Remedial Investigation The following RI activities were completed during this reporting period: August 6, 2010

Transcription

1 August 6, 2 Mr. Ed Jones Washington State Department of Ecology Northwest Regional Office 39 6th Avenue SE Bellevue, Washington Re: Progress Report April through June 2 Art Brass Plating, Seattle, Washington Agreed Order No. DE 5296 Project No A-2 Dear Ed: This progress report summarizes activities conducted on the Art Brass Plating project for the period April through June 2. This work is being completed per the referenced Agreed Order between Art Brass Plating and the Department of Ecology (Ecology). Activities during Reporting Period Activities completed during April, May, and June 2 are summarized below. An exploration location map is provided in Figure. Remedial Investigation The following RI activities were completed during this reporting period: On April 27, 2, Aspect obtained approval to complete the hydraulic studies west of st Avenue South, including a tidal study and slug tests. The tidal study and slug tests were completed in May and June in accordance with the tidal study proposal, Proposed Hydraulic Studies West of st Avenue South, and Ecology s comments. On July 2, 2, a draft of the updated Groundwater Monitoring Plan was submitted to Ecology for their review. The plan contains quarterly sampling plans for the remainder of 2. We coordinated in advance with PSC, Blaser Die Casting, and Capital Industries prior to making a round of water level measurements on May, 2. Water level measurements collected by Art Brass are provided in Table. Groundwater elevation contour maps for the water table, shallow, and intermediate intervals are provided in Figures 2, 3, and 4, respectively. Validation of March 2 groundwater data results by EcoChem, Inc has been completed. Validated results are presented in Table 2. Lab certificates and the EcoChem validation report are provided in Appendix A. e a r t h + w a t e r Aspect Consulting, LLC 4 2nd Avenue S. Suite 2 Seattle, WA

2 Washington State Department of Ecology August 6, 2 Project No C-2 Figures 5 through 8 depict groundwater concentrations of COCs. For monitoring well locations, the March value is presented in Figures 5 through 8. Previous results from groundwater grab samples as well as data from Blaser Die Casting and Capital Industries are also presented on the figures. If multiple grab samples were collected within a given sampling interval, the highest reported value for that interval is depicted on the figure. Quarterly groundwater quality monitoring was completed between June 5th and 24th, 2. Data from June 2 are in the process of being validated by EcoChem. The validated data will be reported to Ecology in the next progress report. Ground surface and top of casing elevations for wells located in the Art Brass monitoring network were surveyed by PLS, Inc. on June 2st. Survey results, reported in Table, were within.-foot of previous survey results, with one exception. The PLS elevation for well PSC-5-25 was.34 feet higher than the older elevation as provided by PSC. By comparing relative elevations from the PLS survey and Aspect s survey results, the PLS elevation was concluded to be the correct value. Interim Action Measures The following activities were completed during this reporting period: Shut down the AS system for a half an hour on April 3th to service the compressor filters. After restarting the compressor, a loose hose clamp was noticed on the outlet and tightened. After changing the filters and repairing the hose clamp, improved performance was noted at the AS wells. The flows to individual wells were more steady, and AS-3 and -4 were sustaining flow (previously had no flow). Shut down the AS system from May 7th to th to facilitate collection of coordinated water level measurements on May th. The final Operation and Maintenance Plan, including as-built information for the modified AS/SVE system and vapor mitigation system at the 22 Findlay building, was submitted to Ecology on May 2. Quarterly groundwater monitoring data from March indicated a slight rebound in TCE concentrations in MW-, located in the heart of the suspected source area. On May 28, following monthly performance monitoring, air sparge flow rates to AS-, -6, -7, -8, and -27 (in the heart of the source area) were increased from 2 to 3 cfm. Subsequent vapor migration monitoring did not indicate that this adjustment had any effect on vapor pressures or concentrations at the monitoring points. Monthly treatment system effluent monitoring on May 28th indicated an exceedance of the change out criteria for the granular activated carbon (GAC) by. ppm. A grab sample of the GAC was collected on June th and submitted to Siemens Water Technologies in Brush Prairie, Washington for profiling in order schedule a change out service. The analytical results were received on July 7th and the waste profile for the GAC was completed. A service date of August 3rd was scheduled with Siemens. Page 2

3 Washington State Department of Ecology August 6, 2 Project No C-2 Shut down the AS system from June th to 7th to facilitate the quarterly groundwater sampling event. Monthly treatment system effluent monitoring on July st, for the month of June, indicated an exceedance of the change out criteria for the GAC by.9 ppm. The analytical results for this sample were received on July 9th, only two weeks before the scheduled change out service, so the system was allowed to continue operation. Performance monitoring of the AS/SVE system in accordance with the draft Operation and Maintenance Plan, including: Monthly monitoring of air sparging and soil vapor extraction system operating parameters, including air flow rate, pressure, vacuum, and VOC/TCE concentrations at each SVE well, vapor sump, trench, and off-gas treatment system; Monthly monitoring of pressure at soil vapor monitoring points using a micromanometer; Monitoring of TCE concentrations at soil vapor monitoring points at points exhibiting positive pressure, using low-level detector tubes; Monthly air sampling for VOCs by EPA Method TO-5 laboratory analysis from the treatment system effluent; Quarterly air sampling for VOCs by EPA Method TO-5 laboratory analysis from the treatment system influent; and Quarterly groundwater sampling at select source area and downgradient monitoring wells in accordance with the approved site-wide groundwater monitoring program, in March 2. Vapor Intrusion The following activities were completed during this reporting period: Sub-slab vapor sampling was conducted at Location 7 (222 S Orcas St) on April 2th in accordance with the Sampling and Analysis Plan for Supplemental Tier 3 Air Quality Monitoring dated March 2th. Sampling results were evaluated and a Tier 3 assessment report (dated May 25th) was submitted to Ecology. Sampling results do not indicate a need for ABP to implement an interim measure to address potential vapor intrusion at this location. Crawl space liners associated with sub-membrane depressurization systems (SMDs) were inspected and repaired on June 28 by Advanced Radon Technologies (ART) at the following locations: A3 (2 S Findlay St) A7 (567 Second Ave S) A5 (25 S Findlay St) A8 (567-½ Second Ave S) A6 (56 Second Ave S) A9 (569 Second Ave S) Page 3

4 Washington State Department of Ecology August 6, 2 Project No C-2 Repairs to the liners included re-sealing seams at joints where the glue was intermittent or failing. The liners were also re-attached to the foundations and supports underneath the structure where feasible. According to ART, some of these liner systems were never truly sealed to the foundation wall when originally installed because of the poor condition and construction of the structure. June groundwater monitoring results were evaluated with respect to VI considerations, in accordance with the requirements of the Groundwater Monitoring Plan. Evaluation results do not indicate the need for additional Tier 3 assessments. The completed evaluation worksheets are attached as Appendix B. Groundwater Monitoring The seventh round of RI quarterly groundwater monitoring was completed in accordance with an approval from Ecology on June 4, 2. Groundwater monitoring was completed between June 5 and 24, 2. Data from June 2 are in the process of being validated by EcoChem. The validated data will be reported to Ecology in the next progress report. Public Communications The project website was updated with an electronic copy of the previous progress report. No other public communications were completed during this period. Anticipated Work in the Upcoming Quarter Work anticipated to be performed during the next progress reporting period (July through September 2) is summarized below. Remedial Investigation The following RI activities are anticipated to be performed during the next reporting period: Submit results from the hydraulic studies west of st Avenue South, including a tidal study and slug tests; Submit a memorandum summarizing the proposed groundwater fate and transport evaluation approach, including recommendations for collecting groundwater seepage samples near the Duwamish; Launch a request to Blaser Die Casting and Capital Industries for an updated groundwater quality data exchange; Finalize the Groundwater Monitoring Plan with quarterly sampling plans for the remainder of 2; and Complete the eight round of quarterly groundwater monitoring. We anticipate conducting this work in September 2. Interim Action Measures The following interim measure activities are anticipated to be performed during the next reporting period: Page 4

5 Washington State Department of Ecology August 6, 2 Project No C-2 Change out of the GAC units for the SVE system is scheduled for August 3rd. Performance monitoring of the AS/SVE system in accordance with the draft Operation and Maintenance Plan, including: Monthly monitoring of air sparging and soil vapor extraction system operating parameters, including air flow rate, pressure, vacuum, and VOC/TCE concentrations at each SVE well, vapor sump, trench, and off-gas treatment system; Monthly monitoring of pressure at soil vapor monitoring points using a micromanometer; Monitoring of TCE concentrations at soil vapor monitoring points at points exhibiting positive pressure, using low-level detector tubes; Monthly air sampling for VOCs by EPA Method TO-5 laboratory analysis from the treatment system effluent; Quarterly air sampling for VOCs by EPA Method TO-5 laboratory analysis from the treatment system influent; and Quarterly groundwater sampling at select source area and downgradient monitoring wells in accordance with the updated Groundwater Monitoring Plan submitted to Ecology in July 2. In accordance with the draft Operation and Maintenance Plan, the next progress report will include interim performance monitoring data, comparison of the effectiveness of the interim measures with design goals, and recommendations to improve system effectiveness, where appropriate. Vapor Intrusion We will work with Ecology and the other Georgetown PLPs to develop a process for shutting down VI mitigation systems that are no longer needed. Groundwater Monitoring The eighth round of RI quarterly groundwater monitoring is planned for September 2. The scope of the quarterly monitoring effort is pending review and approval by Ecology. The 2 Groundwater Monitoring Plan will be updated once agreement is reached with Ecology on the scope of the monitoring effort. Public Communications The project website will be updated with an electronic copy of this progress report and a copy of the memorandum outlining the proposed locations for groundwater monitoring wells for the area west of st Avenue South. We will also post copies of the technical memorandum containing fate and transport approach and hydraulic monitoring results. No other public communications are anticipated in the next quarter. Page 5

6 Washington State Department of Ecology August 6, 2 Project No C-2 The next progress report, which will summarize activities completed from July through September, will be submitted on or before November 8, 2. If you have any questions or comments regarding this report or the project, please call at your earliest convenience. Sincerely, Aspect consulting, LLC Doug Hillman, LHG Principal Hydrogeologist dhillman@aspectconsulting.com Attachments: Table Water Level Measurements Table 2 Validated March 2 Groundwater Monitoring Data Figure Exploration Location Map Figure 2 Groundwater Contour Map, Water Table Interval May 2 Figure 3 Groundwater Contour Map, Shallow Interval May 2 Figure 4 Groundwater Contour Map, Intermediate Interval May 2 Figure 5 Tetrachloroethene (PCE) Occurrence in Groundwater March 2 Figure 6 Trichloroethene (TCE) Occurrence in Groundwater March 2 Figure 7 Cis-,2-Dichloroethene (DCE) Occurrence in Groundwater March 2 Figure 8 Vinyl Chloride Occurrence in Groundwater March 2 Appendix A EcoChem Validation Report and Laboratory Certificates of Analyses Appendix B VI Evaluation Worksheets using June 2 Groundwater Quality Data cc: Mike Merryfield, Art Brass Plating, Inc. William Joyce, Salter Joyce Ziker Tong Li, Groundwater Solutions with link to electronic copy on project website: Janet Knox, Pacific Groundwater Group Peter Jewett, Farallon Consulting Bill Carroll, Arrow Environmental Bill Beck, PSC V:\567 Art Brass Plating\Progress Reports\2 Q2\ABP Progress Report_Apr-Jun.doc Page 6

7 Table - Water Level Measurements Art Brass Plating Well ID Top of Casing Elevation* Ground Surface Elevation* Date of Well Installation Depth to Water (ft) by Measurement Date /8/25 6/29/26 8//28 2/5/28 2/8/28 3/23/29 5/8/29 6/26/29 8/4/29 /23 to 26/29 2/5 to 8/29 2/5/2 5/ and /2 Water Level Elevation* (ft) by Measurement Date /8/25 6/29/26 8//28 2/5/28 2/8/28 3/23/29 5/8/29 6/26/29 8/4/29 AB-CG /2/ AB-CG /8/ MW /5/ MW /5/ MW /5/ MW /5/ MW /24/ MW /24/ MW /24/ MW /8/ MW /8/ MW /2/ MW /7/ MW /8/ MW /9/ MW /9/ MW // MW /7/ MW /8/ MW /7/ MW /3/ MW /8/ MW /6/ MW /6/ MW /2/ MW /2/ MW /7/ MW /7/ MW /8/ MW /8/ MW /8/ MW /8/ MW /9/ MW /9/ MW // MW /9/ MW /3/ MW /3/ MW /3/ PMW /24/ PSC-CG /25/ PSC-CG /25/ PSC-CG /7/ PSC-CG /7/ PSC-CG-38-WT /7/ PSC-CG // PSC-CG /2/ PSC-CG /3/ PSC-CG-42-WT /3/ PSC-CG /6/ PSC-CG-43-WT /6/ PSC-CG /8/ PSC-CG /8/ PSC-CG /25/ PZ /7/ /23 to 26/29 2/5 to 8/29 2/5/2 5/ and /2 Notes *Vertical datum is NAVD88 For the December 28 groundwater monitoring event, the air sparging component of the remediation system was on. This has influenced some of the water levels in wells located within or near the facility. Based on data available from surrounding water table wells, the water level measured at PZ- appears anomalous. The piezometer will be redeveloped and water levels will be reassessed during the May area-wide water level measurement event. Aspect Consulting 8/6/2 V:\567 Art Brass Plating\Progress Reports\2 Q2\Table _Water Level Measurements Table Page of

8 Table 2A - Validated March 2 Groundwater Monitoring Data - Water Table Interval Art Brass Plating 567 Chemical Name Water Table Interval Groundwater Cleanup Level MW--323 MW MW MW MW MW MW MW MW Metals Dissolved Copper in ug/l Dissolved Nickel in ug/l , 47 42, U Dissolved Zinc in ug/l J 4 J 86 J 33 J 4 U 33 J J J 4 U 7 J Total Arsenic in ug/l U Total Barium in ug/l Total Iron in ug/l, 92 6,7,2 4,66 8,85 4 9,4 59,6 26,, 5,6 37,,59 28 Total Manganese in ug/l 2,44 3,34 3,3,27 2,6 8 2,9 2,64, , Volatile Organic Compounds,,-Trichloroethane in ug/l. U U U U U.2 U U U 4. U.2 U.2 U.2 U.2 U.2 U.2 U.2 U,-Dichloroethane in ug/l 47.7 U U U.2.2 U U U.3,-Dichloroethene in ug/l 25. U U U U U.2 U U U 4. U.2 U.2 U.2 U U.2 U,2-Dichloroethane (EDC) in ug/l 2.9. U U U U U.2 U U U 4. U.2 U.2 U.2 U.2 U.2 U.2 U.2 U Chloroethane in ug/l 383. U U U U U.2 U U U 4. U.2 U.2 U.2 U.2 U.2 U.2 U.2 U cis-,2-dichloroethene in ug/l U U Tetrachloroethene (PCE) in ug/l.68. U U U U U.2 U U U 4. U.2 U.2 U.2 U.2 U.2 U.2 U.2 U trans-,2-dichloroethene in ug/l U U U U.2 U U.2 4. U.2 U.2 U.2 U U.2 U Trichloroethene (TCE) in ug/l U U.2 U.2 U U.8 Vinyl chloride in ug/l.28. U U U U U.2 U U U 4. U.2 U.2 U.2 U U.2 U MW MW MW-- 323D MW MW-2-322D MW MW Chemical Name Water Table Interval Groundwater Cleanup Level Metals Dissolved Copper in ug/l 3..4 Dissolved Nickel in ug/l Dissolved Zinc in ug/l 8 4 UJ Total Arsenic in ug/l.42.2 U Total Barium in ug/l Total Iron in ug/l,,3 Total Manganese in ug/l Volatile Organic Compounds,,-Trichloroethane in ug/l. U.2 U.2 U. U.2 U,-Dichloroethane in ug/l 47. U.2 U.2 U U,-Dichloroethene in ug/l 25. U.2 U.2 U. U.2 U,2-Dichloroethane (EDC) in ug/l 2.9. U.2 U.2 U. U.2 U Chloroethane in ug/l 383. U.2 U.2 U. U.2 U cis-,2-dichloroethene in ug/l U.2 U.4 Tetrachloroethene (PCE) in ug/l.68. U.2.2 U. U.8 trans-,2-dichloroethene in ug/l U.2 U.2 U.8.2 U Trichloroethene (TCE) in ug/l U.2 U 8.2 U Vinyl chloride in ug/l.28. U.2 U.2 U. U.2 U Notes Concentrations in shaded cells indicate value exceeds Water Table Interval Groundwater Cleanup Level J - Analyte was positively identified. The reported result is an estimate. U - Analyte was not detected at or above the reported result. UJ - Analyte was not detected at or above the reported estimate MW MW MW PMW PSC-38-WT- 322 PSC-42-WT- 323 Aspect Consulting 8/3/ V:\567 Art Brass Plating\Progress Reports\2 Q2\Tbl2_Validated March 2 GW.xls Table 2A Page of

9 Table 2B - Validated March 2 Groundwater Monitoring Data - Shallow Interval Art Brass Plating 567 Chemical Name Shallow Interval Groundwater Cleanup Level Metals Dissolved Copper in ug/l 3..5 U U.5 U.5 U Dissolved Nickel in ug/l Dissolved Zinc in ug/l 8 4 UJ 4 J 8 4 U 4 U 4 UJ Total Arsenic in ug/l J.8 J U Total Barium in ug/l Total Iron in ug/l, 8,5 223, 239, 23,4 2,5 6,3 Total Manganese in ug/l 45,7, Volatile Organic Compounds,, Trichloroethane in ug/l.2 U U. U.2 U U 25 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U, Dichloroethane in ug/l U 25 U U.2 U.2 U., Dichloroethene in ug/l 25.2 U. U.6 U 25 U U.6.2 U.2 U.2 U.2 U,2 Dichloroethane (EDC) in ug/l U. U.9 U 25 U.9.2 U.2 U.2 U.2 U.2 U.2 U.2 U Chloroethane in ug/l U. U 2.3 U 25 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U cis,2 Dichloroethene in ug/l U 72.2 U.2 U.2 U 2.5 Tetrachloroethene (PCE) in ug/l.68.2 U U. U.2 U U 25 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U trans,2 Dichloroethene in ug/l,4.2 U. U.8 U 25 U.2 U.6.2 U U.2 U.2 U.2 U Trichloroethene (TCE) in ug/l J 79.2 U,3,5.2 U 32.2 U.2 U.2 U.2 U.2 U Vinyl chloride in ug/l.69 2 U. U 4.5 U 25 U U 72.2 U 6 Notes Concentrations in shaded cells indicate value exceeds Shallow Interval Groundwater Cleanup Level J Analyte was positively identified. The reported result is an estimate. U Analyte was not detected at or above the reported result. UJ Analyte was not detected at or above the reported estimate MW MW MW D MW MW MW MW MW MW MW PSC PSC PSC PSC Aspect Consulting 8/6/2 V:\567 Art Brass Plating\Progress Reports\2 Q2\Tbl2_Validated March 2 GW Table 2B Page of

10 Table 2C - Validated March 2 Groundwater Monitoring Data - Intermediate Interval Art Brass Plating 567 Chemical Name Intermediate Interval Groundwater Cleanup Level Metals Dissolved Copper in ug/l Dissolved Nickel in ug/l U Dissolved Zinc in ug/l 8 4 U Total Arsenic in ug/l Total Barium in ug/l Total Iron in ug/l, 8,3 Total Manganese in ug/l 36 Volatile Organic Compounds,, Trichloroethane in ug/l.2 U.2 U.2 U.2 U 4 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U, Dichloroethane in ug/l 47.2 U.2 U.2 U.3 4 U U.2 U.2 U.2 U..6.6, Dichloroethene in ug/l 25.2 U.2 U.2 U.2 U 4 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U,2 Dichloroethane (EDC) in ug/l U.2 U.2 U.2 U 4 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.3.2 U.2 U Chloroethane in ug/l U.2 U.2 U.2 U 4 U.2 U.2 U.8.2 U.2 U.2 U.2 U.2 U U cis,2 Dichloroethene in ug/l 37.2 U.2 U.2 U U.2 U.2 U.9.2 U.5.2 U U.2 U Tetrachloroethene (PCE) in ug/l.68.2 U.2 U.2 U.2 U 4 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U trans,2 Dichloroethene in ug/l,4.2 U.2 U.2 U.2 U 4 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.2 U.3.2 U.2 U Trichloroethene (TCE) in ug/l U.2 U.2 U.3 4,6.2 U.2 U.2 U U.2 U.2 U.2 U.2 U Vinyl chloride in ug/l U.2 U U U.2 U.2 U Notes Concentrations in shaded cells indicate value exceeds Intermediate Interval Groundwater Cleanup Level U Analyte was not detected at or above the reported result. AB AB MW MW MW MW MW MW MW MW MW MW MW PSC PSC PSC Aspect Consulting 8/6/2 V:\567 Art Brass Plating\Progress Reports\2 Q2\Tbl2_Validated March 2 GW Table 2C Page of

11 Legend Direct Push Sample Monitoring Wells Water Table Interval TCE Isoconcentration Line (.8 μg/l) Shallow Interval TCE Isoconcentration Line (3.5 μg/l) Intermediate Interval TCE Isoconcentration Line (3.5 μg/l) Art Brass Plating Study Area STG-GP-4 PSC-S34 PSC-CG-5-25 SPO-44 SPO-45 O H I O AV E S PSC-Q32-G PSC-Y26 PSC-X28 PSC-V3 MW-22-3 PSC-CG STG-GP- STG-GP-5 MW-23-3 MW-23-5 MW-24 MW-24-3 PSC-Q32-D SPO-42 STG-GP-6 PSC-Q32 STG-GP-2 PSC-Q32-A STG-GP-7 PSC-Q32-B STG-GP-9 PSC-CG-43-WT PSC-CG-43-4 E M A RG I N A L WAY ( S R 9 9 ) STG-SVAS- STG-VAS-2 PSC-Q32-E PSC-X23 PSC-CG-42-WT PSC-CG-42-4 STG-GP-8 PSC-CG S F I DA L G O S T U TA H AV E S PSC-S24 AB-CG-42-7 SPO-4 STG-VAS-4 AB-CG-4-7 PSC-CG-4-WT PSC-P26 MW-2-5 MW-2-75 STG-CVAS- SPO-4 STG-VAS-5 STG-CVAS-2 STG-VAS-6 STG-VAS-7 W μg/l PSC-L3 PSC-T2 3.5 μg/l PSC-K28 PSC-J3 S T AV E S MW-7-4 SPO-8 MW-7-6 PSC-R22 W4- S F I N D L AY S SPO- SPO-34 SPO-2 SPO-7 SPO-9 CI-ECS4 SPO-35 PSC-R-59-AA-722 S LU C I L E ST CI-ECS6 CI-ECS7 PSC-CS-22F-GW PSC-CG-38-WT SPO-36 SPO-4 SPO-37 SPO-33 MW-9-6 SPO-22 SPO-23 SPO-2 MW-9-4 S M E A D ST CI-ECS5 CI-ECS3 PSC-59-IA!I Feet MW-8-7 MW-8-5 S B R A N D O N S T S O RC AS S T CI-ECS2 SPO-3 CI-ECS PSC-562-GW CI-ECS CI-B3 PSC-59-SG PSC-R-59-IA-722 PSC-59-IA2 SPO-32 SPO-29 SPO-3 MW-6 MW-6-4 MW-6-75 SPO-3 SPO-2 MW- SPO-28 PSC-M2 SPO-26 SPO-25 PSC-CS-34M-GW PSC-SG-2 PSC-K23 @? 2 N D AV AS-3 PSC-573-AA PSC-573-GW5 BD-PGG-5 PSC-2O-GW BD-PGG-4 PSC-573-IA PSC-573-GW4 BD-PGG-3 BD-PGG-5 PSC-I7 SPO-27 BD-PGG-6 BD-PGG-3 DC-P PSC-573-GW3 BD-PGG-8 BD-PGG-6 BD-PGG-2 BD-PGG-7 PSC-573-GW2 PSC-573-IA2 PSC-5762-IA BD-PGG-4 BD-PGG-8 PSC-5762-SG BD-PGG-9 PSC-573-GW BD-PGG- PSC-5762-GW BD-PGG- BD-PGG-2 PSC-K9 PSC-573-GW9 PSC-CG-34-4 PSC-22M-IA PSC-22M-GW BD-PGG-9 PSC-CG-34-WT PSC-22M-IA PSC-573-GW6 PSC-573-AA2 PSC-22M-SG BD-PGG- PSC-573-GW7 PSC-H7 BD-PGG-7 PSC-22M-AA PSC-CG-36-4 PSC-K2 PSC-CG-36-WT CI-B DC-P7 CI-ECS25 CI-ECS2 CI-ECS2 CI-ECS9 CI-ECS22 CI-ECS23 CI-ECS24 CI-ECS8 CI-B5 CI-ECS26 CI-ECS37 MW-3 MW-5 AS-2 PSC-P7 @? PSC-CG-38-7 MW-7 MW-9 SPO-6 PSC-CG-38-4 MW-5 AS-26 SPO-5 MW-3 PSC-5622-GW SPO-5 SP-3 SPO-3 SP-2 SPO-4 MW-8-3 PSC-27F-GW PSC-5662-GW PSC-N5 SPO-38 SPO-9 CI-ECS7 PSC-59-AA PSC-O9 CI-ECS9 CI-ECS35 CI-ECS36 CI-B2 PSC-J23 PSC-59-GW PSC-CG-39-4 PSC-39-DP SB2_O_B-2 GW2_O_B-2 GW2_O_B- SB2_O_B- CI-ECS33 CI-ECS6 CI-ECS34 PSC-I22 SPO-6.8 μg/l PSC-222-GW CI-ECS5 SP-4 SP-6 PSC-226O-GW MW- CI-ECS4 CI-B4 PSC-H2 3 R D AV E S PSC-P5 AS-5 SPO-8 CI-ECS3 MW- MW--3 PSC-L8 PSC-SG- SP-9 S F I DA L G O S T MW-2 MW-6-3 SP-2 SP-7 SP-4 MW-2 AS-3 SP- SP-3 SP-8 AS-9 PSC-L4 MW-4 MW-4 SPO-2 SP- PSC-38-GW PSC-J6 CI-ECS4 CI-ECS32 CI-ECS27 CI-ECS28 CI-ECS4 CI-ECS3 CI-ECS39 CI-ECS3 CI-ECS38 CI-ECS2 CI-ECS CI-ECS29 SP-5 SPO- PSC-M3 SP-7 4 T H AV E PSC-N PSC-42L-GW PSC-CS-42L-GW PSC-L3 PSC-J5 PSC-F2 ExplorationLocation Map Art Brass Plating Seattle, Washington PSC-42O PSC-46O PSC-44O PSC-CG-33-4 PSC-CG-35-5 PSC-CG-35-4 DC-P6 PSC-42L-SG PSC-42L PSC-564-GW PSC-M9 PSC-I3 PSC-LT-42-IA PSC-LT-42-AA PSC-SG-5 PSC-H4 PSC-42L-GW2 5 T H AV E DC-P3 PSC-576-AA_46 PSC-F6 PSC-Q7 DATE: PSC-K PSC-R58L-AA PSC-CG-3-WT PSC-57B PSC-J9 PSC-CG-3-4 PSC-CG-3-WT DC-P5 PSC-566-GW6 Aug 2 DESIGNED BY: DRAWN BY: REVISED BY: PPW PPW PPW PSC-K8 PSC-52B-SG PSC-52B-GW-27 PSC-58L-GW PSC-R58L-GW PSC-58L-GW-27 PSC-R58L-IA PSC-R58L-IA2 PSC-556-GW PSC-556-AA PSC-R5566-IA PSC-R5566-IA2 DC-P4 PSC-F3 PSC-576-AA2 PSC-576-GW DC-P PROJECT NO. 567 FIGURE NO. PSC-B5 Path:

12 S BRANDON ST I UTAH AVE S PSC-CG-43-WT (8.7) ST AVE S S LUCILE ST 2ND AVE S MW-7 (9.64) 3RD AVE S MW-5 (9.73) MW- (9.78) 4TH AVE S 5TH AVE S MW-3 (9.53) PMW- (9.78) E MARGINAL WAY (HWY 99) PZ- (8.64) S FINDLAY ST MW-9 (9.52) MW-5 (9.3) PSC-CG-38-WT (9.7) MW-8 (9.49) MW-2 (9.84) MW-6 (9.99) 9.8 MW-2 (9.8) MW-4 (9.75) MW-4 (9.79) MW-3 (9.68) PSC-CG-42-WT (8.4) S ORCAS ST MW- (8.94) MW- (9.4) S MEAD ST Legend MW-5 (9.3) Wells Duwamish River MW-24 (8) S FIDALGO ST S FIDALGO ST Well ID water level elevation in feet* Groundwater Contour Map Water Table Interval - May 2 Art Brass Plating Seattle, WA 9..2 ft Groundwater Elevation Contours* * Water level measurements from May th, 2 Vertical datum is NAVD88 Duwamish River Duwamish Channel Circa DATE: Aug 2 DESIGNED BY: DRAWN BY: REVISED BY: PPW PPW PROJECT NO. 567 FIGURE NO. 2 Feet Path: T:\projects_8\Artbrass\RI_Workplan\Delivered\Progress_Reports\August2\2_GW_Contours_WT.mxd

13 S BRANDON ST PSC-CG-39-4 (9.47) I UTAH AVE S PSC-CG-43-4 (7.22) ST AVE S 2ND AVE S 3RD AVE S 4TH AVE S 5TH AVE S S LUCILE ST E MARGINAL WAY (HWY 99) PSC-CG-38-4 (9.6) MW-6-3 (9.94) PSC-CG-35-4 (.2) PSC-CG (5.99) 8. S FINDLAY ST 8.5 MW-8-3 (9.5) 7.5 PSC-CG (6) 7. PSC-CG-42-4 (7.2) S ORCAS ST MW--3 (9.42) MW-9-4 (8.5) 6.5 MW-7-4 (8.36) 6. S MEAD ST Legend MW-22-3 (5.72) Wells Duwamish River MW-24-3 (5.32) PSC-CG-5-25 (5.49) MW-22-3 (5.72) MW-23-3 (6.3) 5.5 S FIDALGO ST PSC-CG-4-4 (6.68) S FIDALGO ST Well ID water level elevation in feet* Groundwater Contour Map Shallow Interval - May 2 Art Brass Plating Seattle, WA 6..5 ft Groundwater Elevation Contours* * Water level measurements from May th, 2 Vertical datum is NAVD88 Duwamish River Duwamish Channel Circa DATE: Aug 2 DESIGNED BY: DRAWN BY: REVISED BY: PPW PPW PROJECT NO. 567 FIGURE NO. 3 Feet Path: T:\projects_8\Artbrass\RI_Workplan\Delivered\Progress_Reports\August2\3_GW_Contours_Shallow.mxd

14 S BRANDON ST I UTAH AVE S ST AVE S 2ND AVE S 3RD AVE S 4TH AVE S 5TH AVE S S LUCILE ST PSC-CG-35-5 (.8) S FINDLAY ST PSC-CG-38-7 (9.7) MW-8-7 (9.69) MW-8-7 (8.62) AB-CG-42-7 (8.3) MW-8-5 (8.6) 9. MW-6-75 (9.) E MARGINAL WAY (HWY 99) 8.5 S ORCAS ST MW-7-6 (8.35) 8. MW-9-6 (8.38) Duwamish River MW-24-5 (5.6) MW-22-5 (5.26) MW-23-5 (5.63) S FIDALGO ST MW-2-5 (7.4) MW-2-75 (7.43) AB-CG-4-7 (6.7) S MEAD ST S FIDALGO ST Legend Well ID MW-22-3 (5.72) water level elevation in feet* Wells Groundwater Contour Map Intermediate Interval - May 2 Art Brass Plating Seattle, WA 6..5 ft Groundwater Elevation Contours* * Water level measurements from May th, 2 Vertical datum is NAVD88 Duwamish River Duwamish Channel Circa DATE: Aug 2 DESIGNED BY: DRAWN BY: REVISED BY: PPW PPW PROJECT NO. 567 FIGURE NO. 4 Feet Path: T:\projects_8\Artbrass\RI_Workplan\Delivered\Progress_Reports\August2\4_GW_Contours_Intermediate.mxd

15 Art Brass Plating Facility Inset Duw am ish River 5 Feet 2 E Marginal Way 5 st Ave S S Lucile St nd Ave S I Water Table Interval Feet Cleanup level for Tetrachloroethene (PCE) in the water table interval is.68 ug/l Duw am ish River E Marginal Way st Ave S S Lucile St th Ave S 2 I! ( Shallow Interval Feet Cleanup level for Tetrachloroethene (PCE) in the shallow interval is.68 ug/l E Marginal Way st Ave S S Lucile St 4th Ave S 8.5 Duw am ish River I Data Updated: ABP - March 2 Capital - July 29 Blaser - August 29 Intermediate Interval Feet Cleanup level for Tetrachloroethene (PCE) in the intermediate interval is.68 ug/l Not Detected, No Exceedance Not Detected (Detection Limit > Cleanup Level) Detected, No Exceedance Detected Above Cleanup Level Groundwater Elev. Contours Maximum detected value for groundwater grab samples and most recent result for monitoring wells (in ug/l) rounded to the nearest whole number. Tetrachloroethene (PCE) Occurrence in Groundwater Art Brass Plating Seattle, Washington DATE: Aug 2 DESIGNED BY: DRAWN BY: REVISED BY: PPW PPW PROJECT NO. 567 FIGURE NO. 5 Path: T:\projects_8\Artbrass\RI_Workplan\Delivered\Progress_Reports\August2\5_PCE_GW.mxd -

16 8. Art Brass Plating Facility Inset Duw am ish River E Marginal Way 5 Feet 5 2 st Ave S S Lucile St nd Ave S I Water Table Interval Feet Cleanup level for Trichloroethene (TCE) in the water table interval is.8 ug/l Duw am ish River E Marginal Way st Ave S S Lucile St th Ave S 5 I Shallow Interval Feet Cleanup level for Trichloroethene (TCE) in the shallow interval is 3.5 ug/l E Marginal Way st Ave S S Lucile St th Ave S Duw am ish River I Data Updated: ABP - March 2 Capital - July 29 Blaser - August 29 Intermediate Interval Feet Cleanup level for Trichloroethene (TCE) in the intermediate interval is 3.5 ug/l Not Detected, No Exceedance Not Detected (Detection Limit > Cleanup Level) Detected, No Exceedance Detected Above Cleanup Level TCE Isoconcentration Line Groundwater Elev. Contours Maximum detected value for groundwater grab samples and most recent result for monitoring wells (in ug/l) rounded to the nearest whole number. Trichloroethene (TCE) Occurrence in Groundwater Art Brass Plating Seattle, Washington DATE: Aug 2 DESIGNED BY: DRAWN BY: REVISED BY: PPW PPW - PROJECT NO. 567 FIGURE NO. 6 Path: T:\projects_8\Artbrass\RI_Workplan\Delivered\Progress_Reports\August2\6_TCE_GW.mxd

17 Art Brass Plating Facility Inset Feet Duw am ish River E Marginal Way st Ave S S Lucile St nd Ave S I Water Table Interval Feet Cleanup level for cis-,2-dichloroethene (DCE) in the water table interval is 72.7 ug/l Duw am ish River E Marginal Way st Ave S S Lucile St th Ave S I Shallow Interval Feet Cleanup level for cis-,2-dichloroethene (DCE) in the shallow interval is 37 ug/l E Marginal Way st Ave S 8 S Lucile St th Ave S Duw am ish River I Data Updated: ABP - March 2 Capital - July 29 Blaser - August 29 Intermediate Interval Feet Cleanup level for cis-,2-dichloroethene (DCE) in the intermediate interval is 37 ug/l Not Detected, No Exceedance Not Detected (Detection Limit > Cleanup Level) Detected, No Exceedance Detected Above Cleanup Level Groundwater Elev. Contours Maximum detected value for groundwater grab samples and most recent result for monitoring wells (in ug/l) rounded to the nearest whole number. cis-,2-dichloroethene Occurrence in Groundwater Art Brass Plating Seattle, Washington DATE: Aug 2 DESIGNED BY: DRAWN BY: REVISED BY: PPW PPW - PROJECT NO. 567 FIGURE NO. 7 Path: T:\projects_8\Artbrass\RI_Workplan\Delivered\Progress_Reports\August2\7_DCE_GW.mxd

18 Art Brass Plating Facility Inset 2 Duw am ish River 5 Feet E Marginal Way st Ave S S Lucile St nd Ave S Feet Water Table Interval 7 I Cleanup level for Vinyl chloride in the water table interval is.28 ug/l Duw am ish River E Marginal Way st Ave S S Lucile St th Ave S I Shallow Interval 3 Feet Cleanup level for Vinyl chloride in the shallow interval is.69 ug/l E Marginal Way st Ave S 9 S Lucile St ! ( th Ave S Duw am ish River ! ( I Data Updated: ABP - March 2 Capital - July 29 Blaser - August 29 Intermediate Interval Feet Cleanup level for Vinyl chloride in the intermediate interval is.69 ug/l Not Detected, No Exceedance Not Detected (Detection Limit > Cleanup Level) Detected, No Exceedance Detected Above Cleanup Level Groundwater Elev. Contours Maximum detected value for groundwater grab samples and most recent result for monitoring wells (in ug/l) rounded to the nearest whole number. Vinyl Chloride Occurrence in Groundwater Art Brass Plating Seattle, Washington DATE: Aug 2 DESIGNED BY: DRAWN BY: REVISED BY: PPW PPW - PROJECT NO. 567 FIGURE NO. 8 Path: T:\projects_8\Artbrass\RI_Workplan\Delivered\Progress_Reports\August2\8_VC_GW.mxd

19 APPENDIX A EcoChem Validation Report and Laboratory Certificates of Analyses

20

21 PROJECT NARRATIVE Basis for Data Validation This report summarizes the results of compliance screening (Level II) performed on groundwater sample data and field and laboratory quality control (QC) sample data for Art Brass Plating quarterly monitoring st Quarter 2. A complete list of samples is provided in the Sample Index. Samples were analyzed by Analytical Resources, Inc. (ARI), Tukwila, Washington. The analytical method and EcoChem project chemists are listed below. Analysis Method Primary Review Secondary Review Volatile Organic Compounds SW826B Jim Hall Christine Ransom Metals SW6B, EPA 2.8 The data were reviewed using guidance and quality control criteria documented in the analytical method; the Quality Assurance Project Plan (QAPP) for Art Brass Plating (Sept. 25, 28); National Functional Guidelines for Inorganic Data Review (USEPA 994 & 24); and National Functional Guidelines for Organic Data Review (USEPA 999).). EcoChem s goal in assigning data validation qualifiers is to assist in proper data interpretation. If values are estimated (assigned a J), data may be used for site evaluation purposes; but reasons for data qualification should be taken into consideration when interpreting sample concentrations. Data that have been labeled as do-not-report (DNR) should not be used for any purpose. Values with no data qualifier meet all data measurement quality objectives and are acceptable for use. Data qualifier definitions, reason codes, and validation criteria are included as Appendix A. A Qualified Data Summary Table is included in Appendix B. Data Validation Worksheets will be kept on file at EcoChem, Inc. A qualified laboratory electronic data deliverable (EDD) is also submitted with this report. cjw 6/4/2 i EcoChem, Inc. l:\aspect 228\22826\22826_cvr.doc

22 SAMPLE INDEX Art Brass Plating st Quarter 2 Total Metals Dissolved Metals SDG Sample ID Lab ID VOA MW QQ6A PSC-38-WT QQ6B MW QQ6C MW-2-322D -799-QQ6D PSC QQ6E MW QQ6F PSC QQ6G MW QQ6H MW QQ6I MW QQ6J PSC QQ6K MW QQ6L MW QQ6M PSC QQ6N PSC QQ6P QQ6 MW QQ6Q MW QQ6R PSC QQ6S MW QQ6T MW QQ6U PSC-38-WT QQ6V MW QQ6W PSC QQ6X MW QQ6Y MW QQ6Z MW QQ6AA MW QQ6AB MW QQ6AC MW QQ6AD MW QQ6AE MW QQ6AF MW D QQ7A PSC QQ7B MW QQ7C MW QQ7D MW QQ7E MW QQ7F MW QQ7G MW QQ7H MW--323D QQ7I QQ7 PMW QQ7J MW QQ7K MW QQ7L MW QQ7M AB QQ7N MW QQ7O MW QQ7P MW QQ7Q MW QQ7R MW QQ7S MW QQ7T 6/4/25:8 PM L:\Aspect 228\22826\22826_Idx QDST.xlsSI Page of 2 EcoChem, Inc.

23 SAMPLE INDEX Art Brass Plating st Quarter 2 Total Metals Dissolved Metals SDG Sample ID Lab ID VOA MW D QQ7U MW QQ7V MW QQ7W MW QQ7X QQ7 MW QQ7Y MW QQ7Z MW QQ7AA MW QQ7AB MW QQ7AC MW QQ8A MW QQ8B MW QQ8C AB QQ8D MW QQ8E MW QQ8F MW QQ8G QQ8 MW QQ8H MW QQ8I MW QQ8J MW QQ8K MW QQ8L MW QQ8M Trip Blank QQ8N Trip Blank QQ8O 6/4/25:8 PM L:\Aspect 228\22826\22826_Idx QDST.xlsSI Page 2 of 2 EcoChem, Inc.

24 DATA VALIDATION REPORT Art Brass Plating st Quarter 2 Volatile Organic Compounds by Method SW826B This report documents the review of analytical data from the analysis of groundwater samples and the associated laboratory and field quality control (QC) samples. Analytical Resources, Inc., Tukwila, Washington, analyzed the samples. Refer to the Sample Index for a list of the individual samples. SDG Number of Samples Validation Level QQ6 9 Groundwater Compliance QQ7 2 Groundwater Compliance QQ8 2 Groundwater, 2 Trip Blank Compliance I. DATA PACKAGE COMPLETENESS The laboratory submitted all required deliverables, with the exception noted below. The laboratory followed adequate corrective action processes and all anomalies were discussed in the case narrative. II. TECHNICAL DATA VALIDATION The QC requirements that were reviewed are listed below. Holding Times and Sample Preservation 2 Matrix Spike/Matrix Spike Duplicates (MS/MSD) Blanks (Method and Field) Field Duplicates Surrogates 2 Reported Results Laboratory Control Samples (LCS/LCSD) 2 Reporting Limits Quality control results are discussed below, but no data were qualified. 2 Quality control outliers that impact the reported data were noted. Data qualifiers were issued as discussed below. Blanks (Method and Field) SDG QQ8: Two trip blanks, Trip Blank and Trip Blank 2, were submitted with this SDG. No target analytes were detected in these blanks. Surrogates SDG QQ6: The recovery of the surrogate compound bromofluorobenzene was less than the lower control limit in the original analysis of Sample MW and in the diluted analyses of Samples PSC and PSC The recoveries of the other three surrogates in each sample were acceptable; therefore no action was taken for the single outliers. cjw6/4/2 VOC - EcoChem, Inc. L:\Aspect 228\22826\22826_VOCa.doc

25 Laboratory Control Samples Laboratory control sample/laboratory control sample duplicate (LCS/LCSD) samples were analyzed at the proper frequency. The percent recovery (%R) values were within the laboratory control limits, with the exceptions noted below. For recoveries greater than the upper control limit, positive results in the associated samples were estimated (J-) to indicate a potential high bias. For recoveries less than the lower control limit, results in the associated samples were estimated (J/UJ-) to indicate a potential low bias. No action was taken if only one of the LCS/LCSD recoveries was outside of the control limits. SDGs QQ6 & QQ7: The recovery for vinyl chloride was less than the lower control limit of 73% for the LCS associated with the 5 ml purge analyzed on 4/2/ on instrument FINN5. The LCSD recovery acceptable; therefore no qualification of data was necessary. Matrix Spike/Matrix Spike Duplicates Matrix spike/matrix spike duplicate (MS/MSD) analyses were performed at the required frequency. The MS/MSD recovery values were within the laboratory control limits, with the exceptions noted below. If the percent recovery (%R) outlier was due to the presence of high levels of the target analyte present in the parent sample, no action was taken. For recoveries greater than the upper control limit, positive results in the parent sample were estimated (J-8) to indicate a potential high bias. For recoveries less than the lower control limit, results in the parent sample were estimated (J/UJ-8) to indicate a potential low bias). No action was taken if only one of the MS/MSD recoveries was outside of the control limits. The following outliers resulted in qualification of data: SDG QQ6: For QC Sample MW , the MS and MSD recoveries of trichloroethene were less than the lower control limits. The reported positive result for trichloroethene was estimated (J-8). Field Duplicates The following acceptance criteria were used to evaluate precision: the relative percent difference (RPD) control limit is 35% for results greater than five times the reporting limit (RL). For results less than five times the RL, the difference between the sample and duplicate must be less than the RL. SDGs QQ6 & QQ7: The data for two sets of field duplicates were submitted: MW & MW-2-323D and MW (SDG QQ6) & MW D (SDG QQ7). All field precision criteria were met. SDG QQ7: One set of field duplicates were submitted: MW--323 & MW--323D. All field precision criteria were met. cjw6/4/2 VOC - 2 EcoChem, Inc. L:\Aspect 228\22826\22826_VOCa.doc

26 Reported Results Several target analytes in the original ml purge analyses exceeded the linear range of the instrument. These results were flagged with an E by the laboratory. The samples were re-analyzed at dilution or with a smaller purge volume; both sets of data were reported. Data that exceeded the linear range were labeled as do-not-report (DNR-2). Results for all other analytes from the dilutions or re-analyses were labeled do-not-report (DNR-). Samples and analytes requiring dilution are as follows: SDG QQ6: PSC : vinyl chloride PSC : vinyl chloride SDG QQ7: MW--323: trichloroethene SDG QQ8: MW : trichloroethene and cis-,2-dichloroethene MW : trichloroethene Reported Results Several samples were analyzed initially at dilutions due to high concentrations of the target analyte trichloroethene. Reporting limits were elevated accordingly. Samples and dilution factors are noted below: SDG QQ7: MW (25x) MW (4x) MW (4x) SDG QQ8: MW (5x) III. OVERALL ASSESSMENT As determined by this evaluation, the laboratory followed the specified analytical method. Accuracy was acceptable, as demonstrated by the surrogate, LCS/LCSD, and MS/MSD percent recovery values, except as previously noted. Precision was also acceptable as demonstrated by the field duplicate, LCS/LCSD, and MS/MSD RPD values. One data point was estimated based on MS/MSD recovery outliers. Data were labeled as do-not-report (DNR) to indicate which result should be used from multiple reported dilutions and analyses. Data labeled DNR should not be used for any purpose. All other data, as qualified, are acceptable for use. cjw6/4/2 VOC - 3 EcoChem, Inc. L:\Aspect 228\22826\22826_VOCa.doc

27 DATA VALIDATION REPORT Art Brass Plating Metals by Methods 2.8 & SW6B This report documents the review of analytical data from the analyses of groundwater samples and the associated laboratory and field quality control (QC) samples. Analytical Resources, Inc., Tukwila, Washington, analyzed the samples. Refer to the Sample Index for a list of the individual samples. SDG Number of Samples Validation Level QQ6 3 Groundwater Compliance QQ7 9 Groundwater Compliance QQ8 Groundwater Compliance I. DATA PACKAGE COMPLETENESS The laboratory submitted all required deliverables, with the exception noted below. The laboratory followed adequate corrective action processes and all anomalies were discussed in the case narrative. SDG QQ7: Metals analysis for sample MW D was not marked on the chain of custody (COC). Sample containers were provided and this sample was analyzed for total and dissolved metals. SDG QQ8: Metals analysis was marked for sample MW on the COC, however no containers were provided. This sample was not analyzed for total or dissolved metals. II. TECHNICAL DATA VALIDATION The QC requirements for review are listed below. Holding Times and Sample Preservation Laboratory Duplicates Method Blanks 2 Field Duplicates Laboratory Control Samples (LCS) Reported Results 2 Matrix Spikes (MS) Reporting Limits Quality control results are discussed below, but no data were qualified. 2 Quality control outliers that impact the reported data were noted. Data qualifiers were issued as discussed below. Matrix Spikes Matrix spiked (MS) were analyzed at the required frequency. The MS recovery values were within the laboratory control limits, with the exceptions noted below. For recoveries greater than the upper control limit, positive results (J-8) to indicate a potential high bias. For recoveries less than the lower control limit, associated results were estimated (J/UJ-8) to indicate a potential low bias. SDG QQ6: For QC Sample MW , the MS recovery for dissolved zinc was less than the lower control limit. All associated dissolved zinc results were estimated (J/UJ-8). cjw 6/4/2 L:\Aspect 228\22826\22826_MET.doc MET - EcoChem, Inc.

28 Field Duplicates The following acceptance criteria were used to evaluate precision: the relative percent difference (RPD) control limit is 35% for results greater than five times the reporting limit (RL). For results less than five times the RL, the difference between the sample and duplicate must be less than the RL. SDGs QQ6 & QQ7: One set of field duplicates were submitted. Sample MW was submitted in SDG QQ6 and Sample MW D was submitted in SDG QQ7. For dissolved arsenic, the difference between the sample and duplicate was greater the RL. The dissolved arsenic results for these two samples were estimated (J-9). III. OVERALL ASSESSMENT As determined by this evaluation, the laboratory followed the specified analytical methods. Accuracy was acceptable, as demonstrated by the laboratory control sample and matrix spike recovery values, with the exception noted above. Precision was also acceptable, as demonstrated by the laboratory and field duplicate RPD values, with the exception previously noted. Data were estimated based on a MS recovery outlier and a field duplicate precision outlier. All data, as qualified, are acceptable for use. cjw 6/4/2 MET - 2 EcoChem, Inc. L:\Aspect 228\22826\22826_MET.doc

29 APPENDIX A DATA QUALIFIER DEFINITIONS, REASON CODES, AND CRITERIA TABLES JC 6/4/95 :2 AM L:\Integral 22\APPENDIX.DOC

30 DATA VALIDATION QUALIFIER CODES Based on National Functional Guidelines The following definitions provide brief explanations of the qualifiers assigned to results in the data review process. U J NJ UJ R The analyte was analyzed for, but was not detected above the reported sample quantitation limit. The analyte was positively identified; the associated numerical value is the approximate concentration of the analyte in the sample. The analysis indicates the presence of an analyte that has been tentatively identified and the associated numerical value represents the approximate concentration. The analyte was not detected above the reported sample quantitation limit. However, the reported quantitation limit is approximate and may or may not represent the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample. The sample results are rejected due to serious deficiencies in the ability to analyze the sample and meet quality control criteria. The presence or absence of the analyte cannot be verified. The following is an EcoChem qualifier that may also be assigned during the data review process: DNR Do not report; a more appropriate result is reported from another analysis or dilution. 4/6/9 PM EcoChem, Inc. T:\Controlled Docs\Qualifiers & Reason Codes\NFG Qual Defs.doc

31 DATA QUALIFIER REASON CODES Holding Time/Sample Preservation 2 Chromatographic pattern in sample does not match pattern of calibration standard. 3 Compound Confirmation 4 Tentatively Identified Compound (TIC) (associated with NJ only) 5A 5B Calibration (initial) Calibration (continuing) 6 Field Blank Contamination 7 Lab Blank Contamination (e.g., method blank, instrument, etc.) 8 Matrix Spike(MS & MSD) Recoveries 9 Precision (all replicates) Laboratory Control Sample Recoveries A more appropriate result is reported (associated with R and DNR only) 2 Reference Material 3 Surrogate Spike Recoveries (a.k.a., labeled compounds & recovery standards) 4 Other (define in validation report) 5 GFAA Post Digestion Spike Recoveries 6 ICP Serial Dilution % Difference 7 ICP Interference Check Standard Recovery 8 Trip Blank Contamination 9 Internal Standard Performance (e.g., area, retention time, recovery) 2 Linear Range Exceeded 2 Potential False Positives 22 Elevated Detection Limit Due to Interference (i.e., laboratory, chemical and/or matrix) T:\Controlled Docs\Qualifiers & Reason Codes\Reason Codes-EcoChem.doc 6/2/8 EcoChem, Inc.

32 DATA VALIDATION CRITERIA Table No.: NFG-VOC Revision No.: 7 Last Rev. Date: 8/23/7 Page: of 2 EcoChem Validation Guidelines for Volatile Analysis by GC/MS (Based on Organic NFG 999) VALIDATION QC ELEMENT Cooler Temperature Hold Time Tuning Initial Calibration (Minimum 5 stds.) Continuing Calibration (Prior to each 2 hr. shift) Method Blank Storage Blank Trip Blank Field Blanks (if required in QAPP) ACCEPTANCE CRITERIA 4 C±2 C Water: HCl to ph < 2 Waters: 4 days preserved 7 Days: unpreserved (for aromatics) Solids: 4 Days BFB Beginning of each 2 hour period Method acceptance criteria RRF >.5 %RSD < 3% RRF >.5 %D <25% One per matrix per batch No results > CRQL ACTION REASON CODE J(+)/UJ(-) if greater than 6 deg. C (EcoChem PJ) J(+)/UJ(-) if hold times exceeded If exceeded by > 3X HT: J(+)/R(-) (EcoChem PJ) R(+/-) all analytes in all samples associated with the tune (EcoChem PJ, see TM-6) If MDL= reporting limit: J(+)/R(-) if RRF <.5 If reporting limit > MDL: note in worksheet if RRF <.5 (EcoChem PJ, see TM-6) J(+) if %RSD > 3% (EcoChem PJ, see TM-6) If MDL= reporting limit: J(+)/R(-) if RRF <.5 If reporting limit > MDL: note in worksheet if RRF <.5 (EcoChem PJ, see TM-6) If > +/-9%: J+/R- If -9% to -26%: J+ (high bias) If 26% to 9%: J+/UJ- (low bias) U(+) if sample (+) result is less than CRQL and less than appropriate 5X or X rule (raise sample value to CRQL) U(+) if sample (+) result is greater than or equal to CRQL and less than appropriate 5X and X rule (at reported sample value) No TICs present R(+) TICs using X rule 7 One per SDG <CRQL Frequency as per project QAPP U(+) the specific analyte(s) results in all assoc.samples using the 5x or x rule Same as method blank for positive results remaining in trip blank after method blank qualifiers are assigned No results > CRQL Apply 5X/X rule; U(+) < action level 6 5A 5A 5A 5B 5B T:\EcoChem Controlled Docs\Criteria Tables\EcoChem Default\EcoChem NFG Organic Criteria.xlsNFG-VOC Copyright 25 EcoChem, Inc.

33 DATA VALIDATION CRITERIA Table No.: NFG-VOC Revision No.: 7 Last Rev. Date: 8/23/7 Page: 2 of 2 EcoChem Validation Guidelines for Volatile Analysis by GC/MS (Based on Organic NFG 999) VALIDATION QC ELEMENT MS/MSD (recovery) ACCEPTANCE CRITERIA One per matrix per batch Use method acceptance criteria ACTION Qualify parent only unless other QC indicates systematic problems: J(+) if both %R > UCL J(+)/UJ(-) if both %R < LCL J(+)/R(-) if both %R < % PJ if only one %R outlier REASON CODE 8 MS/MSD (RPD) One per matrix per batch Use method acceptance criteria J(+) in parent sample if RPD > CL 9 LCS low conc. H2O VOA One per lab batch Within method control limits J(+) assoc. cmpd if > UCL J(+)/R(-) assoc. cmpd if < LCL J(+)/R(-) all cmpds if half are < LCL LCS regular VOA (H2O & solid) One per lab batch Lab or method control limits J(+) if %R > UCL J(+)/UJ(-) if %R <LCL J(+)/R(-) if %R < % (EcoChem PJ) LCS/LCSD (if required) One set per matrix and batch of 2 samples RPD < 35% J(+)/UJ(-) assoc. cmpd. in all samples 9 Surrogates Internal Standard (IS) Added to all samples Within method control limits Added to all samples Acceptable Range: IS area 5% to 2% of CCAL area RT within 3 seconds of CC RT J(+) if %R >UCL J(+)/UJ(-) if %R <LCL but >% (see PJ ) J(+)/R(-) if <% J(+) if > 2% J(+)/UJ(-) if < 5% J(+)/R(-) if < 25% RT>3 seconds, narrate and Notify PM 3 9 Field Duplicates Use QAPP limits. If no QAPP: Solids: RPD <5% OR absolute diff. < 2X RL (for results < 5X RL) Aqueous: RPD <35% OR absolute diff. < X RL (for results < 5X RL) Narrate and qualify if required by project (EcoChem PJ) 9 TICs Major ions (>%) in reference must be present in sample; intensities agree within 2%; check identification NJ the TIC unless: R(+) common laboratory contaminants See Technical Director for ID issues 4 Quantitation/ Identification RRT within.6 of standard RRT Ion relative intensity within 2% of standard All ions in std. at > % intensity must be present in sample See Technical Director if outliers 4 2 (false +) PJ No action if there are 4+ surrogates and only outlier. T:\EcoChem Controlled Docs\Criteria Tables\EcoChem Default\EcoChem NFG Organic Criteria.xlsNFG-VOC Copyright 25 EcoChem, Inc.

34 DATA VALIDATION CRITERIA Table No.: NFG-ICP Revision No.: Last Rev. Date: 6/7/29 Page: of 2 EcoChem Validation Guidelines for Metals Analysis by ICP (Based on Inorganic NFG 994 & 24) VALIDATION QC ELEMENT Cooler Temperature and Preservation Holding Time Initial Calibration Initial Calibration Verification (ICV) Continuing Calibration Verification (CCV) Initial and Continuing Calibration Blank (ICB/CCB) ACCEPTANCE CRITERIA Cooler temperature: 4 C ±2 Waters: Nitric Acid to ph < 2 For Dissolved Metals:.45um filter & preserve after filtration Tissues: Frozen 8 days from date sampled Frozen tissues - HT extended to 2 years Blank + minimum standard If more than standard, r >.995 Independent source analyzed immediately after calibration %R within ±% of true value Every ten samples, immediately following ICV/ICB and at end of run %R within ±% of true value After each ICV and CCV every ten samples and end of run blank < IDL (MDL) ACTION EcoChem Professional Judgment - no qualification based on cooler temperature outliers J(+)/UJ(-) if ph preservation requirements are not met REASON CODE J(+)/UJ(-) if holding time exceeded J(+)/UJ(-) if r <.995 (multi point cal) J(+)/UJ(-) if %R 75-89% J(+) if %R = -25% R(+) if %R > 25% R(+/-) if %R < 75% J(+)/UJ(-) if %R = 75-89% J(+) if %R -25% R(+) if %R > 25% R(+/-) if %R < 75% Action level is 5x absolute value of blank conc. For (+) blanks, U(+) results < action level For (-) blanks, J(+)/UJ(-) results < action level (Refer to TM-2 for additional information) 5A 5A 5B 7 Reporting Limit Standard 2x RL analyzed beginning of run Not required for Al, Ba, Ca, Fe, Mg, Na, K %R = 7%-3% (5%-5% Sb, Pb, Tl) R(-)/J(+) < 2x RL if %R <5% (< 3% Sb, Pb, Tl) J(+) < 2x RL, UJ(-) if %R 5-69% (3-49% Sb, Pb,Tl) J(+) < 2x RL if %R 3-8% (5-2% Sb, Pb, Tl) R(+) < 2x RL if %R > 8% (2% Sb, Pb, Tl) 4 Interference Check Samples (ICSA/ICSAB) Method Blank Laboratory Control Sample (LCS) ICSAB %R 8-2% for all spiked elements ICSA < MDL for all unspiked elements except: K, Na One per matrix per batch (batch not to exceed 2 samples) blank < MDL One per matrix per batch Blank Spike: %R within 8-2% For samples with Al, Ca, Fe, or Mg > ICS levels R(+/-) if %R < 5% J(+) if %R >2% J(+)/UJ(-) if %R= 5 to 79% Use Professional Judgment for ICSA to determine if bias is present see TM-9 for additional details Action level is 5x blank concentration U(+) results < action level R(+/-) if %R < 5% J(+)/UJ(-) if %R = 5-79% J(+) if %R >2% 7 7 CRM: Result within manufacturer's certified acceptance range or project guidelines J(+)/UJ(-) if < LCL, J(+) if > UCL T:\EcoChem Controlled Docs\Criteria Tables\EcoChem Default\EcoChem NFG Metals_CN.xlsNFG-ICP Copyright 26 EcoChem, Inc.

35 DATA VALIDATION CRITERIA Table No.: NFG-ICP Revision No.: Last Rev. Date: 6/7/29 Page: 2 of 2 EcoChem Validation Guidelines for Metals Analysis by ICP (Based on Inorganic NFG 994 & 24) VALIDATION QC ELEMENT Matrix Spikes Post-digestion Spike ACCEPTANCE CRITERIA One per matrix per batch 75-25% for samples less than 4x spike level If Matrix Spike is outside 75-25%, spike at twice the sample conc. ACTION J(+) if %R > 25% J(+)/UJ(-) if %R < 75% J(+)/R(-) if %R < 3% or J(+)/UJ(-) if Post Spike %R 75-25% Qualify all samples in batch No qualifiers assigned based on this element REASON CODE 8 Laboratory Duplicate (or MS/MSD) One per matrix per batch RPD < 2% for samples > 5x RL Diff < RL for samples >RL and < 5x RL (Diff < 2x RL for solids) J(+)/UJ(-) if RPD > 2% or diff > RL (2x RL for solids) qualify all samples in batch 9 Serial Dilution Field Blank Field Duplicate 5x dilution one per matrix %D < % for original sample conc. > 5x MDL Blank < MDL For results > 5x RL: Water: RPD < 35% Solid: RPD < 5% For results < 5 x RL: Water: Diff < RL Solid: Diff < 2x RL J(+)/UJ(-) if %D >% qualify all samples in batch Action level is 5x blank conc. U(+) sample values < action level in associated field samples only J(+)/UJ(-) in parent samples only 9 Linear Range Sample concentrations must fall within range J values over range T:\EcoChem Controlled Docs\Criteria Tables\EcoChem Default\EcoChem NFG Metals_CN.xlsNFG-ICP Copyright 26 EcoChem, Inc.

36 DATA VALIDATION CRITERIA Table No.: NFG-ICPMS Revision No.: Last Rev. Date: 6/7/29 Page: of 2 EcoChem Validation Guidelines for Metals Analysis by ICP-MS (Based on Inorganic NFG 994 & 24) VALIDATION QC ELEMENT Cooler Temperature and Preservation Holding Time ACCEPTANCE CRITERIA Cooler temperature: 4 C ±2 Waters: Nitric Acid to ph < 2 For Dissolved Metals:.45um filter & preserve after filtration 8 days from date sampled Frozen tissues - HT extended to 2 years ACTION EcoChem Professional Judgment - no qualification based on cooler temperature outliers J(+)/UJ(-) if ph preservation requirements are not met REASON CODE J(+)/UJ(-) if holding time exceeded Tune Prior to ICAL monitoring compounds analyzed 5 times wih Std Dev. < 5% mass calibration <. amu from True Value Resolution <.9 % peak height or <.75 5% peak height Use Professional Judgment to evaluate tune J(+)/UJ(-) if tune criteria not met 5A Initial Calibration Blank + minimum standard If more than standard, r>.995 J(+)/UJ(-) if r<.995 (for multi point cal) 5A Initial Calibration Verification (ICV) Independent source analyzed immediately after calibration %R within ±% of true value J(+)/UJ(-) if %R 75-89% J(+) if %R = -25% R(+) if %R > 25% R(+/-) if %R < 75% 5A Continuing Calibration Verification (CCV) Every ten samples, immediately following ICV/ICB and at end of run ±% of true value J(+)/UJ(-) if %R = 75-89% J(+) if %R -25% R(+) if %R > 25% R(+/-) if %R < 75% 5B Initial and Continuing Calibration Blanks (ICB/CCB) After each ICV and CCV every ten samples and end of run blank < IDL (MDL) Action level is 5x absolute value of blank conc. For (+) blanks, U(+) results < action level For (-) blanks, J(+)/UJ(-) results < action level refer to TM-2 for additional details 7 Reporting Limit Standard (CRI) 2x RL analyzed beginning of run Not required for Al, Ba, Ca, Fe, Mg, Na, K %R = 7%-3% (5%-5% Co,Mn, Zn) R(-),(+) < 2x RL if %R < 5% (< 3% Co,Mn, Zn) J(+) < 2x RL, UJ(-) if %R 5-69% (3%-49% Co,Mn, Zn) J(+) < 2x RL if %R 3%-8% (5%-2% Co,Mn, Zn) R(+) < 2x RL if %R > 8% (2% Co, Mn, Zn) 4 Interference Check Samples (ICSA/ICSAB) Method Blank Required by SW 62, but not 2.8 ICSAB %R 8% - 2% for all spiked elements ICSA < IDL (MDL) for all unspiked elements One per matrix per batch (batch not to exceed 2 samples) blank < MDL For samples with Al, Ca, Fe, or Mg > ICS levels R(+/-) if %R < 5% J(+) if %R >2% J(+)/UJ(-) if %R = 5% to 79% Use Professional Judgment for ICSA to determine if bias is present see TM-9 for additional details Action level is 5x blank concentration U(+) results < action level 7 7 T:\EcoChem Controlled Docs\Criteria Tables\EcoChem Default\EcoChem NFG Metals_CN.xlsNFG-ICPMS Copyright 26 EcoChem, Inc.

37 DATA VALIDATION CRITERIA Table No.: NFG-ICPMS Revision No.: Last Rev. Date: 6/7/29 Page: 2 of 2 EcoChem Validation Guidelines for Metals Analysis by ICP-MS (Based on Inorganic NFG 994 & 24) VALIDATION QC ELEMENT Laboratory Control Sample (LCS) ACCEPTANCE CRITERIA One per matrix per batch Blank Spike: %R within 8%-2% CRM: Result within manufacturer's certified acceptance range or project guidelines ACTION R(+/-) if %R < 5% J(+)/UJ(-) if %R = 5-79% J(+) if %R >2% J(+)/UJ(-) if < LCL, J(+) if > UCL REASON CODE Matrix Spike/ Matrix Spike Duplicate (MS/MSD) One per matrix per batch 75-25% for samples where results do not exceed 4x spike level J(+) if %R>25% J(+)/UJ(-) if %R <75% J(+)/R(-) if %R<3% or J(+)/UJ(-) if Post Spike %R 75%-25% Qualify all samples in batch 8 Post-digestion Spike Laboratory Duplicate (or MS/MSD) If Matrix Spike is outside 75-25%, Spike parent sample at 2x the sample conc. One per matrix per batch RPD < 2% for samples > 5x RL Diff < RL for samples > RL and < 5 x RL (Diff < 2x RL for solids) No qualifiers assigned based on this element J(+)/UJ(-) if RPD > 2% or diff > RL all samples in batch 9 Serial Dilution 5x dilution one per matrix %D < % for original sample values > 5x MDL J(+)/UJ(-) if %D >% All samples in batch 6 Internal Standards Field Blank Field Duplicate Every sample SW62: 6%-25% of cal blank IS 2.8: 3%-2% of cal blank IS Blank < MDL For results > 5x RL: Water: RPD < 35% Solid: RPD < 5% For results < 5 x RL: Water: Diff < RL Solid: Diff < 2x RL J (+)/UJ (-) all analytes associated with IS outlier 9 Action level is 5x blank conc. U(+) sample values < AL in associated field samples only J(+)/UJ(-) in parent samples only 9 6 Linear Range Sample concentrations must fall within range J values over range 2 T:\EcoChem Controlled Docs\Criteria Tables\EcoChem Default\EcoChem NFG Metals_CN.xlsNFG-ICPMS Copyright 26 EcoChem, Inc.

38 JC 6/4/95 :2 AM I:\APPENDICES\APPENDIX.DOC APPENDIX B QUALIFIED DATA SUMMARY TABLE