with the project documentation. Page 19 Cleanup Action Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 4,1.1 Waste Profiling Z pperGeo GQe ConSO'z n"-' Wastes generated during the remedial activities will require analytical testing before disposal. Generally, the treatment, storage, and disposal facility (TSDF) receiving the waste specifies the minimum number of samples and analyses before accepting wastes from a site. Wastes that will be generated from the remedial action and destined for off -site disposal include: ■ Soil containing TPH The waste stream will be profiled in accordance with the minimum waste analyses requirements of the respective permitted TSDF. Excavated contaminated soil will be subjected to performance monitoring. The Ecology document Guidance for Remediation of Petroleum Contaminated Sites (Ecology 2010) suggests that samples of stockpiled excavated soil be collected from locations where field survey methods indicate that contamination is likely to be present, and to collect samples from a depth of 6 to 12 inches beneath the surface of the stockpile. 4.1.2 Waste Disposal Tracking Specific documentation requirements will be met for transportation and disposal of the contaminated soil and groundwater (if encountered) during the excavation activities to ensure compliance with state and federal regulations. The waste disposal tracking documentation includes analytical data, waste profiles, waste manifests, and bills of lading. 4.1.3 Compliance Reports A Cleanup Action Report will be prepared followingthe cleanup action and compliance monitoring activities. At a minimum, the Cleanup Action Report will include the following: • A description of the completed cleanup action. ■ A description of the quarterly groundwater monitoring activities. ■ A summary of compliance sampling analytical results for groundwater collected during the cleanup action. ■ Summary tables of the analytical results and figures showing point of compliance monitoring wells. ■ ZipperGeo's conclusions pertaining to the cleanup action. Page 1 10 Cleanup Action Plan Bucky's Complete Auto Repair Project No, 1973.22 June 22, 2018 ■ 5.0 REFERENCES ZipperGeo Geoprafz►aonal Cuniu€;�;;;s Aerotech Environmental Consulting, Inc. (Aerotech), 2018, Limited and Targeted Phase 11 Subsurface Investigation — Austin Family Properties, LLC —1626 — 310`h Street South (30924 Pacific Highway South) — Federal Way, Washington 98003; February 2, 2018. Booth, D. B., Waldron, H. H, and Troost, K. G., Geologic Map of the Poverty Bay 7.5' Quadrangle, King and Pierce Counties, Washington, U.S. Department of the Interior, Scientific Investigation Map 28S4, 2004. Partner Engineering and Science, Inc., 2017, Phase I Environmental Site Assessment Report— Bucky's 3101h Street — 1626 South 310th Street and 31000 Pacific Highway South — Federal Way, Washington 98003; December 29. Zipper Geo Associates, 2018, Remedial Investigation — Bucky's Auto Repair, 30924 Pacific Highway South, Federal, Washington, May 24. Zipper Geo Associates, 2018, Technical Memorandum - Petroleum Contaminated Soil, Bucky's Auto Repair, 30924 Pacific Highway South, Federal Way, Washington, May 24. Zipper Geo Associates, 2018, Technical Memorandum, Conceptual Site Model, Bucky's Auto Repair, 30924 Pacific Highway South, Federal Way, Washington, May 24. Washington State Department of Ecology, 2016, Guidance for the Remediation of Petroleum Contaminated Sites, Publication No. 10-09-057, June. 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UO4 0ww 00 c7 m �wHwwm ,woQo0Z >�4 OO (if (D ¢w w 0 m � mF Uz LL� (frU)Oaa¢ Z ¢ w W ZZz U o Q p gm pOw0 a FzQ��OQ0w 02=¢woC9O O0 0a�awlywY yLd 0a�w0 7 C NN �w S Q m Q Z Q 7 F m U O O U a 0 0 g m m I ® 0 x x = m r 0 I a z iL g x I � I I � I I I I I I I I I I I I I m®61 I LOL � 68 I I _ I � I � I M m I � � l m Q5. m Yk � CD M m� LO m I N / Hinos AVMHJIH 01=11O 'd W O Z tj W Z O a1 vZ o F O � H V a Y � LL N N M 3 d a Y Y w 0 m a u3 j a Z > W O Q O W C7 i W Z — of (r ? a ww t D w w w �> z ai o>¢> O O W>z Z c — w3 U Uww O X¢ H O O Z w 4'3 00 Q Z H U ¢ Z � D U a a� NOS ~O U A- yN3 N Q fL m W 0 0 71, e i I nm 'E J 1 F I I I U I �n I _V`J r r 1 � r t U I •� I J I I I L.I.J 111 I I W V i N I..L I I CO ^ I I I I I F— I C E E � d FM CO 14 or �I '1 ` i i �` 11 •t t • s � �r � N L t i Z � 1 1 :• { . 1 � a _ _ _--------------------•------- � a a" c m a m E m rA W Hinos AVMH!DIH OIJIOVd a W W W a APPENDIX B TABLES G ee F V 0 V� E at+aleyigdcu]Ay77W _ � -Z 7 E auajeyyydculA LOW V T � O aualeyjdeN s]OA Ia470 auale41ftN saualAX lo.1 ❑ 3 �` aualAX-o 2 au.IAX-d 'w Z auazuaglA473 zlr auanlol � auazuag v r c auanlollAdozd°sl-d • 2 auazuaglAjngoas auazuaglA4aaw111 -HZ'S auazuaglA4aawul p m -5'E'S EauazuaglAdwd-u u O auazuaglAdojdosl x q u w g a N m peak _ E wnlwojy:) wnlwpe7 O � ■ Ev 1. 1v v v o N o x v` x n r E 0 0 u E `o 3 au A w E v c _v — L N C a v X ~ 2 O x V V V V V 2 E _ v � F u O c c o v m m c p C m G U p Vv vV V V V V V V N � O x _ H 0 0 E r w` m 3 Q � 0 o c � _ n r v � r 0 _ m a r o v ry M e 72 a � E N 44 � 10 rn o m .j r. p o o a � n m Z s c � ¢ LL m ry N •p p � ry M F 6] N m E Q Q c U y o O N w m a r H r r O TahIP R_ SummnrizPd VPH/EPH and VOC Results Analyte Sample Number and Concentration (mg/kg) B1@12' H B7@2 1/2-3' MW3@2 1/2-3' MW1@15-16' 89@2 1/2-3' DRO NA 2,800 5,600 3,900 2,000 GRO 230 NA 890 630 150 .AL EC>5-6 <1.48 NA <1.17 <1.17 <1.19 AL EC >6-8 2.2 NA <1.67 <1.67 <1.70 .AI EC >8-10 7.02 62.5 151 138 <0.952 .AL EC>10-12 40.8 447 961 764 192 .AL EC>12-16 NA 1,480 2,080 1,620 768 AL EC>16-21 NA 465 723 630 301 .AL EC >21-34 NA <11.2 17.5 <10.4 <10.4 .AR EC>8-10 10.4 11.2 24.3 11.6 <10.4 .AR EC>10-12 216 25.1 90.2 70.5 11 .AR EC >12-13 <5.91 NA 498 433 21.4 AR EC >12-16 NA 174 402 330 84.6 .AR EC >16-21 NA 197 310 261 137 .AR EC >21-34 NA <10.2 <11.1 <10.4 <10.4 Benzene <0.507 NA <0.436 <0.401 <0.408 'Toluene <0.591 NA <0.509 <0.467 <0.476 Ethylbenzene <0.591 NA 0.038 0.024 <0.476 Total Xylenes NA NA NA NA NA m, p-Xylene NA NA 0.072 <0.01 NA o-Xylene <0.507 NA 0.086 <0.005 <0.408 Naphthalene <0.422 NA 0.19 J 0.20 ve 0.11 n-Hexane NA NA <0.025 <0.025 <0.025 MTBE <0.422 NA <0.364 <0.334 <0.340 Ethylene Dibromide (EDB) <0.05 NA <0.005 <0.005 <0.005 1,2 Dichloroethane (EDC) <0.05 NA <0.005 <0.005 <0.005 Isopropylbenzene 0.068 NA NA NA NA N-Propyl Benzene 0.13 NA NA NA NA 1,3,5-Trimethylbenzene 0.23 NA NA NA NA 1,2,4-Trimethyl benzene 0.75 NA NA NA NA S-Butyl Benzene 0.16 NA NA NA NA P-Isopropyltoluene 0.19 NA NA NA NA N-Butylbenzene NA NA NA NA NA Benz(a)anthracene NA <0.01 <0.1 <1 <0.01 Chrysene NA <0.01 <0.1 <1 <0.01 Benzo(a)pyrene NA <0.01 <0.1 <1 <0.01 Benzo(b)fluoranthene NA <0.01 <0.1 <1 <0.01 Benzo(k)fluoranthene NA <0.01 <0.1 <1 <0.01 Indeno(1,2,3-cd)pyre ne NA <0.01 <0.1 <1 <0.01 Dibenz(a,h)anth race ne NA <0.01 <0.1 <1 <0.01 Total TPH 280.99 2,872.00 5,206.32 4,273.84 1,517.16 Direct Contact Pathway Cleanup Level 1,644 2,170 2,151 2,138 2,233 NA: not analyzed for selected analyte. mg/kg: milligrams per kilogram (parts -per -million). H: Holding times for preparation or analysis exeeded. ' : Rounded to the nearest whole number. J: the internal standard associated with the analyte is out of control limits. The reported concentration is an estimate. ve: the analyte response exceeded the valid instrument calibration range. The value reported is an estimate. APPENDIX C SAMPLING AND ANALYSIS PLAN SAMPLING AND ANALYSIS PLAN APPENDIX C OF CLEANUP ACTION PLAN BUCKY'S COMPLETE AUTO REPAIR 30924 PACIFIC HIGHWAY SOUTH FEDERAL WAY, KING COUNTY, WASHINGTON ZGA Project No. 1973.22 June 22, 2018 Prepared for: Farrell Property Investments Prepared by: Zipper(3eo Gvcor-: 1cconsu,Onts Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 Sampling and Analysis Plan Bucky's Complete Auto Repair 30924 Pacific Highway South Federal Way, King County, Washington Prepared for: Farrell Property Investments 17786 Des Moines Memorial Dr. Burien, WA 98148 Project No.: 1973.22 Prepared by: Charles C. Cacek, LEG, M.Sc. Associate Geologist ppeGeo Getpn�F a;ir, ;til Conwftont% Sean W. Donnan, P.G., L.E.G., L.Hg. Principal Table of Contents 1.0 Introduction ...................... ......................................................... .................. ............. ............. ,1 1.1 Purpose and Objectives ........................ ....................................... :...... 1 1.2 Sampling and Analysis Plan Organization ................... :::::........... ,...... 1 1.3 Background.........................................................................................2 1.3.1 Property Location and Description ..................................... :............... 2 1.4 Property History.................................................................................3 1.5 Summary of Previous Investigations ............................ :::;.:..::,............ 3 1.6 Cleanup Action Plan Task Descriptions ............................................... 3 2.0 Project Organization and Management ........ .............................. ....... ...:.::..................................... ... 3 3.0 Cleanup Action Plan Field Program................................................................................................... 7 3.1 Summary of Field Activities and Scope of Work............:...................7 3.1.1 Site Preparation and Mobilization...................................................... 7 3.1.2 Well Decommissioning............................................................:.......:..7 3.1.3 Shoring Installation ........................... .. ...... . .............7 3.1.4 Shoring and Excavation Sequence .............................................:...::.. 7 3.1.5 Construction Dewatering................................................................... 8 3.2 Soil Sampling ------------ ---........................................... I ............. .,........... .8 4.0 Sample Handling and Quality Control Procedures.............................................................................9 4.1 Sample Identification .......................................... ................ :.....I ........ 9 4.1.1 Soil.— ............................. . .................................. ,.......................9 4.2 Decontamination procedures .......................... ....:................. ............ 9 4.3 Sample Container and Handling Procedures...................................10 4.4 Sample Chain -of -Custody Procedures ............................. ... :............. 10 4.5 Field Quality Assurance Sampling....................................................11 5.0 Analytical Testing .......................... ......... ...................... .............. :........................ :...... a ............... 11 6.0 Management of remediation-Derived Waste................................................................................. 12 6.1 Soil..........................................................:.............:.:......................... 12 6.2 Wastewater......................................................................................12 6.3 Disposables.............................................................................-1.......13 7.0 Data Quality Objectives ...... .......................................... ........... - ...........................,......._...........13 7.1 Precision............................................................4............................. 14 7.2 Accuracy...... ...... ............. ..... m ............. a ................... .................. 14 7.3 Representativeness................................................I.........................15 7.4 Completeness ............................ ................................................ ...lS 7.5 Comparability ................................................................................... l5 7.6 Sensitivity'_'_ .............. ......... ................................................ .'__.16 8.0 Data Collection ............. ........ -............ ......................................................................................... 16 81 Data Collection Approach ................................................................ 16 8] Data Types ...................... ................................................................. 16 83 Data Transfer .................................................................................... 16 8.4 Data Inventory ........................................................................... ___ 17 8.4.1 Document Filing and Storage— ... ............................................. ...... 17 8/4.2 Access toProject FUes''..................................... .............................. 17 8.5 Data Validation ..................................... .......................................... l7 8.6 Data Reduction And Analysis ............... .............................................. 1D 9.0 Quality Control Procedures .......................... ........................................................................ ..... —_18 91 Field Quality Control ................................................... ................... 18 9] Laboratory Quality Control --' ......................... ....... -...... 1O 93 Data Quality Control -_'..... ~....................................... -...... l9 9,4 Data Assessment ProceJures....~_.---------------..2O 9.5 Performance Audits ............................................ .............................. 20 10.0 Corrective Actions ........................ ................. ....................................................... —''—'—'—'ZO 11.0 Documentation And Records ................................................ ~........................................................ 2l 11.1 ReWDocumentation-------- ~.----,—.—..Z1 112 Analytical Records ......................................... ~................................. ZZ 12.0 Health and Safety Procedures ......................................................................................................... Z2 13.0 REFERENCES_ .................................................................................................... .............................. 23 APPENDICES Appendix R0uns Appendix Tables Appendix[ Project Forms Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 1.0 INTRODUCTION PPe CLo ZipperGeo Associates, Inc. (ZGA) has prepared this Sampling and Analysis Plan (SAP) for Bucky's Complete Auto Repair located at 30924 Pacific Highway South in Federal Way, Washington (the Property). In accordance with the Washington State Model Toxics Control Act (MTCA) Cleanup Regulations as established in Section 200 of Chapter 173-340 of the Washington Administrative Code (WAC 173-340- 200), the Site includes soil contaminated with gasoline -and diesel range petroleum hydrocarbons. The sources of contamination on the Site appear to be the recently closed -in -place petroleum underground storage tank (UST). This SAP was developed to supplement the requirements of the Cleanup Action Plan (CAP) and to meet the requirements of a SAP as defined by MTCA (WAC 173-340-820). 1.1 Purpose and Objectives The purpose of the SAP is to describe the sample collection, handling, and analysis procedures to be implemented during the cleanup action in accordance with WAC 173-340-380 of MTCA. This SAP identifies specific sampling and analysis protocols, project schedule, and organization and responsibilities. It also provides detailed information regarding the sampling and data quality objectives, sample location and frequency, equipment, and procedures to be used during the cleanup action; sample handling and analysis; procedures for management of waste; quality assurance protocols for field activities and laboratory analysis; and reporting requirements. 1.2 Sampling and Analysis Plan Organization The SAP is organized into the following sections: ■ Section 1.0, Introduction. This section describes the purpose of the SAP; provides a description of the Property features and location, a summary of the current and historical uses of the Property, a summary of the results of previous investigations conducted at the Site; and lists the Cleanup Action Plan (CAP) tasks. ■ Section 2.0, Project Organization and Management. This section presents the project team, including field personnel and management. ■ Section 3.0, Cleanup Action Plan Field Program. This section presents the cleanup action objectives and summarizes field activities. ■ Section 4.0, Sample Handling and Quality Control Procedures. This section describes the sample handling techniques and quality assurance procedures that will be followed during the cleanup action. ■ Section 5.0, Analytical Testing. This section describes the type and number of sample analyses that will be conducted on soil and process water samples during the cleanup action. Page I 1 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 Ipper&eo Gra;�ro(rs�Eenil�OnsUiklrkts ■ Section 6.0, Management of Rem ediation-Derived Waste. This section provides details on handling and disposal procedures that will be implemented during the cleanup action. ■ Section 7.0, Data Quality Objectives. This section summarizes the data quality objectives (DQOs) that will need to be met to ensure the validity of the analytical results. ■ Section 8.0, Data Collection. This section describes the type, transfer, inventory management, and validation procedures of the data that will be gathered during the cleanup action. ■ Section 9.0, Quality Control Procedures. This section provides details regarding the quality control (QC) procedures for both field activities and laboratory analysis. ■ Section 10.0, Corrective Actions. This section identifies the approaches that will be used to correct any protocols that may compromise the quality of the data. ■ Section 11.0, Documentation and Records. This section outlines the documentation that will be prepared during the cleanup action. It includes a discussion of document management, waste disposal tracking, and compliance reports. ■ Section 12.0, Health and Safety Procedures. This section summarizes the health and safety procedures outlined in the Site -specific Health and Safety Plan (HASP; Appendix D of the Cleanup Action Plan [CAP]). ■ Section 13.0, References. This section lists the documents cited within this SAP, including U.S. Environmental Protection Agency (EPA) and Washington State Department of Ecology (Ecology) guidelines for Quality Assurance Project Plans. 1.3 Background This section provides a description of the Property features and location, a summary of historical Property use, and a summary of previous investigations conducted at the Property and adjoining parcels and rights - of -way (ROWS). 1.3.1 Property Location and Description The Property is located at 30924 Pacific Highway South in Federal Way, King County, Washington. The Property is identified as King County Tax Parcel No.785360-0215. The Property is located within a mixed residential and commercial area in the City of Federal Way. The Property comprises 0.61 acres and is developed with a 5,062 square -foot one-story wood frame structure constructed in 1987, and a 6,002 square -foot one story wood frame structure constructed in 1946. The Property is currently occupied by Bucky's Complete Auto Repair, a hair salon, and martial arts studio. Additional improvements include an asphalt -paved parking lot and peripheral landscaping areas. The current land use of the Property and surrounding area is commercial. The property is bordered to the north by a vacant commercial building; to the east by a multi -tenant commercial Page 1 2 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 ZppeGeo C•xpaa P�esic.�•al Can sS1 t�,3CNi5 building and a vacant lot; to the south by a Dollar Tree store; by a 7-11 store to the southwest; and to the south by the Family Dental Center and a multi -tenant commercial building to the south. 1.4 Property History According to a Phase I Environmental Site Assessment of the Property conducted by Partner Engineering and Science, Inc. in 2007, the property was undeveloped from at least 1897 through 1943, and has been commercially developed since 1949. Automotive repair has been performed on the property since 1972. Since that time the building has been occupied by Federal Way Suzuki (1972-1987) and Bucky's Auto Repair (1987-present). 1.5 Summary of Previous Investigations Subsurface investigations conducted at the Property ZipperGeo and others identified gasoline and diesel contamination in excess of MTCA Method A cleanup levels in soil in a limited area located within and adjacent to the northwest portion of the building at depths ranging from 2% feet to at least 21 feet bgs (See attached Figures 1 to 3, Appendix A). Zipper Geo completed extractable petroleum hydrocarbons — volatile petroleum hydrocarbons (EPH-VPH) analyses and established a Method B cleanup level for the site. Four groundwater monitoring wells were installed within and peripheral to the source area, and groundwater samples collected from the wells did not exhibit detectable concentrations of petroleum hydrocarbon constituents. Also, groundwater depths at the site ranged from about 20.30 to 22.12 feet below tops of well casing at the time of sampling (May 1, 2018) with an assessed groundwater migration direction toward the northwest. 1.6 Cleanup Action Plan Task Descriptions The tasks proposed as part of the cleanup action plan include the following: ■ Permitting for the planned excavation ■ Three (3) additional quarters of pre-remediation Groundwater Sampling from existing wells to confirm MTCA Method A compliant and stable results. ■ Site preparation and mobilization ■ Decommissioning of monitoring wells ■ Shoring installation ■ Remedial excavation and soil performance and confirmation sampling. A summary of the CAP schedule is provided in Table C-1 (Appendix B). 2.0 PROJECT ORGANIZATION AND MANAGEMENT This section describes the overall project management strategy for implementing the cleanup action. Page 13 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 z-ppe Geo faE �r�,�.��ional[pns4'kr€;€ts To ensure efficient decision -making for field sampling and laboratory analysis, key data collection decisions, decision criteria, process for decision -making, quality assurance/quality control (QA/QC) procedures, and responsibilities are described below and detailed in Table C-2 (Appendix B). These decision and communication plans will be followed by field personal under direction of the field coordinator and task manager. Site quality control to ensure proper communication and adherence to this SAP is discussed below in Section 9.0. The cleanup action is being conducted by ZGA on behalf of Farrell Property Investments. The following key personnel have been identified for the project. A summary of key personnel roles and responsibilities is provided in Table C-2. Regulatory Agency. The Pollution Liability Insurance Agency (PLIA) is the lead regulatory agency for the Site, as promulgated in MTCA. The cleanup action for the Site is being conducted as an independent remedial action in accordance with WAC 173-340-515 of MTCA. Ecology's site manager for the project is: Mr. Li Ma, Ph.D. State of Washington Pollution Liability Insurance Agency P.O. Box 40930 Olympia, Washington 98504-0930 360-407-0522 Project Contact. ZGA has been contracted by Farrell Property Investments to plan and implement the cleanup action at the Site. The project contact for Farrell Property Investments is: Mr. Sean McKenna Farrell Property Investments 17786 Des Moines Memorial Dr. Burien, WA 98148 206-241-4800 (office) 206-229-1157 (cell) Page 14 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 7 pp Geo GCS' pr,p€a:..• •kno ! con4,.`'ar' Project Principal. The project principal provides oversight of all project activities and reviews all data and deliverables before their submittal to the project contact or regulatory agency. The project principal for ZGA is: Mr. Sean Donnan ZipperGeo Associates, Inc. 19019 361h Avenue West, Suite E Lynnwood, Washington 98036 Office: 425-582-9928 Cell; sdonnan@zippergeo.com Project Manager. The project manager has overall responsibility for developing the SAP, monitoring the quality of the technical and managerial aspects of the cleanup action, and implementing the SAP and corresponding corrective measures, where necessary. The project manager for ZGA is: Mr. Charles Cacek ZipperGeo Associates, Inc. 19019 361h Avenue West, Suite E Lynnwood, Washington 98036 Office: 425-582-9928 Cell 206-300-6237 ccacek@zippergeo.com Laboratory Project Manager. The laboratory project manager will provide analytical support and will be responsible for providing certified, pre -cleaned sample containers and sample preservatives (as appropriate) and for ensuring that all chemical analyses meet the project quality specifications detailed in this SAP. Friedman & Bruya Inc., of Seattle, Washington, has been contracted by ZGA to perform the chemical and physical analyses for compliance samples collected during the cleanup action. The laboratory project manager is: Mr. Mike Erdahl Friedman & Bruya, Inc. 3012 16th Avenue West Seattle, Washington 98119 206-285-8282 merdahl@friedmanandbruya.com Project QA/QC Officer. The project QA/QC officer has the responsibility to monitor and verify that the work is performed in accordance with the SAP and other applicable procedures. The project QA/QC officer has the responsibility to assess the effectiveness of the QA/QC program and to recommend modifications to the program when applicable. The project QA/QC officer is responsible for assuring that the personnel assigned to the project are trained relative to the requirements of the QA/QC program and for reviewing and verifying the disposition of nonconformance and corrective action reports. The project QA/QC officer for ZGA is: Page 15 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 Mr. Charles Cacek ZipperGeo Associates, Inc. 19019 36`h Avenue West, Suite E Lynnwood, Washington 98036 Office: 425-582-9928 Cell 206-300-6237 ccacek@zippergeo.com ZipperGeo Geo C, rrt;7 rs-FF+>sy iq' • i i i � ns� • fx,� s,> Field Coordinator. The field coordinator (FC) will supervise field collection of all samples. The FC will ensure proper recording of sample locations, depths, and identification; sampling and handling requirements, including field decontamination procedures; physical evaluation and logging of samples; and completing of chain -of -custody forms. The FC will ensure that all field staff follows the SAP, that the physical evaluation and logging of soil are based on the visual -manual classification method American Society for Testing and Materials D-2488, and that standardized methods for sample acceptability and physical description of samples be followed. The FC will ensure that field staff maintains records of field sampling events using the forms included as Attachment A of this SAP. The FC will be responsible for proper completion and storage of field forms. The FC for ZGA is: Mr. Jeff Tinklepaugh ZipperGeo Associates, Inc. 19019 36th Avenue West, Suite E Lynnwood, Washington 98036 Office: 425-582-9928 Cell 206-300-6237 jtinklepaugh @zippergeo.com Field Staff. Members of the field staff must understand and implement the QA/QC program, coordinate and participate in the field sampling activities, coordinate sample deliveries to laboratory, and report any deviations from project plans as they relate to the cleanup action objectives as presented in the SAP. Major deviations from the SAP, such as the inability to collect a sample from a specific sampling location, obtaining an insufficient sample volume for the required analyses, or a change in sampling method, must be reported to the project manager. Subcontractors. All subcontractors will follow the protocols outlined in this SAP and will be overseen and directed by ZGA. The following subcontractors have been identified: Private Utility Locator: Bravo Environmental 6437 South 144th Street Tukwila, Washington 98168 425-424-9000 info@bravonw.com Page 1 6 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 Z p pe G c2 o June 22, 2018 -- 4 Ge�p.:`ftre. a'•sl Cunsui€ar;t; 3.0 CLEANUP ACTION PLAN FIELD PROGRAM The objectives of the cleanup action for the Site have been established in consideration of the future use of the Property and include the following: ■ Sample monitoring wells MW-1 to MW-4 for COCs forthree additional quarters to better establish baseline water quality trends prior to the remedial action. ■ Decommission monitoring wells MW-1 through MW-4. ■ Excavate on -Property soil containing petroleum hydrocarbons at concentrations that present a risk to human health and the environment. ■ Acquire a No Further Action determination for the Site. A discussion of the field program is provided in the following sections. 3.1 Summary of Field Activities and Scope of Work 3.1.1 Site Preparation and Mobilization Before initiating construction activities, temporary erosion and sediment control (TESC) measures will be established as deemed necessary. When all TESC measures are implemented in accordance with the construction project plan, construction equipment and supplies will be mobilized to the Site. 3.1.2 Well Decommissioning Monitoring well MW-1 through MW-4 will be decommissioned prior to the cleanup action. The well will be decommissioned by a licensed well driller or under the supervision of a professional engineer, in accordance with the Ecology Water Well Construction Act (1971), Chapter 18.104 of the Revised Code of Washington (WAC 173-160-460). The well would be abandoned in place using bentonite clay. 3.1.3 Shoring Installation Some type of temporary shoring or slot -cut excavation technique will be required to remedially excavate PCS to maximum extent without damaging the existing building (See Figures 1 to 3). However, the type of temporary shoring and/or excavation technique have not been determined at this time. 3.1.4 Shoring and Excavation Sequence The bulk excavation will begin after the completion of the following items: ■ Installing TESC measures. ■ Establishing site security and fencing. ■ Demolishing the existing building. Page 17 Sampling and Analysis Plan Bucky's Complete Auto Repair Project 2 L 1973.22 %� ppeyGeo June 22, 018 i �, �J .,��rprnFEssianai f4nyutk�r+ts ■ Preparing ingress and egress pathways it Installing the shoring system (as the excavation proceeds). The anticipated remedial excavation limits are graphically depicted on Figures 1 to 3. As estimated in the ZGA Technical Memorandum — Petroleum Contaminated Soil, we anticipate that approximately 250 to 410 tons of PCS soil will be excavated from the remedial excavation areas at the Site and disposed of at a Subtitle D landfill. ZGA will use performance samples collected from the impacted soil in each identified remedial excavation area, as well as any additional impacted soil identified in other areas of the Site during excavation activities to classify soil for proper off -site disposal. 3.1.5 Construction Dewatering Near -surface groundwater may be seasonally present above the base of the remedial excavation. Also, stormwater runoff may enter the excavation. Water that is generated from surface water runoff due to precipitation events and any groundwater seepage encountered during the excavation will be directed into a sump equipped with a submersible pump in the base of the excavation cavity. If present collected groundwater and stormwater will be pumped into a polyethylene, aboveground holding tank that will be stored on the Property before off -site treatment, if required, and disposal. The storage tank will be located in an area that is accessible for a vacuum truck service to remove the water and transport it for treatment and disposal off the site. The holding tank will be emptied, as needed, and water levels will be monitored by personnel to ensure that an adequate capacity is maintained in the holding tank. 3.2 Soil Sampling Performance soil samples will be collected and analyzed using an EPA -accredited laboratory to confirm that all known PCS above the Site -specific MTCA Method B cleanup levels have been removed the maximum extent without compromising the existing building. If these discrete, in -place samples exhibit COC concentrations in compliance with Site Cleanup levels, they will be deemed confirmation samples Soil samples will be collected from the sidewalls and floor of the remedial excavation area. More specifically, performance samples will be collected directly below all locations where pre-remediation COC exceedences were present. In addition, samples will be collected along sidewalls at approximate 5 to 8 feet depth intervals along the excavation sidewalls to the excavation base. Preliminary confirmation sampling locations are depicted on Figures 1 to 3. Information logged during soil performance sampling will include sample depth, soil moisture content, observations of physical indications of contamination (e.g., odors, staining), and field screening data obtained using a photoionization detector (PID). Soil samples will be collected directly from the sidewalls and/or bottom of the remedial excavation area using either stainless steel or plastic sampling tools. Soil samples collected at depths of less than 4 feet bgs will be collected manually. Samples collected at depths below 4 feet bgs will be collected with the excavator bucket unless engineering controls are in place that allow for manual sample collection at depths greater than 4 feet bgs. All non -dedicated sampling equipment will be decontaminated between Page 18 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 ZppeGeo. f L'nAYb;Ff�}. SId pU� GOf1i11.sYili5 uses. The samples will be submitted for laboratory analysis and the analytical results will be used to assess when the points of compliance for soil have been achieved. 4.0 SAMPLE HANDLING AND QUALITY CONTROL PROCEDURES The section summarizes sample labeling, containers, handling, chain of custody, and field quality control procedures to be applied during the cleanup action. 4.1 Sample Identification Each sample collected during the cleanup action will be assigned a unique sample identifier (ID) and number. Sample ID labels will be filled out and affixed to appropriate containers immediately before sample collection. The label is filled out in indelible ink and will include the following information: media, date, time sampled, sample identification and number, project name, project number, sampler's initials, and analyte preservative(s) if any. An example of the Sample ID Label is included in Attachment A of this SAP. 4.1.1 Soil Bottom and sidewall soil samples will be assigned a unique ID that will include the components listed below: ■ The remedial excavation area (e.g., EX01) • The compass heading of the sidewall (e.g., N) 10 The sample type (e.g., bottom "B", sidewall "SW") ■ The number of samples collected in that area (e.g., 01, 02, 03) + The depth in feet bgs (e.g., 15) For example, the first soil sample collected from the north sidewall of remedial excavation at a depth of 8 feet bgs would be identified as EX01-NSW01-8. Likewise, the first soil sample collected from the bottom of excavation area EX01 at a depth of 25 feet would be identified as EX01-1301-25. If the base of a remedial excavation area required overexcavation and further sampling within the same area, a second sample would be collected and would be identified as EX01-1302-28. The sample identification would be recorded on the Sample ID Label, Field Report form, and Sample Chain of Custody form. 4.2 Decontamination procedures Decontamination of all non -disposable tools and equipment will be conducted before each sampling event and between each sampling location, including stainless steel bowls/containers and stainless steel spoons/spatulas. A sufficient supply of clean small equipment will be mobilized to the sampling locations to minimize the need for performing field decontamination. Field personnel will change disposable nitrile gloves before collecting each sample and before decontamination procedures and will take precautions Page 19 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 to prevent contaminating themselves with water used in the decontamination process. The following steps will be followed to decontaminate reusable soil and groundwater sampling equipment: ■ The equipment will be washed with a solution of Alconox (or an equivalent detergent) and water. ■ The equipment will be rinsed with tap water. ■ A final rinse will be conducted with distilled or deionized water. Residual sample media from the equipment, used decontamination solutions and associated materials, and disposable contaminated media will be disposed of according to the procedures described in Section 6.0, Management of Investigation -Derived Waste. 4.3 Sample Container and Handling Procedures Soil samples collected for analysis of volatile organic compounds will be collected in accordance with EPA Method 5035. Required containers, preservation, and holding times for each anticipated analysis are listed in Table C-3 (Appendix B). ZGA personnel will be responsible for following the container handling procedures below: ■ Each sample container will be labeled and handled with the date and time sampled, well identification number, project number, and preservative(s), if any. ■ All sample collection information will be documented on a Sample Chain of Custody form; the sample will be placed in a cooler chilled to near 4 degrees Celsius and transported to the laboratory. The FC will check all container labels, chain of custody for entries, and field notes for completeness and accuracy at the end of each day. 4.4 Sample Chain -of -Custody Procedures The written procedures that will be followed whenever samples are collected, transferred, stored, analyzed, or destroyed are designed to create an accurate written record that can be used to trace the possession and handling of the sample from the moment of its collection through analysis and reporting of analytical values. This written record, the Sample Chain of Custody form, will be filled out by the field sampling team at the time the sample is obtained. An example of the Sample Chain of Custody form is included in Attachment A. All samples submitted to the laboratory are accompanied by the Sample Chain of Custody form. This form is checked for accuracy and completeness and then signed and dated by the laboratory sample custodian accepting the sample. At the laboratory, each sample is assigned a unique, sequential laboratory identification number that is stamped or written on the Sample Chain of Custody form. Page 1 10 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 All samples are held under internal chain of custody in the sample control room using the appropriate storage technique (i.e., ambient, refrigeration, frozen). The laboratory project manager assigned to a particular client will be responsible for tracking the status of the samples throughout the laboratory. Samples will be signed out of the sample control room in a sample control logbook by the analyst who will prepare the samples for analysis. The Sample Chain of Custody form will include the following information: client, project name and number, date and time sampled, sample identification, sampler's initials, analysis, and analyte preservative(s), if any. 4.5 Field Quality Assurance Sampling One duplicate soil sample will be collected per approximate 20 soil samples collected during the cleanup action. The QA/QC samples will be assigned a unique sample ID and number. Duplicate samples will begin with the ID "Duplicate", followed by the sample number determined by the sample's order in which it was collected. For example, the second soil duplicate sample collected during the interim action would be labeled Duplicate-02. ZGAfield staff will note the locations of the field duplicates on the Field Report Form and the Soil Sample Summary (Appendix A). 5.0 ANALYTICAL TESTING All compliance samples will be submitted to Friedman & Bruya, Inc., of Seattle, Washington, an Ecology - accredited analytical laboratory, on 24-hour turnaround time. All chemical and physical testing will adhere to EPA's SW-846 (EPA 2007) QA/QC procedures and analyses protocols or follow the appropriate Ecology methods. In completing chemical analyses for this project, the laboratory will meet the following minimum requirements: ■ Adhere to the methods outlined in this SAP, including methods referenced for each analytical procedure. Provide a detailed discussion of any modifications made to previously approved analytical methods. ■ Deliver PDF and electronic data as specified. ■ Meet reporting requirements for deliverables. ■ Meet turnaround times for deliverables. ■ Implement QA/QC procedures discussed in Section 7.0, including DQOs, laboratory quality control requirements, and performance evaluation testing requirements. ■ Notify the project QA/QC manager of any QA/QC problems when they are identified to allow for quick resolution. ■ Allow laboratory and data audits to be performed, if deemed necessary. Page 1 11 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 Z ppe Geo Grr�n�f� saanal Ca�cr.;,:�Fa�s Copies of the Laboratory Quality Assurance Manual from Friedman & Bruya, Inc. are on file at ZGA's offices for review and reference and will be followed throughout the cleanup action. Access to laboratory personnel, equipment, and records pertaining to samples, collection, transportation, and analysis can be provided. Container requirements, holding times, and preservation methods for soil and water are summarized in Table C-3. Sample laboratory analytical results for each analyte will be compared to regulatory limits applicable to the cleanup action. A detailed description of the analytical methods, laboratory practical quantitation limits (PQLs), and applicable regulatory limits for each analyte is provided in Table C-4 (Appendix B). Select soil samples will be submitted for laboratory analysis for the following compounds: • GRPH by Northwest Total Petroleum Hydrocarbon (NWTPH) Method NWTPH-Gx; • Diesel and motor oil -range petroleum hydrocarbons by Method NWTPH-Dx; ■ Benzene, toluene, ethylbenzene, and total xylenes by EPA Method 802113; and 6.0 MANAGEMENT OF REMEDIATION-DERIVED WASTE Contaminated soil, groundwater, and disposable equipment generated during the cleanup action will be handled in accordance with state and federal regulations. The procedures for managing remediation- derived waste for the expected waste streams are discussed below. 6.1 Soil Soil containing COCs that is excavated during the cleanup action at the Site will be segregated from clean overburden soil based on existing laboratory analytical data and field observations, when feasible. If soil is stockpiled for transport, then samples of stockpiled excavated soil will be collected from locations where field instrumentation (i.e., PID) or field observations indicate that contamination is likely to be present and will be collected from a depth of 6 to 12 inches beneath the surface of the stockpile. The number of samples to be collected from the stockpile will be determined by Table 6.9 from Ecology's Guidance for Remediation of Petroleum Contaminated Sites (Ecology 2010; Attachment B). Based on the current development plan, all the soil being excavated from the Site will be removed for off -site disposal. The treatment, storage, and disposal facility will classify the soil being delivered based on the laboratory analytical data provided by the generator. 6.2 Wastewater Wastewater will be generated during the cleanup action in the course of equipment decontamination activities, dewatering activities, and purging water from the wells during compliance groundwater sampling events. Wastewater, as well as groundwater, if present, from the excavation area will be pumped to an aboveground storage tank and removed using a vacuum truck. Page 1 12 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 Z i p pe G e o June 22, 2018 6.3 Disposables Disposable personal protective clothing (e.g., TYVEK suits, rubber gloves, and boot covers) and disposable sampling devices (e.g., plastic tubing, plastic scoops, and bailers) will be placed in plastic garbage bags and disposed of as nonhazardous waste. 7.0 DATA QUALITY OBJECTIVES Field and laboratory activities will be conducted in such a manner that the results be valid and meet the DQOs for this project. Guidance for QA/QC will be derived from the protocols developed for the cited methods within EPA's documents Test Methods for the Evaluation of Solid Wastes Laboratory Manual Physical/Chemical Methods SW-846 (EPA 2007) and the USEPA Contract Laboratory Program, National Functional Guidelines for Organic Data Review (EPA 2008). The DQOs are designed to: ■ Assist the project manager and project team to focus on the factors affecting data quality during the planning stage of the project. ■ Facilitate communication among field, laboratory, and project staff as the project progresses. ■ Document the planning, implementation, and assessment procedures for QA/QC activities for the cleanup action. ■ Verify that the DQOs are achieved. ■ Provide a record of the project to facilitate final report preparation. The DQOs for the project include both qualitative and quantitative objectives, which define the appropriate type of data and specify the tolerable levels of potential decision errors that will be used as a basis for establishing the quality and quantity of data needed to support the cleanup action. To verify that the DQOs are achieved, this SAP details aspects of sample collection and analysis, including analytical methods, QA/QC procedures, and data quality reviews. This SAP describes both qualitative and quantitative measures of data quality to verify that the DQOs are achieved. Detailed QA/QC procedures in the field and at the laboratory are provided in the following sections. The DQOs for the cleanup action will be used to develop and implement procedures to verify that data collected is of sufficient quality to adequately address the objectives of the cleanup action as defined in the CAP. All observations and measurements will be made and recorded in such a manner as to yield results representative of the media and conditions observed and/or measured. Goals for representativeness will be met by verifying that sampling locations are selected properly, that a sufficient number of samples are collected, and that field screening and laboratory analyses are conducted properly. The quality of the laboratory data will be assessed by precision, accuracy, representativeness, completeness, comparability, and sensitivity. Definitions of these parameters and the applicable QC Page 1 13 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 ipperGea Gvapr oda.tisSonsl Can." procedures are described in Sections 7.1 through 7.6. Quantitative DQOs are provided following each definition. Laboratory DQOs have been established by the analytical laboratory. Applicable quantitative goals for these DQOs are listed in Table C-5 (Appendix B). 7.1 Precision Precision measures the reproducibility of measurements under a given set of conditions. Specifically, it is a quantitative measure of the variability of two or more measurements compared to their average values. Precision is calculated from results of duplicate sample analyses. Precision is quantitatively expressed as the relative percent difference (RPD) and is calculated as follows: RPD= (CI-C2) x100 (Ci + C2)/2 Where: RPD = relative percent difference C1= larger of the two duplicate results (i.e., the highest detected concentration) C2 = smaller of the two duplicate results (i.e., the lowest detected concentration) There are no specific RPD criteria for organic chemical analyses. Quantitative RPD criteria for organic analyses will be based on laboratory -derived control limits. 7.2 Accuracy Accuracy is a measure of the closeness (bias) of the measured value to the true value. The accuracy of chemical analytical results is assessed by "spiking' samples in the laboratory with known standards (a surrogate or matrix spike of known concentration) and determining the percent recovery. The accuracy is measured as the percent recovery (%R) and is calculated as follows: %R = (M. - M.) x 100 CS" Where: %R = percent recovery Msa = measured concentration in spiked aliquot M a = measured concentration in unspiked aliquot Csa = actual concentration of spike added Laboratory matrix spikes and surrogates will be carried out at the analytical laboratory in accordance with EPA SW-846 (EPA 2007) and Ecology methods and procedures for inorganic and organic chemical analyses. The frequency of matrix spikes and matrix spike duplicates will each be 1 per batch of 20 samples or less for soil samples. Quantitative percent recovery criteria for organic analyses will be based on laboratory - derived control limits for surrogate recovery and matrix spike results. Page 1 14 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 Z pperGeo :, ch pry €,: ••.iC n al Co ns�iF,�.�E The accuracy of sample results can also be affected by the introduction of contaminants to the sample during collection, handling, or analysis. Contamination of the sample can occur because of improperly cleaned sampling equipment, exposing samples to chemical concentrations in the field or during transport to the laboratory, or because of chemical concentrations in the laboratory. To demonstrate that the samples collected are not contaminated, laboratory method blank samples will be analyzed. The laboratory will run method blanks at a minimum frequency of 5 percent, or one per batch, to assess potential contamination of the sample within the laboratory. 7.3 Representativeness Representativeness is a qualitative assessment of how closely the measured results reflect the actual concentration or distribution of the constituent concentrations in the matrix sampled. The sampling plan design, sample collection techniques, sample handling protocols, sample analysis methods, and data review procedures have been developed to verify that the results obtained are representative of the Site conditions. These issues are addressed in detail in Section 5.0, Analytical Testing, and Section 9.0, Quality Control Procedures, in this SAP. 7.4 Completeness Completeness is defined as the percentage of measurements judged to be valid. Results will be considered valid if they are not rejected during data validation (Section 9.0, Quality Control Procedures). Completeness is calculated as follows: Objectives for completeness are based, in part, on the subsequent uses of the data (i.e., the more critical the use, the greater the completeness objective). The objectives for completeness of samples are expressed as percentages, which refer to the minimum acceptable percentages of samples received at the laboratory in good condition and acceptable for analysis. The objectives of completeness for other samples are 95 percent for soil and water samples. These objectives will be met through the use of proper sample containers, proper sample packaging procedures to prevent breakage during shipment, proper sample preservation, and proper labeling and chain -of -custody procedures. A loss of 5 to 10 percent of intended samples is common, and the goals set are sufficient for intended data uses. The objectives for completeness of chemical analyses are also expressed as percentages and refer to the percentages of analytical requests for which usable analytical data are produced. The initial objective for completeness of chemical analyses in the laboratory is 95 percent. 7.5 Comparability Comparability is a qualitative parameter expressing the confidence with which one data set can be compared with another. The use of standard Ecology and EPA methods and procedures for both sample collection and laboratory analysis will make the data collected comparable to both internal and other data generated. Page 1 15 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 7.6 Sensitivity ZipperGeo- r,�: rirpfes•tor�sl�onau€°.:,��,s Analytical sensitivities are measured by PQLs, which are defined as the lowest level that can be reliably achieved within specified limits of precision and accuracy during routine laboratory operating conditions. PQLs are determined by the laboratory. The specific analytes and their corresponding PQLs that will be required for the cleanup action are presented in Table C-4. The detection or reporting limits for actual samples may be higher depending on the sample matrix and laboratory dilution factors. 8.0 DATA COLLECTION This section outlines the procedures to be followed for the inventory, control, storage, and retrieval of data collected during performance of the cleanup action. The procedures contained in this SAP are designed to verify that the integrity of the collected data is maintained for subsequent use. Moreover, project -tracking data (e.g., schedules and progress reports) will be maintained to monitor, manage, and document the progress of the cleanup action. 8.1 Data Collection Approach Procedures that will be used to collect, preserve, transport, and store samples are described in Section 4.0, Sample Handling and Quality Control Procedures, of this SAP. All sampling protocols will be performed in accordance with generally accepted environmental practices and will meet or exceed current regulatory standards and guidelines. Sampling procedures may be modified, if necessary, to satisfy amendments to current regulations, methods, or guidelines. The data collection approach for key elements of the cleanup action field program will verify the project DQOs are met or exceeded. The key elements include soil samples collected and analytical results used to demonstrate that the concentrations of the chemicals of concern at the limits of the excavation are below applicable cleanup levels as defined in the SAP. The total number of samples collected and specific analyses to be performed will be based on field screening results, field observations, and analytical results for performance and confirmational monitoring. 8.2 Data Types A variety of data will be generated during the cleanup action, including sampling and analytical data. The laboratory analytical data will be transmitted to ZGA as an electronic file, in addition to a hardcopy laboratory data report. This method will facilitate the subsequent validation and analysis of these data while avoiding transcription errors that may occur with computer data entry. Examples of data types include manually recorded field data, such as boring logs, and electronically reported laboratory data. 8.3 Data Transfer Procedures controlling the receipt and distribution of incoming data packages to ZGA and outgoing data reports from ZGA include the following: ■ Incoming documents will be date -stamped and filed. Correspondence and transmittal letters for all reports, maps, and data will be filed chronologically. Data packages, such as those from field personnel, laboratories (such as soil data), and surveyors (elevation data), will be filed by project Page 1 16 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 _71ppe task, subject heading, and date. If distribution is required, the appropriate number of copies will be made and distributed to the appropriate persons or agencies. ■ A transmittal sheet will be attached to all project data and reports sent out. A copy of each transmittal sheet will be kept in the administrative file and the project file. The project manager and project QA/QC officer will review all outgoing reports and maps. 8.4 Data Inventory Procedures for filing, storage, and retrieval of project data and reports are discussed below. 8.4.1 Document Filing and Storage As previously discussed, project files and raw data files will be maintained at ZGA's office. Files will be organized by project tasks or subject heading and maintained by the document control clerk. Electronic project files will be archived for a minimum of 3 years after completion of the project. Electronic copies of files will be maintained in a project directory and backed up daily, weekly, and monthly. 8.4.2 Access to Project Files Access to project files will be controlled and limited to LUP Columbia City LLC and its authorized representatives, Ecology, and ZGA personnel. Electronic access to final reports, figures, and tables will be write -protected in the project directory. 8.5 Data Validation Data quality review will be performed, where applicable, in accordance with the current EPA guidance as set forth in Guidance on Environmental Data Verification and Data Validation (EPA 2002). The following types of QC information will be reviewed, as appropriate: ■ Method deviations ■ Sample extraction and holding times ■ Method reporting limits ■ Blank samples (equipment rinsate and laboratory method) ■ Duplicate samples ■ Matrix spike/matrix spike duplicate samples (accuracy) ■ Surrogate recoveries ■ Percent completeness and RPD (precision) ■ A quality assurance review of the final analytical data packages for samples collected during the cleanup action Page 1 17 Sampling and Analysis Plan Bucky's Complete Auto Repair Project 2 1973.22 Z i p i..,��[`"] e rG eo June 22, 018 C"Praf,,%OonaSConm, 8.6 Data Reduction And Analysis The project manager and project QA/QC officer are responsible for data review and validation. Data validation parameters are outlined as quantitative DQOs in Section 7.0, Data Quality Objectives, of this SAP. The particular type of analyses and presentation method selected for any given data set will depend on the type, quantity, quality, and prospective use of the data in question. The analysis of the project data will require data reduction for the preparation of tables and figures. To verify that data are accurately transferred during the reduction process, two data reviews will be performed, one by the project QA/QC officer or project manager and another by the project principal, before issuing the documents. Any incorrect transfers of data will be highlighted and changed. 9.0 QUALITY CONTROL PROCEDURES This section provides a description of the QC procedures for both field activities and laboratory analysis. The field QC procedures include standard operating procedures for sample collection and handling, equipment calibration, and field QC samples. 9.1 Field Quality Control Field QC samples (e.g., duplicate samples) will be collected during this project and will follow the standard - operating procedures during field screening activities. The procedural basis for these field data collection activities will be documented on the field report forms, as described in Section 11.1, Field Documentation, of this SAP. Any deviations from the established protocols will be documented on the field report forms. 9.2 Laboratory Quality Control Analytical laboratory QA/QC procedures are provided in the Laboratory Quality Assurance Manual that is on file at ZGA's office for Friedman & Bruya, Inc. and summarized below. Laboratory Quality Control Criteria. Results of the QC samples from each sample group will be reviewed by the analyst immediately after a sample group has been analyzed. The QC sample results will then be evaluated to determine whether control limits were exceeded. If control limits are exceeded in the sample group, corrective action (e.g., method modifications followed by reprocessing the affected samples) will be initiated before processing a subsequent group of samples. All primary chemical standards and standard solutions used in this project will be traceable to documented and reliable commercial sources. Standards will be validated to determine their accuracy by comparison with an independent standard. Any impurities identified in the standard will be documented. The following paragraphs summarize the procedures that will be used to assess data quality throughout sample analysis: ■ Laboratory Duplicates. Analytical duplicates provide information on the precision of the analysis and are useful in assessing potential sample heterogeneity and matrix effects. Analytical duplicates are subsamples of the original sample that are prepared and analyzed as a separate Page 1 18 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 sample. A minimum of 1 duplicate will be analyzed per sample group or for every 20 samples, whichever is more frequent. ■ Matrix Spikes and Matrix Spike Duplicates. Analysis of matrix spike (MS) samples provides information on the extraction efficiency of the method on the sample matrix. By performing matrix spike duplicate (MSD) analyses, information on the precision of the method is also provided for organic analyses. A minimum of 1 MS/MSD will be analyzed for every sample group or for every 20 samples, whichever is more frequent. ■ Laboratory Control Samples. A laboratory control sample is a method blank sample carried throughout the same process as the samples to be analyzed, with a known amount of standard added. The blank spike compound recovery assesses analytical accuracy in the absence of any sample heterogeneity or matrix effects. ■ Surrogate Spikes. All project samples analyzed for organic compounds will be spiked with appropriate surrogate compounds, as defined in the analytical methods. Surrogate recoveries will be reported by the laboratories; however, no sample result will be corrected for recovery using these values. ■ Method Blanks. Method blanks are analyzed to assess possible laboratory contamination at all stages of sample preparation and analysis. A minimum of 1 method blank will be analyzed for every extraction batch or for every 20 samples, whichever is more frequent. 9.3 Data Quality Control All data generated by Friedman & Bruya, Inc. will undergo two levels of QA/QC evaluation: one by the laboratory and one by ZGA. As specified in Friedman & Bruya, Inc.'s Laboratory Quality Assurance Manual, the laboratory will perform initial data reduction, evaluation, and reporting. The analytical data will then be validated at ZGA under the supervision of the project QA/QC officer. The following types of QC information will be reviewed, as appropriate: ■ Method deviations ■ Sample transport conditions (temperature and integrity) ■ Sample extraction and holding times ■ Method reporting limits ■ Blank samples ■ Duplicate samples ■ Surrogate recoveries Percent completeness * RPD (precision) Page 1 19 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 ZppeGeo G�o�r:7€t•: s�andi Corsi 4�;E�;s ZGA will review field records and results of field observations and measurements to verify procedures were properly performed and documented. The review of field procedures will include the following: ■ Completeness and legibility of field logs ■ Preparation and frequency of field QC samples ■ Equipment calibration and maintenance ■ Sample Chain of Custody forms Corrective actions are described in Section 10.0, Corrective Actions. 9.4 Data Assessment Procedures The project manager and project QA/QC officer are responsible for data review and validation. Upon receipt of each data package from the laboratory, calculations using the equations presented for precision, accuracy, and completeness will be performed. Results will be compared to quantitative DQOs, where established, or qualitative DQOs. Data validation parameters are outlined in Section 7.0, Data Quality Objectives, of this SAP. 9.5 Performance Audits Performance audits will be completed for both sampling and analysis work. Field performance will be monitored through regular review of Sample Chain of Custody forms, field forms, and field measurements. The project manager and/or the project QA/QC Officer may also perform periodic review of work in progress at the Site. Accreditations received from Ecology for each analysis by Friedman & Bruya, Inc. demonstrate the laboratory's ability to properly perform the requested methods. Therefore, a system audit of the analytical laboratory during this project will not be conducted. The project manager and/or project QA/QC officer will oversee communication with the analytical laboratory on a frequent basis while samples are being processed and analyzed at the laboratory. This will allow ZGA to assess progress toward meeting the DQOs and to take corrective measures if problems arise. The analytical laboratory will be responsible for identifying and correcting, as appropriate, any deviations from performance standards as discussed in Friedman & Bruya, Inc.'s Laboratory Quality Assurance Manual. The laboratory will communicate to the project manager or the project QA/QC officer all deviations to the performance standards and the appropriate corrective measures made during sample analysis. Corrective actions are discussed in Section 10.0 of this SAP. 10.0 CORRECTIVE ACTIONS Corrective actions will be the joint responsibility of the project manager and the project QA/QC officer. Corrective procedures can include the following: Page 1 20 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 ■ Identifying the source of the violation. ■ Reanalyzing samples, if holding time criteria permit. ■ Resampling and analyzing. • Re -measuring parameter. ■ Evaluating and amending sampling and analytical procedures. ■ Qualifying data to indicate the level of uncertainty. L ppe Leo G�oP�:�€�tisiUnnl Cr, r5u'i�.�E3s During field sampling operations, the project manager and field staff will be responsible for identifying and correcting protocols that may compromise the quality of the data. All corrective actions taken will be documented in the field notes. 11.0 DOCUMENTATION AND RECORDS Project files and raw data files will be maintained at ZGA's office. Project records will be stored and maintained in a secure manner. Each project team member is responsible for filing all necessary project information or providing the information to the person responsible for the filing system. Individual team members may maintain files for individual tasks, but team members must provide such files to the central project files upon completion of each task. A project -specific index of file contents will be kept with the project files electronically. All electronic data will be maintained in the database at ZGA. All sampling data will be submitted to Ecology in both printed and electronic formats pursuant to WAC 173-340-840(5) and Ecology's Toxics Cleanup Program Policy 840 (Data Submittal Requirements). 11.1 Field Documentation Documentation of field activities will be included on Field Report forms, Sample ID Labels, Soil Sample Summary form, Waste Material Labels, Material Import and Export Summary forms, and Sample Chain of Custody forms, examples of which are provided in Attachment C. Field forms will be scanned and saved to an electronic project folder. Original and copied forms will be filed in a binder that will be maintained by the project manager. Field personnel will be required to keep a daily field log on a Field Report form. Field notes will be as descriptive and as inclusive as possible, allowing independent parties to reconstruct the sampling situation from the recorded information. Language will be objective, factual, and free of inappropriate terminology. A summary of each day's events will be completed on a Field Report form. At a minimum, field documentation will include the date, job number, project identification and location, weather conditions, sample collection data, personnel present and responsibilities, field equipment used, and activities performed in a manner other than specified in the SAP. In addition, if other forms are completed or used (e.g., Sample Chain of Custody form), they will be referred to in and attached to the Field Report form. Field personnel will sign the Field Report form. An example of the Field Report form is included in Attachment A. Page 1 21 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 11.2 Analytical Records pper&-_�o 6T,{+iY• � �f c�5 • �' � L1 i �rl f}S u d;�F.Y> Analytical data records will be retained by the laboratory and stored electronically in the ZGA project file and project database. For all analyses, the data reporting requirements will include those items necessary to complete data validation, including copies of all raw data. The analytical laboratory will be required to report the following, as applicable: project narrative, chain -of -custody records, sample results, QA/QC summaries, calibration data summary, method blank analysis, surrogate spike recovery, matrix spike recovery, matrix duplicate, and laboratory control sample(s). 12.0 HEALTH AND SAFETY PROCEDURES Field personnel will adhere to health and safety procedures that will be detailed in a project -specific Health and Safety Plan (HASP), which is included as Appendix D of the CAP. The health and safety and emergency response protocols outlined in the HASP are designed to ensure compliance with state and federal regulations governing worker safety on hazardous waste sites. The U.S. Department of Labor has published final rules (Part 1910.120 of Title 29 of the Code of Federal Regulations, March 6, 1990) that amend the existing Occupational Safety and Health Administration standards for hazardous waste operations and emergency response. Within Washington State, these requirements are addressed in WAC 296-843, Hazardous Waste Operations. These regulations apply to the activities to be performed at this Site as a site remediation, or cleanup, under Resource Conservation and Recovery Act 1976 and/or MTCA. Subcontractors to ZGA are required to prepare and effectively implement their own HASP based on their unique scope of work and professional expertise. Each subcontractor's HASP must comply with all applicable federal, state, and local regulations. The subcontractor's HASP should employ appropriate best practices to protect all personnel working on the Site, as well as the public, and to prevent negative impacts to the project or Site. The responsibilities of ZGA for safety on this Site are limited to the following: ■ Implementation of the provisions of this HASP for the protection of its employees and visitors on the Site to the extent that the Site and its hazards are under the control of ZGA. ■ Protection of the Site, other personnel, and the public from damage, injury, or illness as a result of the activities of ZGA and its employees while on the Site. ■ Provision of additional safety -related advice and/or management as contractually determined between the parties. It is anticipated that all field work will be performed during the cleanup action in Level D personal protective equipment. Potential hazards that may be encountered during the cleanup action field activities include exposure to contaminants; traffic/mobile equipment; process hazards; unstable ground; noise exposure; overhead and underground utilities; slips, trips, and falls; powered tools and equipment; working around heavy equipment; rolling and/or pinching objects; and exposure to weather conditions. Page 1 22 Sampling and Analysis Plan Bucky's Complete Auto Repair Project No. 1973.22 June 22, 2018 13.0 REFERENCES .; eGeo C rprs;,l:��.•.o: al COnsh `;;.'�� ats U.S. Environmental Protection Agency (EPA). 1998. Guidance Document for Quality Assurance Project Plans. Publication EPA QA/C-5, EPA/600/R-98/018. 2002. Guidance on Environmental Data Verification and Data Validation. EPA QA/G-8. 2004. National Contract Laboratory Review Program, National Functional Guidelines for Inorganic Data Review. EPA 540/R-04/004. 2007. Test Methods for Evaluating Solid Wastes, Laboratory Manual Physical/Chemical Methods. Final Update IV. EPA SW-846. . 2008. National Contract Laboratory Review Program, National Functional Guidelines for Organic Data Review. EPA 540/R-99/008. Washington State Department of Ecology (Ecology). 2003. Guidance for Site Checks and Site Assessment for Underground Storage Tanks. Publication No. 90-52. . 2004. Guidelines for Preparing Quality Assurance Project Plans for Environmental Studies. Publication No. 04-03-030. . 2008 Guidelines for Property Cleanups under the Voluntary Cleanup Program. Publication No. 08-09-044. July. Revised July 2015. . 2010. Guidance for Remediation of Petroleum Contaminated Sites. Publication No. 10-09- 057. November. Revised June 2016. Page 1 23 APPENDIX A FIGURES o m n v o v— co c o U :5 m E m y u m m 30 a u O¢ o O CO W T N N G a c T a t a sr o o v E o t o t t v s _. `. 'o a° a�i ¢ ' E¢ ' Z a w a ~ E ¢ v¢ UH o v¢ v? a n o o U o U UZ z v Z a a m a2iO c U v n nt z o U v'o .� z m d yin E Z a Z u Z m o— = m �. K 0 U � U n w N o m °� ro w c m °� r `° a r LLJ m n a 0 n O o o O o c m ¢ m ¢ a -¢ w w d w 9 u v m N a N a d N a ¢ L E ¢ L W v (LLJ D m m m m m W ED _L e N �/ m v m - o 3 a v a t v _ v E E a� o n v c v o v U U un w a 7 o D O w ¢ rnm U' C7 o — wo~ a m 3 o E oo o ¢ m v o A w ¢mom' n O O dm�ntU n 'v ct w3 �co aa= E W W w �U 0 E moo o to m ;v¢a�� u o o U m x o a `m M c c W rnt u ¢ o � m t U as N m w w :L' Q m W d o. v ' E E co m N m 7 m m r W U Q 1 Q m ❑ m �- 00 J U) m rn m E] tk n m 1� M m O m i m A lku��A �m Q �— F- :2 X j J a U N W 1 1� lr Wm O m m H-Lnos AVMHJIH OIJIOVd ) 2� NI guns ONno S amge d O LU 2 % CD o r \ \ / / \ \\ 2 k\ } // w_ `;;^~ \ / ���.� 2 ; \f ,., ... ¥ `\� c n o § \ ►]§;§ \ \ § ( § § \ _ 3 ƒ� ,«« © e!§ ,>§ ) } \ R )m \ of - \ §/ ) 'IfN ) \ f w r 0W<}t ; § 2LL °�° /§ ) \- tea® e A00 ) w � G:oe2 j ° (/ J °`------�-- k )[ wwww} ev) / LL § } �'� , § 9 _ \ ,e\$■ ,G Z [j�§ e kg ƒ LL LL ` F. �� (}G\) \ Z. 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( / f | 1 _ 2+ q govns ONno S »mge Q o z LU. ; ] e)§ k APPENDIX B TABLES a) m Q. O a` N � L I'm 0 c a a o 0 d d � � _ 3 w V L A d E rn� ° o = a 2 m m m m c d a E aN v d Ernii CLL)m V1 Y m a w L a) C a CD C a a) C m a 0 C 0 a 0 C a a 0 C _0 0 Y 0 E O C c O 0 O N p a 0 Ocn 0 N O A O rn c 0 � c 7 O) C_ N C C O N C O m 0 c a 2 _ m .E m m n c O :� .0 y W a o V C co Q t0 m O 0 ADC a)tm N Y C o E U m a` w m c) ri v iii iDr Y fq Y y Y N Y fn Y N Y N F N 'Ill F I FM H E c ! \ \ _ § \| )!!- �■ q j ) ! s ; ), _ ] ! \{! : \ _ tj— �— ;;■ § (!! { j 22.— ] /! !!'2 !�1 �) !««,f;;:• , 3,t !Z_ / /)! _ \\\)\\\\ i\ ;\\ OR _t?5 k| !| r { ! _ ! | ® & § E � , / E /0 CD �CL §/ }} 2E 0 SCD \ ) 0 o \/ 0 ) E° E m m « « \ \ \ 2 $ $ - ° � l 00 { \ f \ \ \ \ \ ) b \ > \]f)« f 5 & 2 m t \\{ in 2 a o c e o 0 J cc m \ ) ) ) \ j j\ n � N EI 2G ; tL CL E a) 0 E § / , < /) < k§ > f E k> Z> a w w C-J E u JE § » J \ _ E { o - n § A 3 k / a- m \ \ - A = = G = Co \ / \ § \ ) 0 \ } _ o ± R ± k \ / \ } ` \}\ ( \} c c = = c = 0 z 0 m� O r (O m b 0 O 0 O O Op O O O Op N E p .� u7 uJ f, d J A f.1 N p .Q a Q :r d b p N N O N O fl O O O O O In v v v M a v v N V V o V 0 v 0 v o v V y N V v 6 L J m J \ J J J J J h E E E E E E E a m m m m m m m m yN cD N N N N m N �m N m N y [ p p co apo (7 T 2 p 2 aoo a R. a L L L L L t L y a a a a z z m m a a c w w w w w w w w a> m N N = z x a r x= a a a a a > a c7 Q❑ m r w — x 0 0 0 m� L w — x I r m 0 i W 6 u w \ƒ A0 0 /�CL // cy _2#m k0 \ <k� 0 oƒjf \§ � 3] « � \ �2j= v � o � �ƒ CD §}} 66 cn , \) \\ Cl �$ Raga f=£ as k0 Q ® ® »0 \}27 2 z Z ) < < I�f) I� §\ K\±$ APPENDIX C PROJECT FORMS Zipper Geo Associates�LLC Field Report Daily Field Report No. Date: Project: ZGA Project No.: Client: Contractor: ZGA Field Rep.: Location: Arrival/Departure Time: Permit No.: Weather: Equipment Used: REVIEWED Page of This field report presents the results of our on -site testing as well as the observations and opinions of the field representative regarding the contractor's activities. The contractor is responsible to complete the project in accordance with the approved plans and specifications regardless of our presence on site and our observations and test results. Our services do not include supervision or direction of the contractor's work of that of its subcontractors or responsibility forjob site safety. 19023 — 36th Avenue West, Lynnwood, Washington 98036 (425) 582-9928 / FAX (425) 582-9930 L E E m L O Q W M _0 z r ar m U G1 O L a a E •L aU m L 0 LL L a N m C E m -0m Q !n u ++ A) N a a m Ln 0 N c 0 �a `v O i O 0 � a 0. a L � Y N a v v o -- v _E v ~ o u lu d Y Y V m v 0 u a 0 Z v a E ro Ln FRIEDA,4.kN & BRUYA, INC. cl;c---- $anlpic In.- D,�-ce 1 TI.— .7 -olic �:Z: el a --A P z uj Z- 0 U- 0. wl C.) X 0 m 0 Ol z 0 tin ct a w H a co) s F N O W U z o y CD w tz a a Z bn a' N w "d b N u) z a C C E� r. m m P4 A P- 9 O a � o w b. �Tz, U N a W o " a N o P� co PL rig U Q +, U v 0 z A W F W A W w z HIC91 v 8•00a dd9 Aq spajo Q 8 VHOH DOM via Aq sO0r1 Y'J'Hd,L "N �q HddD XQ'Hd,L "N Aq HdHO V HdHQ wM 0 y y F cz m m P. A cz co �A �y a � ro �A O Q. y RS Q m W E- W A a 0 U W E-� z P4 Pi di z C � c N O O NN j � U op °o U O U a cy fia co GL C L-- APPENDIX D HEALTH AND SAFETY PLAN HEALTH & SAFETY PLAN APPENDIX D OF CLEANUP ACTION PLAN BUCKY'S COMPLETE AUTO REPAIR ke-r, it% 30924 PACIFIC HIGHWAY SOUTH FEDERAL WAY, KING COUNTY, WASHINGTON ZGA Project No. 1973.22 June 22, 2018 Prepared for: Farrell Property Investments `•_FI?EE 7ow,lur Zi p p e r, G e- o Gecprole-•siwis-1 ConsuIonb Bucky's Complete Automotive Repair 30924 Pacific Highway South, Federal Way WA Project No. 2036.22 TABLE OF CONTENTS 1.0 PROJECT SUMMARY...................................................................................................1 2.0 INTRODUCTION............................................................................................................1 2.1 PROJECT DESCRIPTION..............................................................,...,................................I.........._._...._.. 1 2.2 HASP DISTRIBUTION............................................................................................................................ 2 2.3 ORGANIZATIONAL STRUCTURE....................................................--............_.....................................2 2.3.1 Project Manager.................................................................................................................................. 2 2.3.2 Project Health and Safety Manager..................................................................................................... 3 2.3.3 Site Safety Officer ............................. ................................................................................. ............ ._.... 3 3.0 CHEMICAL HAZARD EVALUATION.............................................................................. 3 3.1 TPH (Total Petroleum Hydrocarbons)...,.............................................................................................. 4 3.2 BTEX (benzene, ethyl benzene, toluene, and xylenes)...................................................................... 4 3.4 POTENTIAL EXPOSURE ROUTES.......................................................................................................... 4 3.4.1 Inhalation .......................... ............ ....................................................................................................... 4 3.4.2 Skin Contact.................................................................................................................. 3.4.3 Ingestion.............................................................................................................................................. 5 4.0 OTHER HAZARDS......................................................................................................... 5 4.1 PHYSICAL HAZARDS.....................................................................................................6...................... 5 4.2 HEAT STRESS........................................................................................................................................ 7 5.0 REMEDIAL EXCAVATION & GROUNDWATER SAMPLING ....................................... 7 5.1 AIR MONITORING................................................................................................................... .......... 8 5.2 SOIL SAMPLING......................................................................... ...................... 9 5.3 GROUNDWATER SAMPLING............................................................................................................. 9 6.0 PERSONNEL PROTECTIVE EQUIPMENT.................................................................... 9 6.1 LEVEL D ACTIVITIES............................................................................................................................. 9 6.2 MODIFIED LEVEL D ACTIVITIES........................................................................................................... 9 6.3 SAFETY EQUIPMENT LIST..................................................................................................................10 7.0 SITE CONTROL........................................................................................................... 10 7.1 EXCLUSION ZONE.............................................................................................................................10 8.0 CONTAMINATION........................................................................................................10 Bucky's Complete Automotive Repair 30924 Pacific Highway South, Federal Way WA Project No. 2036.22 8.1 MINIMIZATION OF CONTAMINATION.... .................... .................. — .... -- ......... ..................... 10 8.2 EQUIPMENT DECONTAMINATION...........................................................................................:..:.... 11 8.3 SITE CONTROL.................................................................................................................... .....11 8.4 SPILL CONTAINMENT...................................................................................... .. .................... 9.0 EMERGENCY RESPONSE PLAN.................................................................................. 11 9.1 PLAN CONTENTAND REVIEW............................................... ............................................................. 11. 9.2 PLAN IMPLEMENTATION..................................................................._............................................_... 12 9.3 EMERGENCY RESPONSE CONTACTS..... .........................................._.._.............................................._.12 9.4 FIRES..................................................................................................... ...........................................13 9.5 MEDICAL EMERGENCIES..................................................................................................................... 13 9.6 PLAN DOCUMENTATION AND REVIEW ................................................:............................................. 13 10.0 TRAINING REQUIRMENTS.......................................................................................... 14 LIST OF FIGURES FIGURE 1 - Route to Nearest Hospital (Directions and Map) FIGURE 2 - Record of Health and Safety Communication LIST OF TABLES TABLE 1- Activity Hazard Analysis TABLE 2 - Potential Emergency Hazards and Responses TABLE 3 - Emergency Contingency Information Bucky's Complete Automotive Repair 30924 Pacific Highway South, Federal Way WA Project No. 2036.22 1.0 PROJECT SUMMARY Site Name — Bucky's Complete Auto Repair Location — 30924 Pacific Highway South Land Use of Area Surrounding Facility — Light industrial and commercial Project Activities — Remedial excavation, soil and groundwater sampling Potential Site Contaminants — Total petroleum hydrocarbons (TPH), benzene, ethylbenzene, toluene, and xylene (BTEX) Routes of Entry — Skin contact with soil; incidental ingestion of soil; and inhalation of airborne droplets, dusts, or vapors Protective Measures — Safety glasses, gloves, steel toed boots, hard hats, and protective clothing Monitoring Equipment — Photoionization Detector 2.0 INTRODUCTION This site -specific Health and Safety Plan (HASP) provides procedures to minimize the risks to on -site workers from chemical exposure and physical accidents. The HASP covers elements as specified in 29 Code of Federal Regulations (CFR) 1910.120 or equivalent Washington State Department of Labor and Industries regulations. Zipper Geo Associates, LLC (ZGA), its subcontractors, and clients do not guarantee the health or safety of any person entering this site. Because of the nature of this site and the activity occurring there, it is not possible to discover, evaluate, and provide protection for all possible hazards that may be encountered. Strict adherence to the health and safety guidelines in this plan will reduce, but not eliminate, the potential for injury at this site. The health and safety guidelines in this plan were prepared specifically for this site and should not be used on any other site without prior research and evaluation by trained health and safety specialists. 2.1 PROJECT DESCRIPTION The project site is located at 30924 Pacific Highway South in Kent, Washington and is identified as King County tax parcel #4073200129. The Property is located at 30924 Pacific Highway South in Federal Way, King County, Washington. The Property is identified as King County Tax Parcel No.785360-0215. The Property is located within a mixed commercial and residential area in the City of Federal Way. The Property comprises 0.61 acres and is developed with a 5,062 square -foot one-story wood frame structure constructed in 1987, and a 6,002 square -foot one story wood frame structure constructed in 1946. The Property is currently occupied by Bucky's Complete Auto Repair, hair salon, and martial arts studio. 1 Bucky's Complete Automotive Repair 30924 Pacific Highway South, Federal Way WA Project No. 2036.22 Confirmed chemicals of concern, as identified in the Remedial Investigation report include • Gasoline and diesel -range petroleum hydrocarbons, benzene, toluene, ethylbenzene, and xylenes (BTEX) in soil. This HASP addresses field activities entailed in completing the following planned work tasks: • Three quarters of pre -remedial excavation groundwater monitoring and sampling. • Remedial excavation, export, and disposal of petroleum contaminated soil (PCs). 2.2 HASP DISTRIBUTION This HASP pertains solely to ZGA personnel and ZGA subcontractors involved. For subcontractors, this HASP represents minimum safety procedures. Subcontractors are responsible for all of the safety guidelines addressed in this HASP, as well as any other general safety and health practices not addressed in this HASP. Other consultants and/or subconsultants are independently responsible for the health and safety of their own employees on the project. 2.3 ORGANIZATIONAL STRUCTURE All employees and workers on this project are expected to maintain vigilance at all times to ensure that the work is conducted in a safe and efficient manner. To provide an organizational structure that supports this objective, the following individuals are assigned specific responsibilities and lines of communication for the duration of this project. 2.3.1 Project Manager Charles Cacek of ZGA is the designated Project Manager for this project. He is responsible for overall administration of the project. His duties include project planning, budgeting, communications, and coordination. The Project Manager may delegate all or part of his or her authority and responsibility to other designated ZGA representatives. 2 Bucky's Complete Automotive Repair 30924 Pacific Highway South, Federal Way WA Project No. 2036.22 2.3.2 Project Health and Safety Manager Jeff Tinklepaugh of ZGA is the Project Health and Safety Manager (HSM), and has the responsibility and authority to oversee the development, revision, and approval of this site HASP and to audit implementation of the plan in the field. The HSM is also responsible for reviewing health and safety issues that may arise during the project, coordinating changes in personal protective equipment (PPE) requirements, conducting major accident investigations, and conducting periodic site audits and inspections. The HSM or his designated representative has discretionary authority to shut down this project. This project may not start until the HSM has approved this site -specific HASP. 2.3.3 Site Safety Officer Charles Cacek is the designated Site Safety Officer (SSO). He is responsible for verification and overall compliance with this HASP. His duties include, but are not limited to 1) on -site monitoring to determine appropriate levels and use of PPE; 2) site surveillance, hazard identification, and health risk analysis; 3) implementation of procedures and programs to evaluate risk to site personnel, including initiating changes to the HASP; 4) implementation of site control measures; 5) assisting in conducting and documenting daily health and safety briefings; 6) maintaining health and safety field log books; 7) providing summaries of field operations and progress to the Project Manager; and, 8) informing ZGA and ZGA subcontract personnel on the content of this HASP. 3.0 CHEMICAL HAZARD EVALUATION Based on existing site information, gasoline and diesel range TPH and BTEX are present at the site above human health risk -based criteria as determined for a conservative exposure setting for unrestricted land use. Human health hazards of these chemicals are discussed below. This information covers potential toxic effects that might occur if relatively significant acute and/or chronic exposure were to happen. This information does not mean that such effects will occur from the planned site activities. In general, the chemicals that may be encountered at this site are not expected to be present at concentrations that would produce significant exposures. The types of planned work activities, established safe work practices, and personal protective equipment are intended to limit potential exposures at this site. The standards governing potential exposure to the chemicals of concern are presented using the following abbreviations: STEL Short-term exposure limit expressed as a 15-minute time -weighted average and not to be exceeded at anytime during a work day. IDLH Immediately dangerous to life and health TLV Threshold Limit Value. The time -weighted average concentration for an 8-hour work day and a 40-hour work week, to which nearly all workers may be repeatedly exposed, day after day, without adverse effect. 3 Bucky's Complete Automotive Repair 30924 Pacific Highway South, Federal Way WA Project No. 2036.22 3.1 TPH (Total Petroleum Hydrocarbons) TPH includes gasoline -range organics (GRO), diesel -range organics (DRO), and oil -range organics (ORO). The target organs primarily affected by prolonged exposure to petroleum hydrocarbons are the respiratory system, central nervous system, kidneys, liver, and skin. Prolonged dermal contact with petroleum hydrocarbons can cause irritation or dermatitis. 3.2 BTEX (benzene, ethyl benzene, toluene, and xylenes) Benzene is a central nervous system depressant and an eye and skin irritant. Poisoning may cause hemorrhages and immunosuppression. A relationship has been discovered between benzene exposure and leukemia. Benzene is regulated as an occupational carcinogen. Acute exposure may cause dizziness, excitation, weakness, headache, giddiness, breathlessness and chest constriction. Ethyl benzene is a skin, eye and mucous membrane irritant. It is moderately toxic by ingestion and slightly toxic by skin absorption. Ethyl benzene is a central nervous system depressant. Poisoning may affect the liver. Symptoms of exposure may include a sense of chest constriction and nervous disorders. Skin contact may result in first and second degree burns. The odor can be detected at 140 ppm and irritation occurs at —200 ppm. Toluene is an eye, skin and mucous membrane irritant and a central nervous system depressant. Poisoning may affect the liver and kidneys. Prolonged exposure may affect the heart and blood. The ingestion of alcoholic beverages may enhance the toxic effects of toluene. Symptoms of exposure include respiratory tract irritation, headache, dizziness and eye irritation. Toluene may be absorbed to the bloodstream via skin contact. Xylene is a mild eye and mucous membrane irritant, primary skin irritant and a central nervous system depressant. Ingestion causes severe gastrointestinal upset and creates an aspiration hazard. Chronic inhalation results in symptoms that resemble acute poisoning but are more severe systemically. 3.4 POTENTIAL EXPOSURE ROUTES 3.4.1 Inhalation While TPH, BTEX, and naphthalene have moderate to high volatility, there is a low risk of vapor inhalation given the relatively low concentrations of these contaminants at the site. However, inhalation of dust with adsorbed TPH, BTEX, and naphthalene is a potential concern for soils. In either case, the monitoring specified in this plan will prevent exposure to dangerous levels of these contaminants. 4 Bucky's Complete Automotive Repair 30924 Pacific Highway South, Federal Way WA Project No. 2036.22 3.4.2 Skin Contact Exposure via this route could occur if contaminated water and/or soil contact the skin or clothing. Protective clothing and decontamination activities specified in this plan will minimize the potential for skin contact with the contaminants. At a minimum, modified Level D (see Section 6.2) will be used during all sampling collection and handling activities. 3.4.3 Ingestion Exposure via this route could occur if individuals eat, drink, or perform other hand-to-mouth contact in the contaminated (exclusion) zones. Decontamination procedures established in this plan will minimize the inadvertent ingestion of contaminants. 4.0 OTHER HAZARDS 4.1 PHYSICAL HAZARDS Trips/Falls - As with all field work, caution will be exercised to prevent falls and injuries caused by rain slick surfaces, icy surfaces, cluttered work spaces, exposed sharp objects, etc. Work will not be performed on elevated platforms without fall protection. Preventive measures will include wearing non- skid shoes and keeping active areas clear of clutter. Icy conditions may require the use of sand or de- icing materials on flat, hard surfaces. Head Hazards - Hazards include falling objects, overhead work, and bump hazards. Hard hats will be worn by all personnel on site. Foot and Ankle Hazards - Hazards include sharp objects, uneven or slippery walking surfaces, hazardous materials, and dropped heavy objects. When working around heavy equipment or on construction sites, all personnel will wear rugged steel -toed safety boots designed for construction -type activities. Eye Hazards - Eye protection is required in order to prevent eye injuries from contact with chemical or physical agents. Safety glasses will be worn at all times when working around heavy equipment or on construction sites or with hazardous or potentially hazardous materials. Mechanical Hazards - This includes heavy equipment and motor vehicles such as drill rigs and backhoes. All workers will be aware of the risks of serious injury or death potential associated with working around heavy equipment. All workers shall be alerted to the potential of trauma from moving parts on equipment. Personnel will remain in visual contact with the operator of motorized equipment at all times during which the equipment is operational and there is the possibility of injury due to operation of the equipment. Personnel will not walk in the track of, or downhill from moving motorized equipment. While motorized equipment, such as a backhoe, are excavating, sampling personnel will remain outside the working radius of the 5 Bucky's Complete Automotive Repair 30924 Pacific Highway South, Federal Way WA Project No. 2036.22 excavator bucket, or, the personnel will stand behind an imaginary 45-degree line that extends towards the rear of the backhoe from the point where the excavator arm attaches to the body of the machine. Workers shall be instructed to avoid loose clothing so hands and arms won't be pulled into moving parts. All workers should know where the automatic shut-off switch is located on drill rigs. Excavation/Drilling Hazards - Prior to opening or excavating a trench or boring a hole, efforts shall be made to determine whether underground installations of utilities will be encountered. The minimum clearance for direct burial cable is two feet. Air knifing will be used for pre -drilling at select boring locations as a measure to further mitigate the potential for underground utilities to be encounter during drilling. No excavation or drilling should be performed that will operate within 10 feet of electric wiring. Excavation trenches greater than four feet deep will not be entered unless adequate safety precautions as specified in Chapter 296-155 Part N, Excavation, Trenching, and Shoring (WAC 296-155-650 through WAC 296-155-665) are followed. Personnel on -site will not put their heads below the upper edge of a trench. Any variance from this plan must be discussed with and agreed to by the Site Safety Officer. Workers should remain alert to the danger of the sidewalls of the excavation collapsing. Motor Vehicles - One of the leading causes of worker injury is automobile accidents. All workers will have a valid driver's licenses and follow all applicable driving laws. All drivers will wear seat belts at all times. Electrical Hazards - All electrical equipment will be checked prior to commencing operations by site personnel familiar with equipment. Lighting - Field activities performed at night will use adequate lighting for the particular task. Flashlights should be kept in all vehicles to ensure that employees will have light for moving between lighted work areas and for emergency purposes. Confined Space Entry - Personnel will not enter any confined space, such as the active or abandoned storm drain systems or storage tanks without the specific approval of the Project Manager. A specific confined space entry health and safety plan will be written for any confined space entry, and must be reviewed by all top management personnel. Lightning - Work will stop and all personnel will exit the field work site when heavy equipment is in use in the event of a thunderstorm within one mile of the site. 0 Bucky's Complete Automotive Repair 30924 Pacific Highway South, Federal Way WA Project No. 2036.22 Plants and Animals - Outdoor work locations often contain irritant plants and wild animals that may present hazards to workers. When identified at a job site all workers will be informed of these hazards prior to going out on the site. Examples of hazards that have been encountered in the past are wasp nests in ground water monitoring wells and various thorny plants including stinging nettles. 4.2 HEAT STRESS Use of impermeable clothing reduces the cooling ability of the body because of evaporation reduction. This may lead to heat stress. If such conditions occur during site activities, appropriate work -rest cycles and electrolyte -rich fluids (Gatorade® or equivalent) will be used to minimize the effects of heat stress on site personnel. Heat stress monitoring (pulse rates) will be conducted when ambient temperatures exceed 70°F during work activities requiring Level(s) C and D PPE. Each employee will check his or her own pulse rate at the beginning of each break period. Take the pulse at the wrist for 6 seconds, and multiply by 10. If the pulse rate exceeds 110 beats per minute, then reduce the length of the next work period by one-third. For example, if after a one -hour work period at 80 degrees a worker has a pulse rate of 120 beats per minute, the worker must shorten the next work period by one-third, resulting in a work period of 40 minutes until the next break. 4.3 HYPOTHERMIA Hypothermia can result from abnormal cooling of the core body temperature. It is caused by exposure to a cold environment and wind chill. Wetness or water immersion can also result in hypothermia. Typical warning signs of hypothermia include fatigue, weakness, lack of coordination, apathy, and drowsiness. A confused state is a key symptom of hypothermia. Shivering and pallor are usually absent, and the face may appear puffy and pink. Body temperatures below 90° F require immediate treatment to restore temperature to normal. Current medical practice recommends slow rewarming as the treatment for hypothermia, followed by professional medical care. This can be accomplished by moving the person into a sheltered area and wrapping him or her with blankets in a warm room. In emergency situations, when a person's body temperature falls below 90' F and heated shelter is not available, use a sleeping bag, blankets, and body heat from another individual to help restore normal body temperature. 5.0 REMEDIAL EXCAVATION & GROUNDWATER SAMPLING Remedial excavation will be performed with trackhoes, loaders, and dump trucks. Prior to commencing work, the earth work contractor will complete both public and [private utility locates and secure the planned excavation and work area. In orderto minimize potential contact with waste materials, modified Level D PPE, including wearing of hard hat, protective clothing and gloves, and steel -toed boots, will be utilized by drilling operator and sampling personnel who potentially may come in contact with waste materials. In addition, hearing protection and safety glasses will be utilized as appropriate during the drilling operations. 7 Bucky's Complete Automotive Repair 30924 Pacific Highway South, Federal Way WA Project No. 2036.22 5.1 AIR MONITORING Air monitoring and visual observations of the site are required to determine the effectiveness of engineering controls, to re-evaluate levels of protection and determine if site conditions have changed. At minimum, monitoring will be done at the beginning of the work shift and periodically throughout the work. Specific monitoring locations and frequencies are given below. Each piece of monitoring equipment will be inspected and calibrated prior to work start—up. Failure of any of the equipment listed below to work properly must be reported to the Site Health and Safety Supervisor immediately. Work in the exclusion zone is not to continue beyond the monitoring cycle if equipment is not working properly. Air monitoring will be conducted using a photoionization detector (PID). Photoionization Detector —The photoionization detector (PID) will be calibrated daily prior to beginning field activities. Calibration will be conducted according to manufacturer's instructions and be recorded -in the health and safety log book. -Air monitoring in the exclusion zone should be conducted every 30 minutes during excavation or drilling and field operations, and the results recorded in the log book. At a minimum, air monitoring should be conducted once during advancement of each borehole. If on -site personnel detect odors within the exclusion zone, monitoring frequency is to be upgraded at the direction of the SSO. Action Levels: ■ Less than 5 parts per million (ppm) on the PID above background levels at the breathing zone height (averaged over a 1-minute period): Respiratory protection is not required atthis level. ■ 5 to 10 ppm continuous readings in the breathing zone (averaged over a 1-minute period) requires crew to wear Level C PPE with a half mask respirator with combination high efficiency dust filters/organic vapor cartridges in addition to the protective clothing. • 10 to 50 ppm continuous readings in the breathing zone (for 1 minute) requires the workers to wear full -face respiratory protection with combination high efficiency dust filters/organic vapor cartridges in addition to the protective clothing. ■ Levels greater than 50 ppm for a one -minute average requires an evacuation of the work area. Work should not continue until additional readings have been obtained by the Site Health and Safety Supervisor in an appropriate level of protection. Additional ventilation at the work site shall be employed to reduce levels to < 50 ppm. Approximately 5-minute sampling intervals shall elapse to allow gases to vent. M Bucky's Complete Automotive Repair 30924 Pacific Highway South, Federal Way WA Project No. 2036.22 5.2 SOIL SAMPLING ZGA will complete soil excavation oversight soil sampling during remedial excavation work. ZGA staff will not enter the unshored excavation if deeper than 4 feet. During collection of soil samples, modified Level D protective equipment will be utilized, including use of safety glasses where the potential for contact via splash exists. 5.3 GROUNDWATER SAMPLING ZGA will sample groundwater monitoring wells for three (3) quarters prior to remedial excavation. ZGA will utilize traffic cones or delineators to sample wells in trafficked areas. During collection of groundwater samples, modified Level D protective equipment will be utilized, including use of safety glasses where the potential for contact via splash exists. 6.0 PERSONNEL PROTECTIVE EQUIPMENT Work for this project is expected to be conducted in Level D or modified Level D PPE. Situations requiring Level A, B, or C protection (i.e., respirators or supplied air respirators) are not anticipated for this project. If situations are encountered that require these levels, then engineering controls will be initiated to maintain work in modified Level D or upgraded level D protection. If these engineering controls prove to be ineffective, then work will stop, and the HASP will be consulted, and the Project Manager notified in order to devise new strategies for controlling site exposure hazards. 6.1 LEVEL D ACTIVITIES Workers performing site activities where skin contact with free product or heavily contaminated materials is possible will wear chemical -resistant gloves (nitrile, neoprene, or other appropriate outer gloves and nitrile or non -powdered latex inner gloves) and chemical -resistant suits (i.e., polycoated if high splash potential to contaminated liquids) such as Tyvek° or rain gear. The protective clothing and gloves are to be suitable for the types of chemicals that may be encountered on site. Use face shields or goggles as necessary to avoid splashes to the eyes or face. All sampling and soil handling activities for this project are expected to be completed modified Level D as noted below. 6.2 MODIFIED LEVEL D ACTIVITIES Workers performing general site activities where skin contact with highly contaminated materials is unlikely and inhalation risks are not expected will wear regular work clothes, hard hats (if overhead hazard exists), steel toed boots, safety glasses, and non -powdered latex or Nitrile gloves. 01 Bucky's Complete Automotive Repair 30924 Pacific Highway South, Federal Way WA Project No. 2036.22 6.3 SAFETY EQUIPMENT LIST The following Safety Equipment must be available on site: • First aid kit; • Mobile telephone; • Steel toed boots; • Chemical -resistant gloves; • Safety glasses; • Fire extinguisher; ■ Hardhat (when overhead hazards are present). 7.0 SITE CONTROL A single site control zone will be established at the jobsite—an exclusion zone. The exclusion zone is defined as the area where contamination and other site hazards are either known or are likely to be present. There will be no smoking, eating, or drinking within the exclusion zone. The control zone will be configured as described below. However, it is possible that the zone locations may be changed due to work plan revisions. 7.1 EXCLUSION ZONE Exclusion zones will be established around each drilling location. Only persons with appropriate training, PPE, and authorization from the SSO will enter this perimeter while work is being conducted there. 8.0 CONTAMINATION 8.1 MINIMIZATION OF CONTAMINATION To make the work zones function effectively, the amount of equipment and number of personnel allowed in contaminated areas must be minimized. In addition, the amounts of soil, water, or other media collected should not exceed what is needed for laboratory analysis and record/log samples. Use plastic drop cloths and equipment covers where appropriate to minimize hand-to-mouth transfer of contaminated materials. Eating, drinking, chewing gum, smoking, or using smokeless tobacco are forbidden in the exclusion zone. 10 Bucky's Complete Automotive Repair 30924 Pacific Highway South, Federal Way WA Project No. 2036.22 8.2 EQUIPMENT DECONTAMINATION Proper decontamination procedures will be employed to ensure that contaminated materials do not contact individuals and are not spread from the site. These procedures will also ensure that contaminated materials generated during site operations and during decontamination are managed appropriately. 8.3 SITE CONTROL Site control will be the responsibility of the SSO. Any control problems not associated with ZGA's work and/or beyond ZGA's control will be reported to the client or appropriate authorities. 8.4 SPILL CONTAINMENT Bulk chemicals subject to spillage are not expected to be used in this project; therefore, a detailed spill containment plan is not required for this project. Soil and groundwater will be sampled and handled within their respective exclusion zones. Areas outside of the exclusion zone affected by spills will be decontaminated. Chemicals used to decontaminate sampling equipment will be stored and used within the exclusion zone. Liquids containing these chemicals will be stored with other decontamination liquids for later disposal. 9.0 EMERGENCY RESPONSE PLAN This emergency response plan outlines procedures for appropriate response to emergency situations that could occur on this project. Table 2 lists potential emergency hazards associated with this project and immediate responses that should be followed. All site personnel will be expected to identify an emergency situation, notify the appropriate personnel or agency, evacuate the hazardous area, and attempt to control only readily manageable hazards. 9.1 PLAN CONTENT AND REVIEW The principal hazards addressed by the emergency response plan include fire or explosion, medical emergencies, uncontrolled contaminant releases, and other situations such as the presence of chemicals above exposure guidelines or inadequate PPE for the hazards present. To help anticipate potential emergency situations, field personnel shall always exercise caution and look for signs of potentially hazardous situations, including the following examples: ■ Visible or odorous chemical contaminants; ■ Drums or other containers; ■ General physical hazards (traffic, moving equipment, sharp or hot surfaces, slippery or uneven surfaces, etc.); ■ Live electrical wires or equipment; and, 11 Bucky's Complete Automotive Repair 30924 Pacific Highway South, Federal Way WA Project No. 2036.22 ■ Poisonous or dangerous animals. These and other potential problems should be anticipated and steps taken to prevent problems before they occur. The emergency response plan shall be reviewed and rehearsed prior to site activities, as necessary, during the on -site health and safety briefing. This ensures that all personnel will know what their duties are should an actual emergency occur. 9.2 PLAN IMPLEMENTATION The SSO shall act as the lead individual in the event of an emergency. The SSO will determine the need to implement the emergency procedures in concert with other project personnel. Other on -site field personnel will assist the SSO as required during the emergency. In the event that the Emergency Response Plan is implemented, the SSO or designees are responsible for alerting all personnel in the affected area. Emergency evacuation routes and safe assembly areas shall be identified and discussed in the on -site health and safety briefing. The "buddy -system" will be employed during evacuation to ensure safe escape, and the SSO shall be responsible for roll call to account for all personnel. 9.3 EMERGENCY RESPONSE CONTACTS Site personnel must know emergency contacts in the event of Emergency Response Plan implementation. This HASP with the following information will be in the possession of the ZGA SSO while on site: ■ Emergency telephone numbers (Table 4); • Route to nearest hospital (Figures 1a and 1b); and If a significant environmental release of contaminants occurs, the federal, state, and local agencies noted in this plan must be notified as soon as possible and/or in accordance with published reporting requirements. Contact the Project Manager as soon as possible, and the Project Manager will be responsible for notifying one or more of the agencies listed in Table 4. If significant release of contaminants occurs to navigable waters, the Coast Guard and National Response Center must be notified. In the event of an emergency situation requiring implementation of the emergency response plan (fire or explosion, serious injury, tank leak or other material spill, presence of chemicals above exposure guidelines, inadequate personnel protection equipment for the hazards present, etc.) cease all work immediately. Offer whatever assistance is required, but do not enter work areas without proper protective equipment. Workers not needed for immediate assistance will decontaminate per normal procedures (if possible) and leave the work area until authorized to re-enter by the SSO's approval for re -start of work. The following general emergency response safety procedures should be followed. 12 Bucky's Complete Automotive Repair 30924 Pacific Highway South, Federal Way WA Project No. 2036.22 9.4 FIRES Field personnel will attempt to control only very small fires. If an explosion appears likely, evacuate the area immediately. If a fire occurs that cannot be controlled, then immediate intervention by the local fire department or other appropriate agency is imperative. Use these steps: • Abandon the site and head toward a previously agreed upon upwind location; ■ Exit the water as quickly as possible to minimize the risk of hypothermia; • Contact fire agency identified in the site -specific plan; and • Inform Project Manager of the situation. 9.5 MEDICAL EMERGENCIES Contact the agency listed in the site -specific plan if a medical emergency occurs. If a worker leaves the site to seek medical attention, another worker should accompany the patient. When in doubt about the severity of an accident or exposure, always use a conservative approach and seek medical attention. Notify the Project Manager of the outcome of the medical evaluation as soon as possible. For minor cuts and bruises, an on -site first -aid kit will be available. • If a worker is seriously injured or becomes ill or unconscious, immediately request assistance from the emergency contact sources noted in the site -specific plan. Do not attempt to assist an unconscious worker in an untested or known dangerous confined space without applying confined space entry procedures, or without using proper respiratory protection such as a self-contained breathing apparatus (SCBA). • In the event that a seriously injured person is also heavily contaminated, use clean plastic sheeting to prevent contamination of the inside of the emergency vehicle. Less severely injured individuals may also have their protective clothing carefully removed or cut off before transport to the hospital. If it is deemed appropriate to transport the victim to the hospital, follow the route identified on Figures 1a and 1b. 9.6 PLAN DOCUMENTATION AND REVIEW The SSO will notify the Project Manager as soon as possible after the emergency situation has been stabilized. The Project Manager notify the appropriate client contacts and regulatory agencies, if applicable. If an individual is injured, the SSO or her designee will file a detailed Accident Report with ZGA management within 24 hours. 13 Budry's Complete Automotive Repair 30924 Pacific Highway South, Federal Way WA Project No. 2036.22 The Project Manager, the SSO, and ZGA management will critique the emergency response action following the event. The results of the critique will be used in follow-up training exercises to improve the Emergency Response Plan. 10.0 TRAINING REQUIRMENTS All site personnel potentially exposed to hazardous substances, health hazards, or safety hazards and those entering the exclusion zones will have received hazardous waste operation and emergency response training as required by 29 CFR 1910.120(e). The minimum required training is summarized by the following matrix: Personnel Requirements All potentially exposed site personnel 40-Hour HAZWOPER 8-Hour refresher annually 3 days On -the -Job Supervision Site Specific Hazard Communication One worker on site First Aid/CPR and Blood borne Pathogens 14 FIGURES YOUR TRIP TO: E=L-X� 34515 9tta Aire S, Federal Way. Ie k 98003 M1 S nMIN 3.0 mi €a Est. fuel oost;: $0.39 rrtp time based onimme conaltions as or9,13 AM on June 15. � Pfint a full health report of your car with Ht8_ courant Tr&ma: LWA H UM rrehicte diagnostics t8ao? g9S-2501 (� 1_ Start out going south on Pacific Hwy SIWA--99 toward S, 3111th St. YV Then 2.48 miles • - 11 2.45 total miles y 2. Tum right onto S 3411th St_ J s 348th St isjud past S 34Wh Pa' - IF yaa reach S 351af St you Ve gone ab--ut O 2 rwfec too far_ Then 0_24 miles �y 3_ Firm right onto 9th Ave & 1 9fh Ave S is O. y mides pia& 11dT P1 S. tf you reach Sth Ave S you Ve .gone abcut 0.1 mder too far_ Then 0.15 miles 5. "fake the 1 st left. !i you reach S 344th St you've gone about 0.1 miles boo far Then 0.18 miles 5_ Turn slight right Then 0.94 miles & 34515 Sth Ave S. Fedsrst 'Way. WA O-SOOG34701, 3451E 4 i H lVE S if you reach 9th Aire S youVe gone about O. 9 mile: tiro far. 2.713 total males 2.85 total miles 3_01 total miles &04total miles yam` _ t �,.'i•:f.l� S: - 53�te'Sf. � r ti +r 3.Y • s a k'-=.T. h st 5 "21P i= —� - 5 Y2J:n•it •y 1 C •' � 9?Sb:h546 � � f' _.IP_Y I -FedPral-way—� r i rRin M1S I 1 `.s'4x. . .01 t.5•c Y • T 1� A I } •y.. � 3yy _ I i• _ i �-- 'S3AAih5t--- Ekh'S1= t+�,�lYfaiF rimirp 7 Rarnrri of HPalth and Safpty Cnmmimiratinn PROJECT NAME: Bucky's Complete Automotive Center 30924 Pacific Highway South, Federal Way WA SITE CONTAMINANTS: TPH, BTEX, and Naphthalene PPE REQUIREMENTS (check all that apply): _ Safety Glasses —Gloves (specify) _Safety Boots _Clothing (specify) _ Hard Hat _ Respirator (specify) Life Jacket Other (specify) The following personnel have reviewed a copy of the Site -specific HASP. By signing below, these personnel indicate that they have read the plan, including all referenced information, and that they understand the requirements which are detailed for this project. PRINTED NAME SIGNATURE PROJECT DUTIES DATE * Project Manager: Please route a copy of this form to the corporate H&S Manager when completed. TABLES Table 1. Activity Hazard Analysis Activitv Hazard Control Surveying sampling Slipping on wet or oily Wear appropriate slip -resistant boots. locations (bathymetry) surfaces. Skin or clothing contamination Avoid touching or stepping on surfaces with visibly contaminated from surficial contamination. soils, puddles, or stains. Appropriate PPE will be worn. Follow heat stress precautions in Section 3.3.1. Decontamination of Inhalation or eye contact with Wear safety glasses and respirators, if necessary. equipment airborne mists or vapors. Skin contact with Wear modified Level D personal protection (PPE). Tape openings in contaminated liquids. garment. Follow heat stress precautions in Section 3.3.1. Accidental ingestion of Decontaminate clothing and skin prior to eating, drinking, smoking, contaminants. or performing other hand-to-mouth contact activities. Collection of soil Skin contact Follow safety procedures outlined in Sections 4.1, 5.1 and samples by hand w/contaminated soils. 5.2. Sample handling, Skin contact with Wear modified Level D PPE. packaging, and processing contaminated soils and preservative acids. Collecting groundwater Striking overhead obstructions Remove or avoid overhead obstructions, maintain minimum and soil samples and powerlines. 15' clearance from power lines. Contact with mechanical Install guards on all exposed gears and pulleys; inspect equipment; equipment (exposed gears, control work areas. pulleys, etc.). Struck by moving vehicles. Ensure vehicles have back-up alarms; establish traffic zones in work area; chalk all parked vehicles; driver training. Noise. Wear hearing protection when noise level exceeds 85 dB. Heavy lifting. Use mechanical lifting devices; use proper lifting techniques. Contact with contaminated Wear modified Level D PPE. soil. Table 2. Potential Emergency Hazards and Responses Potential Emergency Hazard Response Fire or Explosion If manageable, attempt to put out a small fire with a fire extinguisher. Otherwise, call 911 and evacuate the area and meet at designated area. SSO will take roll call to make sure everyone was evacuated safely. Emergency meeting places will be determined in the field during the tailgate meetings. Medical At least one person with current first aid/CPR training will be on- Emergency/Personal Injury site at all times. This person will attempt to assess the nature and critical path of the injury, call 911 immediately, and apply first aid/CPR if necessary. Stop work and wait for medical personnel to arrive. Fill out a site accident report. Hydraulic Oil Spill or Leak If the leak/spill is small, immediately apply absorbent pads to control the leak and continue work. If the leak/spill is uncontainable, stop work, call 911 immediately, and wait for assistance. Collision Stop work and call 911 for assistance. SSO will assess damage and potential hazards. Table 3. Emergency Contingency Information Subject Information Site Location Bucky's Complete Automotive Repair, Federal Way, Washington Nearest Hospital St. Francis Hospital Emergency Room 34515 9th Avenue South Federal Way, WA 98003 253-835-8100 The route from the facility to the hospital is described in Figure 1. Emergency Police, Fire, and Ambulance ................................ ...... ,...................... 911 Responders .— 800-424-8802 National Response Center... ...................................... USEPA............................................................................ 908-321-6660 Washington Department of Ecology — Northwest Region Spill Response (24-hour emergency response line)._._-....";: ................... 206-649-7000 Emergency Contacts Charles Cacek, Zipper Geo Associates.................................206-300-6237 In Emergency, call for Give the following information: help as soon as possible Where you are (address, cross streets, or landmarks) • Phone numberyou are calling from • What happened —type of injury, accident • How many persons need help • What is being done for the victim(s) • You hang up last —let whomever you called hang up first