Item No.: 4a_attach_1 
Meeting Date:    July 1, 2014 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION X 
STATE OF WASHINGTON DEPARTMENT OF ECOLOGY 

IN THE MATTER OF:               ) 
) 
Lower Duwamish Waterway              ) 
) 
Port of Seattle, King County,                ) 
City of Seattle, The Boeing Company,           ) 
) 
RESPONDENTS               ) 
)       SECOND AMENDMENT 
) 
Proceeding Under Sections l04, 122(a),          )     U.S. EPA, Region 10 
122(d)(3) of the Comprehensive              )     Docket No. CERCLAEnvironmental
Response, Compensation,        )     10-2001-0055 
and Liability Act (CERCLA), as amended,       ) 
42 U.S.C.  9604, 9622(a), 9622(d)(3) and Under the )     Ecology Docket No. 
Washington State Model Toxics Control Act )    00TCPNR-1895 
(MTCA), ch. 70.105D RCW.              ) 
________________________________________________) 

This Second Amendment to the Administrative Order on Consent For Remedial Investigation/ Feasibility Study
(AOC) for the Lower Duwamish Waterway (LDW), CERCLA Docket No. 10-2001-0055, issued on December
20, 2000, requires performance of the Enhanced Natural Recovery (ENR)/Activated Carbon (AC) pilot study
set forth below under the terms and conditions of the AOC by mutual agreement with the Parties in accordance
with Section XXVI of the AOC. This statement of work (SOW) for the ENR/AC pilot study for the Lower
Duwamish Waterway (LDW) provides a general overview of the work to be performed, a list of study
steps/tasks, and a schedule for deliverables. 
The goals of the ENR/AC pilot study are to: 
Verify that ENR amended with AC can be successfully applied in the LDW by monitoring
physical placement success (uniformity of coverage and percent of carbon in a placed layer); 
Evaluate performance of ENR/AC compared to ENR alone in locations with a range of
polychlorinated biphenyl (PCB) concentrations; 
Assess potential impacts to the benthic community in ENR/AC compared to ENR alone; and 
Assess changes in bioavailability in ENR/AC compared to ENR alone. 
In addition, LDWG may propose to evaluate whether ENR/AC will remain stable in scour areas (Category 1
areas).

The study is intended to help inform the remedial design for the LDW related to the implementation and
effectiveness of remedial technologies. Study results will be used to re-assess and appropriately refine the
technology assignment assumptions for ENR, ENR/AC, and (if approved by EPA and Ecology) ENR/AC/scour
mitigation applications. 
The tasks are briefly described below.
Task 1: Identify Plot Locations (QAPP and Field Collection). First, LDWG will prepare a memorandum
which includes tables and figures identifying candidate plot locations for the Pilot Study including a review of
existing data and a rationale for selecting plot areas for sampling and send to EPA and Ecology for initial
review. Based on initial discussions with EPA and Ecology, LDWG will prepare a Quality Assurance Project
Plan (QAPP) for collection of surface sediment samples to be used for confirmation of plot locations. The
QAPP will include a Health and Safety Plan for preliminary sampling. After approval of the QAPP, LDWG will
collect bulk surface sediment data (e.g., PCB Aroclors, total organic carbon) from proposed plot areas to
confirm target sediment concentrations. Validated data from this effort will be provided to EPA/Ecology.
Study plot locations and sizes will be finalized in a working meeting with EPA/Ecology. 
Task 2: Prepare the Design Package. LDWG will prepare a design package that evaluates sediment data
collected under Task 1 and finalizes the design plans for each plot area. The design package will present the
selected plot locations, and include existing conditions for each plot, the rationale for the proposed locations,
and the proposed size of the test plots. Test plots will be approximately 1/2 acre in size per treatment subplot.
The design package will include: 
Contract drawings and technical specifications 
Narrative design report 
QAPP for baseline and post-construction monitoring 
Water quality monitoring plan for construction 
Construction quality assurance plan 
Health and Safety Plan 
The design package will also include any evaluations needed for substantive compliance with the Clean Water
Act (e.g., Section 404(b)) and the Endangered Species Act. 
Technical details regarding the pilot study scope include: 
Evaluate the use of ENR material (e.g., sand) and ENR sand amended with AC. The study will focus on
total PCBs as the indicator chemical. Surface sediment and porewater will be analyzed for PCB
congeners to assess bioavailability. Information on other contaminants (e.g., polycyclic aromatic
hydrocarbons (PAHs)) may be collected for informational purposes, as determined from contaminant 
concentrations within selected plot locations. 
Use one target carbon dose for all study plots. The proposed carbon dose will be presented in the design
package. 
Use one delivery mechanism for all study plots. Material will be placed mechanically. The proposed
delivery mechanism will be presented in the design package 
Test two or three paired study plots:
o  ENR and ENR/AC in subtidal area 
SECOND AMENDMENT TO LDW RI/FS ORDER - 2

o  ENR and ENR/AC in intertidal area 
o  LDWG may also propose a third paired study plot which includes ENR/AC/scour mitigation and
ENR/scour mitigation in areas of limited scour potential. 
The study plots will be selected to include a range of PCB concentrations from the RAL (SQS) up to the
CSL.
Task 3: Develop Construction Work Plan. LDWG will develop a Work Plan for construction of the
pilot study. This plan will provide the detailed means and methods for conducting the work.
Task 4: Implement Field Pilot Study and Post-Construction Monitoring. LDWG will implement the
ENR/AC pilot per the Construction Work Plan. LDWG will collect baseline data prior to placement of the plots 
and will collect post-construction data. Baseline and post-construction data collection will include, but not be
limited to: 
Porewater data (PCBs and potentially other contaminants as determined in the design package); 
Bulk sediment data (additional PCB data if needed), conventional parameters (e.g., total organic
carbon), black carbon, and potentially other contaminants as determined in the design package; 
SPI camera surveys for benthic community successional stages and stability (deposition and mixing
patterns); 
Benthic infauna surveys (Year 3); and 
Physical conditions of the placed layer (post-construction). 
Baseline data will be collected before construction to establish the baseline bioavailability metric. Construction
will be conducted during the in-water work window as approved by EPA in consultation with NOAA, USFWS
and Tribes, in accordance with the Construction Work Plan. Placement of material will be verified immediately
after completion of construction. 
Post-construction monitoring will be conducted annually for up to 3 years post-placement (Year 1, Year 2, Year
3). Benthic infauna surveys will be conducted to evaluate community function at the end of the 3-year period.
(Another monitoring event may be conducted 5 years post-construction under a separate scope as part of the
remedial design effort, to be determined based on results of year 3 monitoring.) 
Task 5: Prepare Data Report(s). Validated sampling data will be provided to EPA and Ecology within 75
days after completion of any sampling event (and 90 days after the Year 3 event). Data will be analyzed and
reports will be prepared following the Year 1 sampling and at the end of the 3-year monitoring period. The
Year 1 report will include the construction completion details, baseline data, and the Year 1 monitoring results.
The Year 3 report will include the Year 2 and Year 3 monitoring results. LDWG will submit draft reports for
review by EPA/Ecology. The reports will be revised and finalized and approved per the AOC process.
Table 1 provides a schedule for completing the key deliverables/milestones associated with the LDW Pilot
Study. All project deliverables will be submitted by LDWG and revised to address all EPA and Ecology
comments in accordance with the schedule in Table 1.
Table 1.     Schedule for Task Deliverables/Milestones 
SECOND AMENDMENT TO LDW RI/FS ORDER - 3

Task          Deliverable          Schedule 
Draft Memorandum of   7 days after issuance of AOC amendment 
candidate plot locations 
Draft QAPP for plot     45 days after submittal of draft memorandum
sampling             of candidate plot locations to EPA/Ecology 
Task 1: Study Plot
Identification      Final QAPP for plot      20 days after receipt of EPA/Ecology
(QAPP and     sampling           comments 
Sampling) 
Validated data to        65 days after approval of QAPP 
EPA/Ecology 
Working meeting with EPA/Ecology to select
Finalize Plot Locations 
plots 7 days after submittal of validated data 
Notify EPA and Ecology  145 days after issuance of AOC amendment 
of design contractor 
Task 2: Design
Package         Draft Design Report     130 days after selection/approval of plots 
Final Design Report      45 days after receipt of EPA comments 
Notify EPA and Ecology  Within 145 days after approval of the Final
of Construction         Design Report 
Contractor(s) 
Task 3:
Construction Work  Draft Construction Work  60 days after award of construction contractor 
Plan            Plan 
Final Construction Work  25 days from receipt of EPA/Ecology
Plan                 comments 
Notification for Pilot      Provide notification to EPA/Ecology 30 days
Task 4: Implement
Study Construction Start   prior to initiation of field construction 
Field Pilot Study
and Post-        Completion of         Per approved construction schedule 
Construction      Construction 
Monitoring 
Completion of Monitoring  3 years after completion of construction 
75 days after completion of any sampling
Sampling data 
event (90 days after Year 3 event) 
90 days after completion of Year 1 monitoring
Year 1 Draft Data Report 
event, including data validation 
30 days from the receipt of EPA/Ecology
Task 5: Reporting   Year 1 Final Data Report 
comments 
90 days after completion of Year 3 monitoring
Year 3 Draft Data Report 
event, including data validation 
30 days from the receipt of EPA/Ecology
Year 3 Final Data Report 
comments 
Note: Progress reports will be submitted monthly for the duration of the pilot study, consistent with the requirements set forth in the
AOC. 
SECOND AMENDMENT TO LDW RI/FS ORDER - 4

Ecology  Washington State Department of Ecology 
EPA  U.S. Environmental Protection Agency 
QAPP quality assurance project plan 
All schedule dates are expressed in calendar days 

It is so ORDERED and AGREED this ___ day of _______________, 2014. 

By: ________________________________ 
Cami Grandinetti 
Remedial Program Manager 
Environmental Cleanup Office 
U.S. EPA, Region X 

By: ________________________________ 
James J. Pendowski 
Program Manager 
Toxics Cleanup Program 
State of Washington Department of Ecology 



Agreed this ___  day of _______________, 2014. 
For Respondent Port of Seattle 

By
Title _________________ 



SECOND AMENDMENT TO LDW RI/FS ORDER - 5

Agreed this _____  day of _______________, 2014. 
For Respondent City of Seattle 

By
Title _______________________ 
















SECOND AMENDMENT TO LDW RI/FS ORDER - 6

Agreed this  ____ day of ______________, 2014. 
For Respondent King County 

By
Title ______________________ 
















SECOND AMENDMENT TO LDW RI/FS ORDER - 7

Agreed this ___  day of ______________, 2014. 
For Respondent The Boeing Company 

By
Title _________________________ 














SECOND AMENDMENT TO LDW RI/FS ORDER - 8