SAMPLING AND ANALYSIS PLAN FOR TIER 3 AIR QUALITY MONITORING 218-1/2 South Findlay Street, Seattle (Location 10)

SAMPLING AND ANALYSIS PLAN FOR TIER 3 AIR QUALITY MONITORING 218-1/2 South Findlay Street, Seattle (Location 10) Prepared for: Art Brass Plating, Inc. Project No. 050067-007B-01 August 5, 2009 Draft

SAMPLING AND ANALYSIS PLAN FOR TIER 3 AIR QUALITY MONITORING 218-1/2 South Findlay Street, Seattle (Location 10) Prepared for: Art Brass Plating, Inc. Project No. 050067-007B-01 August 5, 2009 Draft Aspect Consulting, LLC David A. Heffner, PE Associate Engineer dheffner@aspectconsulting.com V:\050067 Art Brass Plating\VI Assessment\218-onehalf\Draft SAP.doc 401 Second Avenue S, Suite 201 Seattle, WA 98104 Tel: (206) 328-7443 Fax: (206) 838-5853 www.aspectconsulting.com a limited liability company

ASPECT CONSULTING Contents Purpose of Air Quality Monitoring...1 Site Walk/Building Evaluation...1 Tier 3 Assessment Data Gaps...2 Sampling Methodology...3 Laboratory Analysis and Evaluation of Results...4 Data Quality Indicators...5 Precision and Accuracy... 5 Representativeness... 5 Comparability... 6 Completeness... 6 Schedule...6 Limitations...6 List of Tables 1 IPIMALs and Reporting Limits for Compounds of Concern in Air List of Figures 1 Floor Plan with Proposed Air Sampling Location List of Appendices A B Building Evaluation Form Quality Manual Excerpts, Air Toxics, Limited PROJECT NO. 050067-007B-01 AUGUST 5, 2009 DRAFT i

ASPECT CONSULTING Purpose of Air Quality Monitoring 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. ABP s VI Assessment Work Plan (dated August 29, 2008) specifies that groundwater quality data for monitoring wells AB-MW-9 and AB-MW-13 be evaluated with respect to volatilization potential ( Tier 1 of the decision process) to determine whether the residence at 218-1/2 South Findlay Street merits Tier 3 assessment (air quality monitoring). These wells were sampled in December 2008, and results of Tier 1 assessment were reported in the ABP progress report for 4th quarter 2008. Tier 3 assessment was determined to be warranted due to detection of an elevated concentration of trichloroethene (TCE) in the sample collected from the water table interval in well AB- MW-9. (Results for well AB-MW-13 did not indicate a potential VI concern.) This sampling and analysis plan (SAP) addresses air quality monitoring at 218-1/2 South Findlay Street to satisfy Tier 3 assessment requirements. The purpose of Tier 3 assessment is to determine if indoor air is being unacceptably impacted by VI. If monitoring results indicate unacceptable impacts, ABP will consult with Ecology regarding the need to either further assess indoor air impacts or implement an interim measure to mitigate the VI pathway. If the results indicate no unacceptable impacts, ABP will document this in a report which does not propose mitigation. Site Walk/Building Evaluation 218-1/2 South Findlay Street is a small (roughly 500 square feet) single-story residence located in the backyard of a larger house (218 South Findlay Street) that has an operating sub-slab depressurization system. A site walk/building evaluation was conducted on July 22, 2009. A completed Building Evaluation Form is included as Appendix A. A sketch of the building s floor plan is shown on Figure 1. (All locations and dimensions shown on the figure are approximate, based on observations and measurements made during the site walk.) The building appears to date from the late 1920s or 1930s, and is basic wood frame/lath construction. The floor of the structure is elevated nearly 2 feet above grade, and the underlying crawlspace is open to atmosphere along the south and west sides. (Plywood encloses the crawlspace along the building s north and east sides.) The base of the crawlspace is bare dirt. No significant floor penetrations were noted during the building evaluation. The residence is occupied by two adults who are both cigarette smokers. Other than cigarette smoke, no significant odors were noted during the site visit. PROJECT NO. 050067-007B-01 AUGUST 5, 2009 DRAFT 1

ASPECT CONSULTING Tier 3 Assessment Data Gaps As noted above, an elevated concentration of TCE was detected in the shallow (water table interval) groundwater sample collected from nearby well AB-MW-9 in December 2008. The groundwater table was approximately 7 feet below grade at the time of sample collection. TCE and other compounds of concern (COCs) could potentially volatilize from the groundwater, migrate through vadose zone soils, and enter the structure s living space via crawlspace air. Tier 3 assessment data gaps include the following: a) How high are TCE (and other COC) concentrations in soil gas near and under the building? b) How high are TCE (and other COC) concentrations in crawlspace air under the building, due solely to VI? c) How high are TCE (and other COC) concentrations in indoor air, due solely to VI? And, since questions b) and c) cannot be answered by only sampling crawlspace air and indoor air (unless one assumes that there are no other contaminant sources contributing to those measurements), two other important Tier 3 data gaps are: d) To what extent does ambient (outdoor) air pollution contribute to crawlspace and indoor air COC measurements? e) To what extent do contaminant sources in the structure itself (including the crawlspace) contribute to crawlspace and indoor air COC measurements? Question c) is the primary Tier 3 data gap. This data gap will be addressed by collecting an indoor air sample. To address question d), we plan to collect an outdoor (ambient background) air sample concurrent with the indoor sample. To address question e), steps will be taken to minimize potential contaminant sources in the structure itself. We did not observe any obvious COC-emitters during the site walk/building evaluation. We ve given the occupant Page 9 from the Building Evaluation Form entitled Instructions for Inhabitants of Building Prior to Sampling Event and discussed it with him. These instructions will be reviewed with the occupant again several days prior to the sampling event, in an effort to minimize contaminant contributions from potential sources within the structure. Given the elevated concentration of TCE detected in nearby shallow groundwater, TCE concentrations in soil gas under or approaching the house are potentially high enough to pose unacceptable VI impacts, and we do not propose to collect soil gas samples. Nor do we propose to collect an air sample in the crawlspace, since it is not an occupied space. 2 DRAFT PROJECT NO. 050067-007B-01 AUGUST 5, 2009

ASPECT CONSULTING Sampling Methodology Air quality monitoring will be conducted 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: One 24-hour time-integrated indoor air sample will be collected in a 6-liter Summa canister at the proposed sampling location shown on Figure 1. The proposed sampling location is centrally located within the small structure, in the room where the occupants spend most of their time. It is assumed that the measured COC concentrations, after accounting for any ambient contribution (see next bullet), will adequately represent average indoor COC concentrations due to VI impacts. One outdoor (ambient background) air sample will be collected concurrent with the indoor air sample. The outdoor sample will also be collected in a 6- liter Summa canister over a 24-hour period, from a minimum height of two meters above ground surface. An attempt will be made to locate the outdoor air sample upwind of the residence. It is assumed that an outdoor air sample collected at the same time as the indoor sample can adequately represent the ambient COC contribution to the measured indoor concentrations. If tubing is attached to a canister inlet (e.g., so that an air sample can be collected at an appropriate height above the ground or floor surface): The length of tubing will not exceed six feet; The tubing s inside diameter will not exceed 3/8-inch; and 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 will be introduced to the tubing using a GasTec plunger designed for pulling air samples through glass detector tubes. The weather forecast will be monitored, and an attempt will be made to collect the samples during a period of decreasing barometric pressure, preferably when a storm-generated low has reached the area. Weather conditions (temperature, wind speed, wind direction, and barometric pressure) observed at the Boeing Field weather station before, during, and at the conclusion of the sampling event will be recorded. Near-real-time data for this weather station will be accessed on-line immediately prior to initiating the sampling event, and wind direction data will be considered in selecting the outdoor sampling location. Each Summa canister will be certified clean and equipped with a vacuum gage and a flow regulator. To begin sample collection, the Aspect Consulting technician will open the valve on the flow regulator and record the initial vacuum gage reading and the start-of-sampling time in his field notes and on the sample information tag attached to the canister. After the sampling equipment is verified to be operating correctly, it will be left unattended. The Aspect Consulting technician will return after approximately 20 hours to PROJECT NO. 050067-007B-01 AUGUST 5, 2009 DRAFT 3

ASPECT CONSULTING check the canister to ensure that it still has an adequate vacuum. The flow regulator valve will be closed when the canister vacuum reaches approximately -5 to -6 inches mercury (Hg), or approximately 24 hours after start-of-sampling, whichever occurs first. When the valve is closed, the final vacuum gage reading and the end-of-sampling time will be recorded in the field notes and on the sample information tag. The Summa canisters will be packed in their original shipping containers and sent within 3 days to Air Toxics, Limited, in Folsom, California, for analysis. The field team conducting the Tier 3 sampling event will adhere to a project-specific, written Health and Safety Plan. Ecology will be notified at least one week prior to the sampling event, which will be coordinated with the occupants. The occupants will be contacted by phone approximately 3 days prior to start of sampling to review the Instructions for Inhabitants of Building Prior to Sampling Event (Page 9 of the Building Evaluation Form). Laboratory Analysis and Evaluation of Results Air samples will be analyzed for the following COCs using modified Method TO-15 SIM: tetrachloroethene (PCE) 1,1-dichloroethene vinyl chloride trichloroethene (TCE) cis-1,2-dichloroethene Reporting limits (RLs) are provided in Table 1. We will perform a cursory comparison of COC detections in indoor air relative to detections in well AB-MW-9 groundwater samples, and note any apparent discrepancies. For example, if an elevated concentration of PCE is detected in indoor air, we will conclude that it is likely coming from a source other than groundwater, since PCE was not detected in groundwater and we are not aware that TCE can transform/degrade to PCE in the environment. On the other hand, TCE detections that are significantly elevated above the outdoor measurement will need to be attributed to VI. Sampling results will be evaluated in accordance with the Tier 3 assessment methodology specified in the VI Assessment Work Plan. Indoor air concentrations (corrected to account for the contribution of ambient air) will be compared to the indoor air inhalation pathway interim measure action levels (IPIMALs) for a residential scenario (see Table 1). This will be done by calculating a cancer cumulative exceedance factor (CCEF) and a noncancer cumulative exceedance factor (NCCEF) for both indoor air samples. If the CCEF or the NCCEF exceeds a factor of 10 for either sample (indicating a carcinogenic risk of greater than 1E-5 and/or a hazard index greater than 1), the need to implement an interim measure to address the potential VI threat will be discussed with Ecology. Regardless of the outcome of the above evaluation, a draft Tier 3 assessment report that documents air sampling results and recommends next steps will be prepared and submitted to Ecology for review. 4 DRAFT PROJECT NO. 050067-007B-01 AUGUST 5, 2009

ASPECT CONSULTING Data Quality Indicators Data quality indicators (DQIs), including precision, accuracy, representativeness, comparability, and completeness (PARCC parameters), and data RLs are dictated by the data quality objectives, project requirements, and intended uses of the data. For this project, a primary criterion of the analytical data is to be of sufficient technical quality to determine whether the CCEF and NCCEF values calculated using the laboratory-reported COC concentrations are above or below a factor of 10. An assessment of data quality is based upon quantitative (precision, accuracy, and completeness) and qualitative (representativeness and comparability) indicators. Definitions of these parameters and the applicable QC procedures are presented below. Precision and Accuracy Precision measures the reproducibility of measurements, while accuracy measures correctness and includes components of random error (variability due to imprecision) and systemic error. Analytical precision is the agreement among multiple analyses of the same sample, which is quantitatively expressed as the relative percent difference (RPD) between duplicate sample results. Analytical accuracy is measured by comparing the percent recovery of analytes spiked (as compared to the expected value) to preestablished acceptance criteria. Elements of quality control employed by Air Toxics, Limited, to ensure analytical precision and accuracy (as well as other DQIs) are discussed in their Quality Manual, excerpts of which are included in Appendix B. Field duplicate samples represent total precision, the reproducibility associated with the entire sampling and analysis process for a given sampling event. However, the actual variability in indoor air concentrations between sampling events is expected to be much greater than any variability in measured concentrations that would be quantified through the analysis of field duplicate samples. For this reason, we do not propose to collect field duplicates for this project. Representativeness Representativeness measures how closely the measured results reflect the actual concentration or distribution of the chemical compounds in the matrix sampled. The goal of air sampling is to determine COC concentrations in indoor air, due solely to VI, under reasonable worst-case conditions. The following steps will be taken to increase the likelihood that air sampling results are representative: Time-integrated air samples will be collected over a 24-hour sampling period. The occupants will be encouraged to take steps to limit building ventilation (e.g., by keeping windows shut and not operating ventilation fans) during the sampling period; The occupants will be encouraged to take steps to minimize the potential for contaminant emissions from non-vi sources during the sampling period; and PROJECT NO. 050067-007B-01 AUGUST 5, 2009 DRAFT 5

ASPECT CONSULTING An attempt will be made to conduct sampling during a period of decreasing barometric pressure. Comparability Comparability is a qualitative parameter expressing the confidence with which one data set can be compared with another. The use of standard techniques for sample collection and a certified analytical laboratory for laboratory analyses should make data collected comparable between air sampling events. Completeness Completeness is defined as the percentage of measurements made that are judged to be valid measurements. Results will be considered valid if all the precision, accuracy, and representativeness objectives are met and if RLs are sufficient for the intended uses of the data. COC concentrations for indoor air canisters are considered critical and thus have a 100 percent target completeness goal. If overall completeness is less than 100 percent for indoor air canister COC data, Art Brass Plating will assess the reason for the lack of completeness. Further sample collection may be necessary, and will be completed under advisement from Ecology. Schedule General schedule requirements are discussed in the Schedule section of the VI Assessment Work Plan. The Work Plan calls for Tier 3 sampling to be completed within 30 days of Ecology approving the site-specific SAP. Depending on the extent of Ecology comments on this draft SAP, sampling could potentially be completed as early as September 2009. However, it is proposed that sampling not be conducted until the start of the heating season (e.g., November 2009), when any indoor air impacts are likely to be more severe. Air Toxics Laboratory should provide sampling results within 15 business days of canister receipt (anticipated in December 2009, assuming sampling in November), and a draft Tier 3 assessment report will be submitted to Ecology within 30 days of receiving sampling results from the laboratory (anticipated January 2010 submittal). 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. 6 DRAFT PROJECT NO. 050067-007B-01 AUGUST 5, 2009

Table 1 - IPIMALs and Reporting Limits for Compounds of Concern in Air Indoor Air IPIMALs for Residential Scenario Lowest Achievable Reporting Limit cited by Air Toxics, Lowest Reporting Limit (Approx.) after Accounting for Canister Compound of Concern Cancer Noncancer Ltd. (2) Pressurization (3) Tetrachloroethene (PCE) 0.42 27 0.14 0.22 Trichloroethene (TCE) 0.098 1.6 0.016 0.026 1,1-Dichloroethene -- 9.1 0.040 0.064 cis-1,2-dichloroethene -- 1.6 0.081 0.13 Vinyl Chloride 0.28 4.6 0.026 0.042 -- No toxicity value was available. Therefore, an IPIMAL could not be calculated. IPIMALs Inhalation pathway interim measure action levels Notes: 1) All concentrations are in units of micrograms per cubic meter (ug/m 3 ). 2) Reporting limits cited by Air Toxics, Ltd., for analysis by modified TO-15 SIM (Sh)/SpRL-Std 17 (TCE @ 3pptv). These limits do not take into account sample dilution due to canister pressurization. Per Air Toxics, the dilution factor from pressurization will typically raise reporting limits by a factor of 1.5 to 1.7 when using a 6-liter canister. 3) Values in this column were obtained by simply multiplying the previous column values by 1.6 (the average of 1.5 and 1.7; see Note 2). Aspect Consulting 8/5/09 V:\050067 Art Brass Plating\VI Assessment\218-onehalf\IPIMALs & Reporting Limits - Table1 Table 1 Page 1 of 1

Alley Electric heater Kitchen Living Room / Bedroom Utility / Storage Areas All locations and dimensions are approximate N 0 5 10 Feet earth+water www.aspectconsulting.com a limited liability company Bathroom Front Entry Legend Floor Plan with Proposed Air Sampling Location 218-1/2 South Findlay Street Art Brass Plating Seattle, Washington Proposed Indoor Air Sampling Location DATE: DESIGNED BY: DRAWN BY: REVISED BY: July 2009 DAH PMB PROJECT NO. 050067 FIGURE NO. 1 Q:\Art Brass Plating\050067 Art Brass\2009-07\050067-01.dwg

APPENDIX A Building Evaluation Form

APPENDIX B Quality Manual Excerpts Air Toxics, Limited