Prepared for: Art Brass Plating, Inc. Project No B-01 January 25, 2010

Transcription

1 TIER 3 ASSESSMENT REPORT FOR DECEMBER 2009 AIR SAMPLING EVENT 214 South Findlay Street, Seattle (Location 19) 218-1/2 South Findlay Street, Seattle (Location 10) 222 South Orcas Street, Seattle (Location 17) Prepared for: Art Brass Plating, Inc. Project No B-01 January 25, 2010

2 401 Second Avenue S, Suite 201 Seattle, WA Tel: (206) Fax: (206) a limited liability company

3 ASPECT CONSULTING Contents Introduction... 1 December 2009 Air Sampling Event... 2 Tier 3 Assessment of Air Sampling Results... 3 Discussion of Results South Findlay Street ½ South Findlay Street South Orcas Street... 4 Conclusions... 6 References... 7 Limitations... 8 List of Tables 1 Summary of December 2009 Tier 3 Air Sampling Results List of Figures 1 Buildings Where Art Brass Plating is Responsible for Interim VI Activities 2 Floor Plan Showing Air Sampling Locations, 214 South Findlay Street 3 Floor Plan Showing Air Sampling Locations, 218-1/2 South Findlay Street 4 Floor Plan Showing Air Sampling Locations, 222 South Orcas Street List of Appendices A B C D VI Evaluation Worksheets Weather Conditions at Boeing Field Weather Station Ecology Approval Letters Laboratory Report, Air Toxics, Limited PROJECT NO B-01 JANUARY 25, 2010 i

4 ASPECT CONSULTING Introduction Art Brass Plating (ABP) recently replaced Philip Services Corporation (PSC) as the lead business during the pendency of Agreed Order No. DE5296, dated January 8, 2008, between ABP and the Washington State Department of Ecology, for interim vapor intrusion (VI) assessment at properties in the vicinity of the ABP facility (see Figure 1). A tiered assessment process described in ABP s VI Assessment Work Plan (Aspect Consulting, 2008) is used to determine whether a specific property may require VI mitigation. This report documents air sampling conducted in December 2009 in accordance with Tier 3 assessment requirements. The following properties were included in this air sampling event: 214 South Findlay Street (identified as Location 19 in the VI Assessment Work Plan), a single-story residence located approximately 240 feet west of ABP (measured from the western edge of the ABP parcel to the center of the structure); 218½ South Findlay Street (Location 10), a single-story residence located approximately 180 feet west-northwest of ABP; and 222 South Orcas Street (Location 17), a two-story commercial building occupied by Quality Press and located approximately 270 feet southwest of ABP. See Figure 1 for property locations. Tier 1/Tier 2 assessments using December 2008 groundwater monitoring results indicated that Tier 3 assessments were warranted at these three properties. The Tier 1/Tier 2 assessment results were reported in ABP s fourth quarter 2008 progress report (Aspect Consulting, 2009a). Air sampling was conducted in accordance with the site-specific Tier 3 sampling and analysis plans (SAPs) for the respective properties (Aspect Consulting, 2009c, 2009d, and 2009e). The December 2009 event represents the first time air was sampled at 218½ South Findlay Street and 222 South Orcas Street. At 214 South Findlay Street, air was previously sampled in August 2009, and results were documented in a Tier 3 assessment report dated September 18, 2009 (Aspect Consulting, 2009f). That report concluded that sampling results did not indicate a need to implement an interim measure to address potential VI at 214 South Findlay Street. However, the site-specific SAP required that a second sampling event be conducted during the heating season. Ecology has reviewed and approved the site-specific SAPs for the three properties as well as the initial Tier 3 assessment report for 214 South Findlay Street. Ecology approval letters are included as Appendix C. Note that the SAP approval letters include Ecology suggestions regarding minor work plan modifications. PROJECT NO B-01 JANUARY 25,

5 ASPECT CONSULTING December 2009 Air Sampling Event Sampling at all three properties was initiated on December 9, Samples were collected at two indoor locations and one outdoor (ambient) location except at 218½ South Findlay Street, where one indoor and one outdoor sample were collected. Sampling locations are shown on Figures 2 through 4. Laboratory-supplied evacuated 6-liter Summa canisters were used to collect the time-integrated air samples. A 24-hour sampling period was used at the residential properties, and an 8-hour sampling period at 222 South Orcas Street. Detailed sampling procedures were in general conformance with the Standard Operating Procedure for Indoor Air Sampling provided in Appendix A of the VI Assessment Work Plan. Additional details on sampling methodology are as follows: The indoor air samples were collected at heights of 3.5 to 6 feet above the floor, and the outdoor samples at 7.5 to 9 feet above ground surface. Up to 2 feet of ¼-inch-diameter tubing was attached to the canister inlet to achieve the desired air intake height. Immediately prior to attaching the tubing to the canister inlet and opening the canister valve to initiate the sampling event, the air to be sampled was introduced to the tubing using a GasTec plunger designed for pulling air samples through glass detector tubes. Each Summa canister was equipped with a flow regulator and a vacuum gage with a range of 0 to 30 inches of mercury (in Hg). Vacuum readings were recorded by the field technician on three occasions during the sampling period, and by the analytical laboratory upon receipt of the filled canisters. These readings are provided in Table 1. The weather forecast was monitored in an attempt to: a) locate the outdoor air samples upwind of the corresponding structures; and b) collect the samples during a period of low ambient temperature and decreasing barometric pressure. Weather conditions (temperature, barometric pressure, wind speed, and wind direction) observed at the Boeing Field weather station during the week of December 6 through 12 are provided in Appendix B. In the hours immediately prior to sampling and during the sampling interval itself, wind direction was predominantly from the southeast, so the outdoor samples were appropriately located upwind of the corresponding structures. Ambient temperatures during the sampling interval were low, in the range of roughly 16 to 38 degrees F. This implies that the heating systems in the structures were quite active, presumably producing a strong chimney effect that is typically associated with worst case VI conditions. The barometric pressure trend was also favorable for capturing worst case VI conditions, decreasing by approximately 0.13 inches of mercury (in Hg) during the sampling interval. A primary objective in scheduling air sampling at 222 South Orcas Street was to sample on a day when the large vented printing press would be operating, since the forced venting is thought to create a negatively pressurized 2 PROJECT NO B-01 JANUARY 25, 2010

6 ASPECT CONSULTING environment in the production and shipping areas inside the building. This objective was achieved. Tier 3 Assessment of Air Sampling Results The Summa canisters were packed in their original shipping containers and returned to Air Toxics, Limited (ATL), in Folsom, California, for analysis of the following target compounds: Tetrachloroethene (PCE) 1,1-dichloroethene vinyl chloride trichloroethene (TCE) cis-1,2-dichloroethene Except for PCE, these are the site-specific compounds of concern (COCs) in groundwater. While PCE is sometimes detected in site media, extensive evaluation of sampling results has demonstrated that PCE concentrations are not attributable to the ABP facility. Nonetheless, PCE is included on the list of target compounds because PCE concentrations are input to the exceedance factor calculations discussed below. Analytical results are summarized in Table 1, and the complete laboratory report is provided as Appendix D. All samples except those collected inside Quality Press (222_PRODUCTION_ and 222_SHIPPING_120909) were analyzed using modified Method TO-15 SIM in order to achieve low detection limits. Due to the presence of high levels of non-target compounds in the production and shipping areas of that building, the laboratory transferred those two samples from SIM analysis to full scan TO-15 and performed sample dilutions. As a result, the detection limits achieved by the laboratory are at least two orders of magnitude higher for those two samples than for the others. PCE and TCE were detected in all samples (both indoors and outdoors) except for the two with the elevated detection limits. Maximum concentrations were 4.9 micrograms per cubic meter (µg/m 3 ) PCE and 0.32 µg/m 3 TCE, both of which were detected in the 214 South Findlay Street bedroom sample. The other three target compounds were not detected in any of the samples. Sampling results were evaluated and cumulative exceedance factors calculated in accordance with the Tier 3 assessment methodology specified in the VI Assessment Work Plan. The completed VI evaluation worksheets are provided as Appendix A. For each location, analytical results for the indoor sample with the highest concentrations (or, if no indoor detections, the highest detection limits) were compared to the indoor air inhalation pathway interim measure action levels (IPIMALs). If a compound was detected in both the indoor sample and the corresponding outdoor sample, a corrected indoor air concentration was calculated by subtracting the outdoor concentration from the indoor concentration. For non-detect results, one-half the indoor air sample detection limit was used in the exceedance factor calculation. Results for 214 and 218½ South Findlay Street were compared to the IPIMALs for a residential use scenario, while commercial scenario IPIMALs were used to evaluate the Quality Press results. The calculated cancer cumulative exceedance factors (CCEFs) and non-cancer cumulative exceedance factors (NCCEFs) are summarized at the bottom of Table 1. PROJECT NO B-01 JANUARY 25,

7 ASPECT CONSULTING CCEF values greater than 10 indicate a carcinogenic risk exceeding 1E-5. NCCEF values above 10 indicate a hazard index greater than 1. Per the VI Assessment Work Plan, if either value is greater than 10, the need to implement an interim measure to address the potential VI threat will be discussed with Ecology. Discussion of Results 214 South Findlay Street The calculated CCEF value for this location is 11.7, slightly exceeding the threshold value of 10. As shown on the evaluation worksheet in Appendix A, this elevated value is primarily attributable to PCE in the indoor air sample. However, as noted above, it has been demonstrated that PCE is not a COC in site groundwater. Therefore, the elevated PCE concentration detected in indoor air at 214 South Findlay Street cannot reasonably be attributed to the ABP release. Subtracting out the PCE contribution, the calculated CCEF value for this location decreases from 11.7 to less than 1.4, well below the threshold value of 10 that indicates a potential need to implement an interim measure to address VI. The PCE detected in indoor air at this location is likely attributable to a source located inside the residence, such as recently dry-cleaned clothing. Regarding quality assurance review of the air sampling results at this location, note that the laboratory reported a total loss of vacuum upon receipt of the filled 214_BEDRM_ canister. This raises a concern regarding sample integrity. (For example, has the sample been diluted by air leaking into the canister after the sampling event?) In this case, however, detected concentrations of PCE and TCE are similar to and, in fact, slightly higher than the levels detected in indoor sample 214_LIVNGRM_120909, which was located just 13 feet away. There were no quality assurance issues associated with sample 214_LIVNGRM_ The good agreement between the analytical results of these nearby indoor samples suggests that the integrity of sample 214_BEDRM_ should not be a concern. 218½ South Findlay Street Since the calculated CCEF and NCCEF values are both less than 10, the results of the December 2009 air sampling event do not indicate a need to implement an interim measure to address potential VI at this location. 222 South Orcas Street Sampling indoor air for evidence of VI is problematic at this location due to the fact that Quality Press stores and uses on a daily basis a variety of liquid products containing volatile organic compounds (VOCs) which would logically be present in indoor air. High concentrations of these non-target compounds in the two indoor samples caused the laboratory to change the analytical method and perform sample dilutions to protect their 4 PROJECT NO B-01 JANUARY 25, 2010

8 ASPECT CONSULTING instruments. As a result, while no target compounds were detected in either sample, the detection limits were too high to allow for a meaningful exceedance factor evaluation. Ecology was aware that non-target VOC interference could potentially be a problem at Quality Press, and recommended in its SAP approval letter (Appendix C) that the laboratory be alerted ahead of time. Aspect had discussions with ATL both before ordering the canisters and after receiving the analytical results. ATL claims they followed standard procedures in dealing with samples containing elevated VOC concentrations. Given the high concentrations of non-target VOCs in the samples, ATL did not have any recommendations on how lower detection limits might be achieved. As shown on the evaluation worksheet for this location (Appendix A), elevated detection limits for PCE and vinyl chloride as well as TCE contributed to the calculated CCEF value of 114. The PCE contribution to this value can be subtracted out since, as previously noted, PCE is not a COC in site groundwater and cannot reasonably be attributed to the ABP release. Almost the entire vinyl chloride contribution can also be subtracted out by considering TCE/vinyl chloride concentration ratios observed in site media. Sampling results at 220 South Findlay Street, located immediately downgradient of the ABP facility (see Figure 1), provide vapor-phase data. Indoor air and sub-slab soil vapor were sampled at 220 South Findlay Street on February 12, 2009, and results were reported in Table 15 of ABP s first quarter 2009 progress report (Aspect Consulting, 2009b). TCE/vinyl chloride concentration ratios in the two soil vapor samples and the indoor air sample (corrected for outdoor contributions as described above) all exceeded 140. In groundwater, results for probe sample SPO-16, collected in December 2008 at the northwest corner of the Quality Press building, indicate a TCE/vinyl chloride ratio of 210. (The groundwater sampling results are shown on the VI Evaluation Worksheet 2 included in Appendix A.) Therefore, the contribution of vinyl chloride to the CCEF value should be negligible compared to that of TCE. Unfortunately, after subtracting out the contributions of both the elevated PCE and vinyl chloride detection limits, a CCEF value of 78 still remains, due solely to the elevated TCE detection limit. The federal Occupational Safety and Health Administration (OSHA) has established permissible exposure limits (PELs) to regulate workplace exposure to volatile chemicals. The PEL for TCE is 100 parts per million by volume (ppmv) as an 8-hour time-weighted average (TWA). On a mass basis this is equivalent to 537,000 µg/m 3, or over two million times the indoor air IPIMAL for TCE under the commercial use scenario (0.23 µg/m 3 ). (One explanation for the huge discrepancy between these two values is that IPIMALs are based solely on risk to human health, whereas PELs are based on both health risk and economic feasibility.) From a regulatory standpoint, PELs are applicable only in situations where employees are routinely exposed to chemicals as part of an industrial/manufacturing process. Since Quality Press apparently does not use any chemical formulations containing TCE, the PEL for TCE is not applicable at this facility. From a practical standpoint, however, we believe PELs are pertinent to the current discussion. We know that many VOCs are routinely used at Quality Press, and that their use results in high indoor air concentrations. Permissible workplace concentrations for these VOCs are the PELs established by OSHA. We do not know the extent to which non-target VOC concentrations approach the corresponding PELs. However, we do know that the TCE concentration in Quality Press indoor air during the December 2009 sampling event was less than one-hundredth of one percent (<0.01%) of its PEL. This PROJECT NO B-01 JANUARY 25,

9 ASPECT CONSULTING certainly suggests that TCE represents a negligible incremental health risk to Quality Press workers. Resampling indoor air at this location is not expected to yield significantly lower detection limits. Sub-slab soil vapor or soil vapor just above the groundwater table in the alley north of the building could potentially be sampled. A soil vapor sample may contain lower concentrations of non-target VOCs than are found in indoor air. In addition, per Ecology s draft guidance for evaluating soil vapor intrusion (Ecology, 2009), a vapor attenuation factor (VAF) of 0.1 could likely be assumed in evaluating sampling results. Therefore, soil vapor sampling would more likely yield a meaningful exceedance factor evaluation. Another consideration is that recent groundwater monitoring results indicate rapidly improving conditions at well MW-8 which, among the TCE-impacted water table monitoring wells, is closest to Quality Press (see Figure 1). From December 2008 to December 2009, the CCEF value calculated from monitoring results at that well dropped from 596 to 72. This 88 percent decline over just one year is likely due primarily to air sparging at ABP, which began in September Recall that probe sample SPO-16, collected in December 2008 at the northwest corner of the Quality Press building, yielded a CCEF value of 20.1 (refer to VI Evaluation Worksheet 2 in Appendix A), and that this triggered Tier 3 sampling at Quality Press. Since SPO-16 is located farther from ABP than well MW-8, a somewhat longer interval is likely needed for the positive effects of air sparging to be experienced at that location. However, only about a 50 percent improvement in groundwater quality in the vicinity of SPO-16 is needed to produce a CCEF value below 10, which would indicate that Tier 3 evaluation is not required at Quality Press. The decision process endpoint must be kept in mind when deciding whether sampling soil vapor or re-sampling water table groundwater is worthwhile. Detection of elevated TCE concentrations would potentially indicate that a sub-slab depressurization system should be installed (for example) to protect workplace inhalation exposure to TCE. As noted above, however, results of the current sampling round suggest that mitigating the VI pathway would not measurably reduce workplace inhalation risk. When the vast majority of workplace inhalation risk is likely due to VOC sources located inside the building, the reasonableness of installing a sub-slab depressurization system is highly questionable. Conclusions The December 2009 air sampling event was successfully completed during meteorological conditions conducive to capturing worst-case VI conditions (i.e., very low ambient temperatures and decreasing barometric pressure). Conclusions include the following: 1. The marginally elevated concentrations of PCE detected in indoor air at 214 South Findlay Street are not attributable to the ABP release, and are most likely due to a 6 PROJECT NO B-01 JANUARY 25, 2010

10 ASPECT CONSULTING source located inside the residence such as recently dry-cleaned clothing. Accounting for this, current sampling results do not indicate a need to implement an interim measure to address potential VI. This represents the second Tier 3 sampling event at 214 South Findlay Street (August 2009 was the first) yielding this conclusion. 2. Sampling results at 218½ South Findlay Street do not indicate a need to implement an interim measure to address potential VI. 3. Due to the intrinsic nature of printing operations at Quality Press (222 South Orcas Street), non-target VOC concentrations are high in the shipping and production areas of the building. TCE and other COCs were not detected in the air samples collected in these areas. However, due to non-target VOC interference, detection limits were too high to allow for a meaningful exceedance factor evaluation. Sampling soil vapor instead of indoor air could potentially yield a meaningful exceedance factor evaluation. However, recent groundwater monitoring results indicate that air sparging has been effective at ABP, and groundwater quality in the vicinity of Quality Press should soon improve to the point that Tier 3 evaluation is not required. And, in any case, current air sampling results suggest that, if VI does contribute TCE to indoor air, that contribution represents a negligible incremental risk to worker health. When the vast majority of workplace inhalation risk is likely due to VOC sources located inside the building, the reasonableness of installing a sub-slab depressurization system is highly questionable. References Aspect Consulting, 2008, Vapor Intrusion Assessment Work Plan, Art Brass Plating, August 29, Aspect Consulting, 2009a, Letter to E. Jones, Washington State Department of Ecology, re Progress Report October through December 2008, Art Brass Plating, Seattle, Washington. February 6, Aspect Consulting, 2009b, Letter to E. Jones, Washington State Department of Ecology, re Progress Report January through March 2009, Art Brass Plating, Seattle, Washington, May 5, Aspect Consulting, 2009c, Sampling and Analysis Plan for Tier 3 Air Quality Monitoring (Revision 1), 214 South Findlay Street, Seattle (Location 19), June 29, Aspect Consulting, 2009d, Sampling and Analysis Plan for Tier 3 Air Quality Monitoring, 218-1/2 South Findlay Street, Seattle (Location 10), August 5, 2009 (Draft). Aspect Consulting, 2009e, Sampling and Analysis Plan for Tier 3 Air Quality Monitoring (Revision 1), 222 South Orcas Street, Seattle (Location 17), August 28, Aspect Consulting, 2009f, Tier 3 Assessment Report for August 2009 Air Sampling Event, 214 South Findlay Street, Seattle (Location 19), September 18, PROJECT NO B-01 JANUARY 25,

11 ASPECT CONSULTING Ecology, 2009, Guidance for Evaluating Soil Vapor Intrusion in Washington State: Investigation and Remedial Action, Washington State Department of Ecology, Toxics Cleanup Program, Publication No , October 2009 (Review draft). Limitations Work for this project was performed and this report prepared in accordance with generally accepted professional practices for the nature and conditions of work completed in the same or similar localities, at the time the work was performed. It is intended for the exclusive use of Art Brass Plating, Inc. for specific application to the referenced property. This report does not represent a legal opinion. No other warranty, expressed or implied, is made. 8 PROJECT NO B-01 JANUARY 25, 2010

12 Table 1 - Summary of December 2009 Tier 3 Air Sampling Results Art Brass Plating, Seattle, Washington Indoor Air Samples Outdoor (Ambient Background) Air Samples Sampling Address 214 S Findlay St 218½ S Findlay St 222 S Orcas St (3) 214 S Findlay St 218½ S Findlay St 222 S Orcas St Sample ID 214_LIVNGRM_ _BEDRM_ /2_INSIDE_ _PRODUCTION_ _SHIPPING_ _OUT_ /2_OUTSIDE_ _OUT_ Sampling Dates (4) December 9 & 10, 2009 December 9, 2009 December 9 & 10, 2009 December 9, 2009 Start-of-Sampling > During Sampling 18 (after 20 hrs) 7 (after 20 hrs) 11.5 (after 20 hrs) 13.5 (after 6 hrs) 11 (after 6 hrs) 8.25 (after 20 hrs) 8 (after 20 hrs) 13 (after 6 hrs) End-of-Sampling Upon Receipt by Laboratory Analytical Laboratory Results Concentrations in micrograms per cubic meter (ug/m 3 ) Tetrachloroethene (PCE) U 45 U Trichloroethene (TCE) U 36 U ,1-Dichloroethene U U U 13 U 26 U U U U cis-1,2-dichloroethene 0.19 U 0.11 U 0.13 U 13 U 26 U 0.12 U 0.11 U 0.14 U Vinyl Chloride U U U 8.4 U 17 U U U U Calculated Indoor Air IPIMAL Exceedence Factors (5) Canister Vacuum in inches of mercury (in. Hg) Cancer Cumulative Exceedence Factor (CCEF) (Note 6) (Note 7) 114 Noncancer Cumulative Exceedence Factor (NCCEF) (Note 6) (Note 7) 5.5 IPIMAL Inhalation pathway interim measure action level U Analyte was not detected at the indicated detection limit. Notes: 1) Samples were collected in evacuated 6-liter Summa canisters. See Figures 1-3 for sampling locations. 2) Air Toxics, Ltd., provided the sampling equipment and analyzed the samples. The laboratory report is included as Appendix D. Laboratory detections are bolded. 3) Samples were analyzed by modified TO-15 SIM except for the two indoor samples collected at 222 S Orcas St. The laboratory transferred these two samples from SIM analysis to full scan TO-15 and performed sample dilutions due to the presence of high levels of non-target compounds. 4) Per the site-specific sampling and analysis plans, a sampling duration of approximately 24 hours was used for the residential structures (214 and 218½ S Findlay St) and approximately 8 hours for the commercial structure (222 S Orcas St). 5) See IPIMAL exceedence factor discussion in report text and evaluation worksheets in Appendix A. Exceedence factors greater than 10 are bolded. 6) Exceedence factor not calculated for this sample because detected concentrations are lower than for sample 214_BEDRM_ ) Exceedence factor not calculated for this sample because detection limits are lower than for sample 222_SHIPPING_ Aspect Consulting 1/25/10 V:\ Art Brass Plating\Tier \Table 1 - Table1 Table 1 Page 1 of 1

13 Legend Approximate Art Brass Plating Property Boundary AB-MW-1 CG-138-WT SPO-16 Water Table Monitoring Well by Aspect Water Table Monitoring Well by Others Water Table Probe (selected locations) 12 Location ID where Interim VI Measures are Required S. LUCILE ST 11 Building addressed in the VI Assessment Work Plan 1ST AVE S st Ave. S. 113 S. Findlay St. 2ND AVE S 225 S. Lucile Street Dresser-Rand 3RD AVE S 305 S. Lucile Street 307 S. Lucile Street 317 S. Lucile Street th Ave. S. Office Building Building addressed by the Interim Cleanup Action Building addressed in the VI Inspection, Monitoring, and Maintenance Work Plan CG-142-WT 300' West st Ave. S st. Ave. S st. Ave. S. ALLEY 111 S. Findlay St. A2 A3 121 A4 ALLEY st Ave. S. 122 S. Findlay St. 123 A S. Findlay St A nd Ave. S. A nd Ave. S nd Ave. S. A9 123 S. Orcas St. A7 CG-138-WT AB-MW-16 AB-MW nd Ave. S. 200 S. Orcas Street Office Building nd Ave S nd Ave. S AB-MW S. Findlay St. ALLEY ALLEY S. FINDLAY ST SPO-16 S. ORCAS ST S. Findlay St. 218 S. Findlay St. 10 A1 AB-MW S. Orcas Street Quality Press 17 AB-MW-8 AB-MW S. Findlay Street Office Building 217 S. Findlay Street Warehouse 226 S. Orcas Street 2 Warehouse 18 AB-MW-5 AB-MW-7 AB-MW-3 AB-MW-11 AB-MW-1 ALLEY PMW-1 AB-MW S. Findlay Street Warehouse 4 AB-MW-2 ALLEY AB-MW-12 1 AB-MW rd Ave. S. Art Brass Plating Parking AB-MW th Ave S. Restaurant th Ave S. Auto Body Shop Subway th Ave. S th Ave. S th Ave. S. Buildings Where Art Brass Plating is Responsible for Interim VI Activities Art Brass Plating Seattle, Washington 4TH AVE S N Feet DATE: DESIGNED BY: DRAWN BY: REVISED BY: Jan 2010 DAH PMB - PROJECT NO FIGURE NO. 1 Q:\Art Brass Plating\ Art Brass\ Tier 3 Assessment Report\ dwg

14 Back Entry Bathroom Mud Room Bedroom Closets Bedroom Vent to Crawlspace Closets Furnace Air Ducts 214_BEDRM_ All locations and dimensions are approximate. N Feet 3 Steps Down to Mud Room Dining Area Former Exterior Wall One Step Down to Dining Area earth+water a limited liability company Kitchen LEGEND 214_LIVNGRM_ Front Entry Living Room Air Sampling Location, December 9 & 10, 2009 Floor Plan Showing Air Sampling Locations 214 South Findlay Street Art Brass Plating Seattle, Washington 214_OUT_ (Offset approx 18 ft) DATE: DESIGNED BY: DRAWN BY: REVISED BY: Jan 2010 DAH PMB PROJECT NO FIGURE NO. 2 Q:\Art Brass Plating\ Art Brass\ Tier 3 Assessment Report\ dwg

15 Alley Electric heater Kitchen 218 1/2_INSIDE_ Living Room / Bedroom Utility / Storage Areas All locations and dimensions are approximate. N Feet earth+water a limited liability company Bathroom LEGEND Front Entry 218 1/2_OUTSIDE_ (Offset approx 25ft) Air Sampling Location, December 9 & 10, 2009 Floor Plan Showing Air Sampling Locations 218-1/2 South Findlay Street Art Brass Plating Seattle, Washington DATE: DESIGNED BY: DRAWN BY: REVISED BY: Jan 2010 DAH PMB PROJECT NO FIGURE NO. 3 Q:\Art Brass Plating\ Art Brass\ Tier 3 Assessment Report\ dwg

16 ALLEY Delivery Entrances SPO S. Findlay St. Warehouse Printing Press Roof Exhaust (approximate location) Approximately 200 feet from southwest corner of Art Brass Plating parcel Parking Lot 222_PRODUCTION_ Vented Printing Press (approximate location) Production (2-Story-High Ceiling) LEGEND AB-MW-11 SPO-16 Parking Lot Water Table Monitoring Well Water Table Probe Air Sampling Location December 9, 2009 Ceiling-Mounted Heater N Office Entrance Feet S. ORCAS STREET earth+water a limited liability company Offices (1st & 2nd Stories) 222 S. Orcas Street (Quality Press) 222_SHIPPING_ Delivery Entrance Shipping (1st Story) & Sales (2nd Story) 226 S. Orcas Street 222_OUT_ (Offset approx 32ft) Floor Plan Showing Air Sampling Locations 222 South Orcas Street Art Brass Plating Seattle, Washington Warehouse DATE: DESIGNED BY: DRAWN BY: REVISED BY: Jan 2010 DAH SCC/PMB 3rd AVENUE SOUTH AB-MW-11 PROJECT NO FIGURE NO. 4 Q:\Art Brass Plating\ Art Brass\ Tier 3 Assessment Report\ dwg

17 APPENDIX A VI Evaluation Worksheets

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22 APPENDIX B Weather Conditions at Boeing Field Weather Station

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24 APPENDIX C Ecology Approval Letters

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31 APPENDIX D Laboratory Report Air Toxics, Limited

32 12/29/2009 Mr. Eric Marhofer Aspect Consulting LLC 401 Second Avenue South Suite 201 Seattle WA Project Name: Art Brass Project #: _7B_001 Workorder #: Dear Mr. Eric Marhofer The following report includes the data for the above referenced project for sample(s) received on 12/14/2009 at Air Toxics Ltd. The data and associated QC analyzed by Modified TO-15 SIM are compliant with the project requirements or laboratory criteria with the exception of the deviations noted in the attached case narrative. Thank you for choosing Air Toxics Ltd. for your air analysis needs. Air Toxics Ltd. is committed to providing accurate data of the highest quality. Please feel free to contact the Project Manager: Kelly Buettner at if you have any questions regarding the data in this report. Regards, Kelly Buettner Project Manager 180 BLUE RAVINE ROAD, SUITE B FOLSOM, CA (916) FAX (916) Hours 6:30 A.M to 5:30 PST Page 1 of 25

33 WORK ORDER #: Work Order Summary CLIENT: PHONE: FAX: DATE RECEIVED: Mr. Eric Marhofer Aspect Consulting LLC 401 Second Avenue South Suite 201 Seattle, WA /14/2009 DATE COMPLETED: 12/29/2009 BILL TO: P.O. # PROJECT # CONTACT: Accounts Payable Aspect Consulting LLC 179 Madrone Lane North Bainbridge Island, WA _7B_001 Art Brass Kelly Buettner RECEIPT FRACTION # NAME TEST VAC./PRES. FINAL PRESSURE 01A 218 1/2_INSIDE_ Modified TO-15 SIM 6.0 "Hg 5 psi 01AA 218 1/2_INSIDE_ Lab Duplicate Modified TO-15 SIM 6.0 "Hg 5 psi 02A 218 1/2_OUTSIDE_ Modified TO-15 SIM 1.5 "Hg 5 psi 03A 214_LIVNGRM_ Modified TO-15 SIM 13.5 "Hg 5 psi 04A 214_BEDRM_ Modified TO-15 SIM 0.0 "Hg 5 psi 05A 214_OUT_ Modified TO-15 SIM 2.5 "Hg 5 psi 06A 222_PRODUCTION_ Modified TO-15 SIM 5.5 "Hg 5 psi 07A 222_SHIPPING_ Modified TO-15 SIM 6.0 "Hg 5 psi 08A 222_OUT_ Modified TO-15 SIM 6.5 "Hg 5 psi 09A Lab Blank Modified TO-15 SIM NA NA 09B Lab Blank Modified TO-15 SIM NA NA 09C Lab Blank Modified TO-15 SIM NA NA 10A CCV Modified TO-15 SIM NA NA 10B CCV Modified TO-15 SIM NA NA 10C CCV Modified TO-15 SIM NA NA 11A LCS Modified TO-15 SIM NA NA 11B LCS Modified TO-15 SIM NA NA Continued on next page 180 BLUE RAVINE ROAD, SUITE B FOLSOM, CA (916) (800) FAX (916) Page 2 of 25

34 WORK ORDER #: Work Order Summary CLIENT: PHONE: FAX: DATE RECEIVED: Mr. Eric Marhofer Aspect Consulting LLC 401 Second Avenue South Suite 201 Seattle, WA /14/2009 DATE COMPLETED: 12/29/2009 BILL TO: P.O. # PROJECT # CONTACT: Accounts Payable Aspect Consulting LLC 179 Madrone Lane North Bainbridge Island, WA _7B_001 Art Brass Kelly Buettner RECEIPT FINAL FRACTION # NAME TEST VAC./PRES. PRESSURE 11C LCS Modified TO-15 SIM NA NA CERTIFIED BY: DATE: 12/29/09 Laboratory Director Certfication numbers: CA NELAP CA, LA NELAP/LELAP- AI 30763, NJ NELAP - CA004 NY NELAP , UT NELAP , AZ Licensure AZ0719 Name of Accrediting Agency: NELAP/Florida Department of Health, Scope of Application: Clean Air Act, Accreditation number: E87680, Effective date: 07/01/09, Expiration date: 06/30/10 Air Toxics Ltd. certifies that the test results contained in this report meet all requirements of the NELAC standards This report shall not be reproduced, except in full, without the written approval of Air Toxics Ltd. 180 BLUE RAVINE ROAD, SUITE B FOLSOM, CA (916) (800) FAX (916) Page 3 of 25

35 Laboratory Services Since 1989 LABORATORY NARRATIVE Modified TO-15 SIM Aspect Consulting LLC Workorder# Eight 6 Liter Summa Special (SIM Certified) samples were received on December 14, The laboratory performed analysis via modified EPA Method TO-15 using GC/MS in the SIM acquisition mode. This workorder was independently validated prior to submittal using 'USEPA National Functional Guidelines' as generally applied to the analysis of volatile organic compounds in air. A rules-based, logic driven, independent validation engine was employed to assess completeness, evaluate pass/fail of relevant project quality control requirements and verification of all quantified amounts. Method modifications taken to run these samples are summarized in the table below. Specific project requirements may over-ride the ATL modifications. Requirement TO-15 ICAL %RSD acceptance criteria </=30% RSD with 2 compounds allowed out to < 40% RSD ATL Modifications Project specific; default criteria is </=30% RSD with 10% of compounds allowed out to < 40% RSD Daily Calibration +- 30% Difference Project specific; default criteria is </= 30% Difference with 10% of compounds allowed out up to </=40%.; flag and narrate outliers Blank and standards Zero air Nitrogen Method Detection Limit Follow 40CFR Pt.136 App. B The MDL met all relevant requirements in Method TO-15 (statistical MDL less than the LOQ). The concentration of the spiked replicate may have exceeded 10X the calculated MDL in some cases Receiving Notes The Chain of Custody (COC) information for sample 218 1/2_INSIDE_ did not match the entry on the sample tag with regard to sample identification. The information on the COC was used to process and report the sample. Sample 214_BEDRM_ arrived at ambient pressure yet flow controllers were used for sample collection. Analytical Notes Samples 222_PRODUCTION_ and 222_SHIPPING_ were transferred from SIM analysis to full scan TO-15 due to high levels of non-target compounds. Dilution was performed on samples 222_PRODUCTION_ and 222_SHIPPING_ due to the presence of high level non-target species. Page 4 of 25

36 Laboratory Services Since 1989 Definition of Data Qualifying Flags Eight qualifiers may have been used on the data analysis sheets and indicates as follows: B - Compound present in laboratory blank greater than reporting limit (background subtraction not performed). J - Estimated value. E - Exceeds instrument calibration range. S - Saturated peak. Q - Exceeds quality control limits. U - Compound analyzed for but not detected above the reporting limit. UJ- Non-detected compound associated with low bias in the CCV N - The identification is based on presumptive evidence. File extensions may have been used on the data analysis sheets and indicates as follows: a-file was requantified b-file was quantified by a second column and detector r1-file was requantified for the purpose of reissue Page 5 of 25

37 Summary of Detected Compounds MODIFIED EPA METHOD TO-15 GC/MS SIM Client Sample ID: 218 1/2_INSIDE_ Lab ID#: A Compound Trichloroethene Tetrachloroethene Rpt. Limit Amount Rpt. Limit Amount Client Sample ID: 218 1/2_INSIDE_ Lab Duplicate Lab ID#: AA Compound Trichloroethene Tetrachloroethene Rpt. Limit Amount Rpt. Limit Amount Client Sample ID: 218 1/2_OUTSIDE_ Lab ID#: A Compound Trichloroethene Tetrachloroethene Rpt. Limit Amount Rpt. Limit Amount Client Sample ID: 214_LIVNGRM_ Lab ID#: A Compound Trichloroethene Tetrachloroethene Rpt. Limit Amount Rpt. Limit Amount Client Sample ID: 214_BEDRM_ Lab ID#: A Compound Trichloroethene Tetrachloroethene Rpt. Limit Amount Rpt. Limit Amount Client Sample ID: 214_OUT_ Lab ID#: A Page 6 of 25

38 Summary of Detected Compounds MODIFIED EPA METHOD TO-15 GC/MS SIM Client Sample ID: 214_OUT_ Lab ID#: A Compound Trichloroethene Tetrachloroethene Rpt. Limit Amount Rpt. Limit Amount Client Sample ID: 222_PRODUCTION_ Lab ID#: A No Detections Were Found. Client Sample ID: 222_SHIPPING_ Lab ID#: A No Detections Were Found. Client Sample ID: 222_OUT_ Lab ID#: A Compound Trichloroethene Tetrachloroethene Rpt. Limit Amount Rpt. Limit Amount Page 7 of 25

39 File Name: e122613sim Dil. Factor: 1.68 Compound Vinyl Chloride 1,1-Dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Client Sample ID: 218 1/2_INSIDE_ Lab ID#: A MODIFIED EPA METHOD TO-15 GC/MS SIM Rpt. Limit Amount Date of Collection: 12/9/09 2:05:00 PM Date of Analysis: 12/26/09 03:20 PM Rpt. Limit Amount Not Detected Not Detected Not Detected Not Detected Not Detected 0.13 Not Detected Container Type: 6 Liter Summa Special (SIM Certified) Surrogates 1,2-Dichloroethane-d4 Toluene-d8 4-Bromofluorobenzene Method %Recovery Limits Page 8 of 25

40 File Name: e122614sim Dil. Factor: 1.68 Compound Vinyl Chloride 1,1-Dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Client Sample ID: 218 1/2_INSIDE_ Lab Duplicate Lab ID#: AA MODIFIED EPA METHOD TO-15 GC/MS SIM Rpt. Limit Amount Date of Collection: 12/9/09 2:05:00 PM Date of Analysis: 12/26/09 04:11 PM Rpt. Limit Amount Not Detected Not Detected Not Detected Not Detected Not Detected 0.13 Not Detected Container Type: 6 Liter Summa Special (SIM Certified) Surrogates 1,2-Dichloroethane-d4 Toluene-d8 4-Bromofluorobenzene Method %Recovery Limits Page 9 of 25

41 File Name: e122615sim Dil. Factor: 1.41 Compound Vinyl Chloride 1,1-Dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Client Sample ID: 218 1/2_OUTSIDE_ Lab ID#: A MODIFIED EPA METHOD TO-15 GC/MS SIM Rpt. Limit Amount Date of Collection: 12/9/09 2:10:00 PM Date of Analysis: 12/26/09 04:49 PM Rpt. Limit Amount Not Detected Not Detected Not Detected Not Detected Not Detected 0.11 Not Detected Container Type: 6 Liter Summa Special (SIM Certified) Surrogates 1,2-Dichloroethane-d4 Toluene-d8 4-Bromofluorobenzene Method %Recovery Limits Page 10 of 25

42 File Name: e122616sim Dil. Factor: 2.44 Compound Vinyl Chloride 1,1-Dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Client Sample ID: 214_LIVNGRM_ Lab ID#: A MODIFIED EPA METHOD TO-15 GC/MS SIM Rpt. Limit Amount Date of Collection: 12/9/09 3:10:00 PM Date of Analysis: 12/26/09 05:33 PM Rpt. Limit Amount Not Detected Not Detected Not Detected Not Detected Not Detected 0.19 Not Detected Container Type: 6 Liter Summa Special (SIM Certified) Surrogates 1,2-Dichloroethane-d4 Toluene-d8 4-Bromofluorobenzene Method %Recovery Limits Page 11 of 25

43 File Name: e122617sim Dil. Factor: 1.34 Compound Vinyl Chloride 1,1-Dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Client Sample ID: 214_BEDRM_ Lab ID#: A MODIFIED EPA METHOD TO-15 GC/MS SIM Rpt. Limit Amount Date of Collection: 12/9/09 3:11:00 PM Date of Analysis: 12/26/09 07:11 PM Rpt. Limit Amount Not Detected Not Detected Not Detected Not Detected Not Detected 0.11 Not Detected Container Type: 6 Liter Summa Special (SIM Certified) Surrogates 1,2-Dichloroethane-d4 Toluene-d8 4-Bromofluorobenzene Method %Recovery Limits Page 12 of 25

44 File Name: e122618sim Dil. Factor: 1.46 Compound Vinyl Chloride 1,1-Dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Client Sample ID: 214_OUT_ Lab ID#: A MODIFIED EPA METHOD TO-15 GC/MS SIM Rpt. Limit Amount Date of Collection: 12/9/09 3:20:00 PM Date of Analysis: 12/26/09 07:47 PM Rpt. Limit Amount Not Detected Not Detected Not Detected Not Detected Not Detected 0.12 Not Detected Container Type: 6 Liter Summa Special (SIM Certified) Surrogates 1,2-Dichloroethane-d4 Toluene-d8 4-Bromofluorobenzene Method %Recovery Limits Page 13 of 25

45 File Name: Dil. Factor: 6.56 Compound Vinyl Chloride 1,1-Dichloroethene trans-1,2-dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Client Sample ID: 222_PRODUCTION_ Lab ID#: A MODIFIED EPA METHOD TO-15 GC/MS FULL SCAN Rpt. Limit Amount Date of Collection: 12/9/09 8:25:00 AM Date of Analysis: 12/28/09 07:28 PM Rpt. Limit Amount 3.3 Not Detected 8.4 Not Detected 3.3 Not Detected 13 Not Detected 3.3 Not Detected 13 Not Detected 3.3 Not Detected 13 Not Detected 3.3 Not Detected 18 Not Detected 3.3 Not Detected 22 Not Detected Container Type: 6 Liter Summa Special (SIM Certified) Surrogates Toluene-d8 1,2-Dichloroethane-d4 4-Bromofluorobenzene Method %Recovery Limits Page 14 of 25

46 File Name: Dil. Factor: 13.4 Compound Vinyl Chloride 1,1-Dichloroethene trans-1,2-dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Client Sample ID: 222_SHIPPING_ Lab ID#: A MODIFIED EPA METHOD TO-15 GC/MS FULL SCAN Rpt. Limit Amount Date of Collection: 12/9/09 8:26:00 AM Date of Analysis: 12/28/09 09:50 PM Rpt. Limit Amount 6.7 Not Detected 17 Not Detected 6.7 Not Detected 26 Not Detected 6.7 Not Detected 26 Not Detected 6.7 Not Detected 26 Not Detected 6.7 Not Detected 36 Not Detected 6.7 Not Detected 45 Not Detected Container Type: 6 Liter Summa Special (SIM Certified) Surrogates Toluene-d8 1,2-Dichloroethane-d4 4-Bromofluorobenzene Method %Recovery Limits Page 15 of 25

47 File Name: e122706sim Dil. Factor: 1.71 Compound Vinyl Chloride 1,1-Dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Client Sample ID: 222_OUT_ Lab ID#: A MODIFIED EPA METHOD TO-15 GC/MS SIM Rpt. Limit Amount Date of Collection: 12/9/09 8:30:00 AM Date of Analysis: 12/27/09 11:06 AM Rpt. Limit Amount Not Detected Not Detected Not Detected Not Detected Not Detected 0.14 Not Detected Container Type: 6 Liter Summa Special (SIM Certified) Surrogates 1,2-Dichloroethane-d4 Toluene-d8 4-Bromofluorobenzene Method %Recovery Limits Page 16 of 25

48 File Name: e122605asim Dil. Factor: 1.00 Compound Vinyl Chloride 1,1-Dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Client Sample ID: Lab Blank Lab ID#: A MODIFIED EPA METHOD TO-15 GC/MS SIM Rpt. Limit Amount Date of Collection: NA Date of Analysis: 12/26/09 09:55 AM Rpt. Limit Amount Not Detected Not Detected Not Detected Not Detected Not Detected Not Detected Not Detected Not Detected Not Detected 0.14 Not Detected Container Type: NA - Not Applicable Surrogates 1,2-Dichloroethane-d4 Toluene-d8 4-Bromofluorobenzene Method %Recovery Limits Page 17 of 25

49 File Name: e122704sim Dil. Factor: 1.00 Compound Vinyl Chloride 1,1-Dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Client Sample ID: Lab Blank Lab ID#: B MODIFIED EPA METHOD TO-15 GC/MS SIM Rpt. Limit Amount Date of Collection: NA Date of Analysis: 12/27/09 09:45 AM Rpt. Limit Amount Not Detected Not Detected Not Detected Not Detected Not Detected Not Detected Not Detected Not Detected Not Detected 0.14 Not Detected Container Type: NA - Not Applicable Surrogates 1,2-Dichloroethane-d4 Toluene-d8 4-Bromofluorobenzene Method %Recovery Limits Page 18 of 25

50 File Name: Dil. Factor: 1.00 Compound Vinyl Chloride 1,1-Dichloroethene trans-1,2-dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Client Sample ID: Lab Blank Lab ID#: C MODIFIED EPA METHOD TO-15 GC/MS FULL SCAN Rpt. Limit Amount Date of Collection: NA Date of Analysis: 12/28/09 12:34 PM Rpt. Limit Amount 0.50 Not Detected 1.3 Not Detected 0.50 Not Detected 2.0 Not Detected 0.50 Not Detected 2.0 Not Detected 0.50 Not Detected 2.0 Not Detected 0.50 Not Detected 2.7 Not Detected 0.50 Not Detected 3.4 Not Detected Container Type: NA - Not Applicable Surrogates Toluene-d8 1,2-Dichloroethane-d4 4-Bromofluorobenzene Method %Recovery Limits Page 19 of 25

51 Client Sample ID: CCV Lab ID#: A MODIFIED EPA METHOD TO-15 GC/MS SIM File Name: e122602sim Dil. Factor: 1.00 Compound Vinyl Chloride 1,1-Dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Container Type: NA - Not Applicable Surrogates 1,2-Dichloroethane-d4 Toluene-d8 4-Bromofluorobenzene %Recovery Date of Collection: NA Date of Analysis: 12/26/09 07:53 AM %Recovery Method Limits Page 20 of 25

52 Client Sample ID: CCV Lab ID#: B MODIFIED EPA METHOD TO-15 GC/MS SIM File Name: e122702sim Dil. Factor: 1.00 Compound Vinyl Chloride 1,1-Dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Container Type: NA - Not Applicable Surrogates 1,2-Dichloroethane-d4 Toluene-d8 4-Bromofluorobenzene %Recovery Date of Collection: NA Date of Analysis: 12/27/09 07:57 AM %Recovery Method Limits Page 21 of 25

53 Client Sample ID: CCV Lab ID#: C MODIFIED EPA METHOD TO-15 GC/MS FULL SCAN File Name: Dil. Factor: 1.00 Compound Vinyl Chloride 1,1-Dichloroethene trans-1,2-dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Container Type: NA - Not Applicable Surrogates Toluene-d8 1,2-Dichloroethane-d4 4-Bromofluorobenzene %Recovery Date of Collection: NA Date of Analysis: 12/28/09 07:43 AM %Recovery Method Limits Page 22 of 25

54 Client Sample ID: LCS Lab ID#: A MODIFIED EPA METHOD TO-15 GC/MS SIM File Name: e122603sim Dil. Factor: 1.00 Compound Vinyl Chloride 1,1-Dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Container Type: NA - Not Applicable Surrogates 1,2-Dichloroethane-d4 Toluene-d8 4-Bromofluorobenzene %Recovery Date of Collection: NA Date of Analysis: 12/26/09 08:32 AM %Recovery Method Limits Page 23 of 25

55 Client Sample ID: LCS Lab ID#: B MODIFIED EPA METHOD TO-15 GC/MS SIM File Name: e122703sim Dil. Factor: 1.00 Compound Vinyl Chloride 1,1-Dichloroethene cis-1,2-dichloroethene Trichloroethene Tetrachloroethene Container Type: NA - Not Applicable Surrogates 1,2-Dichloroethane-d4 Toluene-d8 4-Bromofluorobenzene %Recovery Date of Collection: NA Date of Analysis: 12/27/09 08:35 AM %Recovery Method Limits Page 24 of 25