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Imagine the result Closure Request BP Facility No. 6008 212 15th Street Washougal, Washington June 30, 2011 Closure Request BP Facility No. 6008 Alexander Lopez III, LG 212 15th Street Project Geologist Washougal, Washington Prepared for: BP West Coast Products, LLC Prepared by: ARCADIS U.S., Inc. 111 SW Columbia Street Suite 670 Portland Oregon 97201 Tel 503 220 8201 Fax 503 220 8209 Thomas F. Mullen, LHG Our Ref.: Senior Hydrogeologist GP09BPNA.WA44.Q0000 Date: June 30, 2011 This document is intended only for the use of the individual or entity for which it was prepared and may contain information that is privileged, confidential and exempt from disclosure under applicable law. Any dissemination, distribution or copying of this document is strictly prohibited. Closure Request ARCO Facility No. 6008 Introduction 1 Property Information 2 Property Description 2 Property Zoning and Location 2 Site Discovery and Definition 2 Property Ownership and Use 3 Past Ownership and Use 3 Current Ownership and Use 3 Future Ownership and Use 3 Area Drinking Water Sources 4 Area Sensitive and Environmental Receptors 4 Environmental Conditions 6 Physiographic Setting and Topography 6 Geology and Hydrogeology 6 Surface Waters 6 Sediment 7 Soil Vapor 7 Ecological and Natural Resources 7 Cultural and Archaeological Resources 7 Summary of Previous Site Investigations 8 Summary of Previous Remedial Actions 12 Potential Constituents of Concern 13 Conceptual Site Model 15 Potential Constituent Sources 15 Potential Transport Mechanisms and Receptors 16 Ecological Receptors 17 Potential Exposure Pathways 17 i Closure Request ARCO Facility No. 6008 Site Clean-Up Levels 18 Method A Cleanup Levels 18 Points of Compliance 20 Applicable Relevant and Appropriate Regulations 20 Compliance with MTCA Statutes and Regulations 22 Soil 22 Grab Groundwater 22 Surface Waters 22 Sediment 22 Soil Vapor 23 Ecological and Natural Resources 23 Cultural and Archaeological Resources 23 Conclusions 24 References 26 Tables Table 1 Soil Analytical Results – January 2011 Table 2 Grab Groundwater Analytical Results – January 2011 Table 3 Historical Soil Analytical Results Figures Figure 1 Site Location Map Figure 2 Site Plan with Soil Boring and Soil Sampling Locations Figure 3 Cross Section Location Map Figure 4 Cross Section A-A’ Figure 5 Soil Analytical Results – January 2011 Figure 6 Grab Groundwater Analytical Results – January 2011 Figure 7 Human Health Conceptual Site Model ii Closure Request ARCO Facility No. 6008 Appendices A Voluntary Cleanup Program Application B Property Details and Legal Description C EDR Geocheck and Offsite Sensitive Receptor Reports D Boring Logs Acronyms and Abbreviations ARCADIS ARCADIS U.S., Inc. bgs below ground surface BTEX benzene, toluene, ethylbenzene, total xylenes COC constituents of concern CSM conceptual site model CUL cleanup levels Ecology Washington State Department of Ecology DRO diesel range organics EDB 1,2-dibromoethane EDC 1,2-dichloroethane GRO gasoline range organics HO heavy oil LUST Leaking Underground Storage Tank MSL mean sea level mg/kg milligrams per kilogram MTBE methyl tertiary-butyl ether MTCA Model Toxics Control Act NFA No Further Action PID photoionization detector PVC polyvinyl chloride Site ARCO Facility No. 6008 located at 212 15th Street, Washougal, Washington TEE Terrestrial Ecological Evaluation g/L micrograms per liter USEPA U.S. Environmental Protection Agency UST underground storage tank VCP Voluntary Cleanup Program iii Closure Request ARCO Facility No. 6008 Introduction On behalf of BP West Coast Products, LLC, ARCADIS U.S., Inc. (ARCADIS) has prepared this Request for Closure for ARCO Facility No. 6008 located at 212 15th Street in Washougal, Washington (the “Site”). The property and surrounding areas are illustrated in Figure 1. This report summarizes previous site investigation activities and is submitted concurrently with an application to the Washington State Department of Ecology (Ecology) Voluntary Cleanup Program (VCP) (Appendix A). The purpose of this report is to provide Ecology with information that will demonstrate that a No Further Action (NFA) determination is appropriate for the Site. 1 Closure Request ARCO Facility No. 6008 Property Information Property Description The Site is located at the northeast corner of the intersection of 15th Street and B Street in Washougal, Washington. The Site currently operates as an ARCO retail gasoline station and convenience store. Current facilities include four (4) 10,000-gallon, double-walled fiberglass gasoline underground storage tanks (USTs) and associated product piping on the north side of the Site, a canopy covering four dual dispenser pumps on the west side of the Site, and a second canopy covering two dual dispenser pumps on the southeast side of the Site. The entire Site is paved with asphalt or concrete with the exception of the station building, fuel dispensers, signage and landscaped areas. Previous facilities included two 6,000-gallon and two 4,000-gallon single-walled steel gasoline USTs which were decommissioned by removal in January and February 1990 (Sweet Edwards/EMCON 1991). Current and former site configurations are presented in Figure 2. A legal description of the property is presented in Appendix B. Property Zoning and Location The property is located in a mixed commercial/residential area of Washougal, Washington. According to the most recent (2008) zoning map produced by the City of Washougal Community Development Department, the Site is located within an area zoned as Town Center Core (TCC), which provides for commercial and residential use. The Site is bounded to the north by C Street and vacant property and to the east by residential properties. The Site is bounded to the south by B Street and a residential property across B Street and to the west by 15th Street and residential properties beyond 15th Street. The nearest surface water body, the Columbia River, is located approximately 0.17 mile south of the Site. The Washougal River is located approximately 0.45 mile northeast and 0.5 mile north of the Site. Site Discovery and Definition During UST decommissioning activities in January and February 1990, a small hole was reportedly observed in one of the gasoline USTs and petroleum-impacted soil was observed in the tank cavity (Sweet Edwards/EMCON 1991). Approximately 60 cubic yards of soil was excavated and placed in an on-site treatment gallery. Figure 2 shows 2 Closure Request ARCO Facility No. 6008 the treatment gallery location. The Site was listed on the Ecology Leaking Underground Storage Tank (LUST) database in January 1990. Property Ownership and Use Past Ownership and Use The property was previously owned by ARCO and was sold to the current owner in 2007 (Delta 2007). The property operated as a gasoline service station and convenience store. The following table summarizes former and current UST information: Tank Installation Decommissioning Tank ID Content Volume Date Date 1 4,000 Gasoline Unknown 1990 2 4,000 Gasoline Unknown 1990 3 6,000 Gasoline Unknown 1990 4 6,000 Gasoline Unknown 1990 5 10,000 Gasoline 1990 Operational 6 10,000 Gasoline 1990 Operational 7 10,000 Gasoline 1990 Operational 8 10,000 Gasoline 1990 Operational Current Ownership and Use In 2007, ARCO sold the property to the current property owner, KTK Kanso, LLC. The property continues to operate as a retail gasoline station and currently utilizes four 10,000-gallon USTs located on the west-central portion of the property. Future Ownership and Use Future use of the property is anticipated to remain as a retail gasoline station. Additionally, the property is expected to be continued to be zoned for mixed residential and commercial use. 3 Closure Request ARCO Facility No. 6008 Area Drinking Water Sources The public water supply for the City of Washougal is obtained from two sources. The primary production facility, located at 411 Third Street, began operations in 1942 with the installation of a public supply well. Four additional wells were installed to meet increased demands in 1947, 1954, 1983 and 2007 (City of Washougal 2009). Ecology well logs were located for the supply wells installed in 1954 and 2007. The 1954 well was drilled to a depth of 103 feet below ground surface (bgs), with a perforated casing between 84.5 and 98 feet bgs. The 2007 well was drilled to a depth of 100 feet and screened between 72 and 92 feet bgs. According to the well logs, clay or topsoil was encountered from the surface to approximately 3 feet bgs. Cobbles and boulders were generally encountered between 3 feet bgs and approximately 60 feet bgs. Gravels and sand with some cobbles were generally encountered between 60 feet bgs and 97 to 99 feet bgs. A layer of clay or gravel with clay was encountered at the terminus of each boring. A secondary supply source is located at 2801 I Street, with one active well installed in 1931. The secondary source is primarily used in the summer months. City water is treated with chlorine as a precaution against bacteria and sodium hydroxide as a corrosion inhibitor prior to holding in reservoirs (City of Washougal 2009). According to an EDR Geocheck Report (Inquiry #3057259.1s presented in Appendix C), there are 12 water wells and 1 public supply well located within 1 mile of the property. The nearest water wells were located ½ mile northeast and southeast of the property. The public supply well was located between ¼ and ½ mile northeast of the property. No water wells were found within ¼ mile of the Site. Based on the preceding information, groundwater beneath the Site is not used as a drinking water source and is not expected to be used as a potable water source in the future. Area Sensitive and Environmental Receptors According to an EDR Offsite Receptor Report (Inquiry #3057259.2s), there are no environmental receptors within 1 mile of the property. Five sensitive receptors are located within 1 mile of the property, including three daycare facilities (located 1/8 to ¼ mile, ¼ to ½ mile and ½ to 1 mile from the Site, respectively) and two health care facilities (located ½ to 1 mile from the property).