T-30 Environmental Cleanup Project Consent decree
FILED
17 JUL 19 PM 12:19
KING COUNTY
1 SUPERIOR COURT CLERK
E-FILED
2 CASE NUMBER: 17-2-19080-2 SEA
3
4
5
6
7 STATE OF WASHINGTON
KING COUNTY SUPERIOR COURT
8
STATE OF WASHINGTON, NO.
9 DEPARTMENT OF ECOLOGY,
10 Plaintiff, CONSENT DECREE
11 v. RE: TERMINAL 30 SITE
12 PORT OF SEATTLE,
13 Defendant.
14
TABLE OF CONTENTS
15
I. INTRODUCTION ........................................................................................................ 3
16 II. JURISDICTION ........................................................................................................... 4
III. PARTIES BOUND ....................................................................................................... 4
17 IV. DEFINITIONS ............................................................................................................. 5
V. FINDINGS OF FACTS ................................................................................................ 5
18 VI. WORK TO BE PERFORMED ..................................................................................... 7
VII. DESIGNATED PROJECT COORDINATORS ........................................................... 8
19 VIII. PERFORMANCE ......................................................................................................... 9
IX. ACCESS ....................................................................................................................... 9
20 X. SAMPLING, DATA SUBMITTAL, AND AVAILABILITY ................................... 10
XI. PROGRESS REPORTS ............................................................................................. 11
21 XII. RETENTION OF RECORDS .................................................................................... 12
XIII. TRANSFER OF INTEREST IN PROPERTY ........................................................... 12
22 XIV. RESOLUTION OF DISPUTES ................................................................................. 13
XV. AMENDMENT OF DECREE .................................................................................... 15
23 XVI. EXTENSION OF SCHEDULE .................................................................................. 15
XVII. ENDANGERMENT ................................................................................................... 17
24 XVIII. COVENANT NOT TO SUE ...................................................................................... 18
XIX. CONTRIBUTION PROTECTION ............................................................................ 19
25 XX. LAND USE RESTRICTIONS ................................................................................... 19
XXI. FINANCIAL ASSURANCES .................................................................................... 20
26 XXII. INDEMNIFICATION ................................................................................................ 21
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 XXIII. COMPLIANCE WITH APPLICABLE LAWS ......................................................... 21
XXIV. REMEDIAL ACTION COSTS .................................................................................. 22
2 XXV. IMPLEMENTATION OF REMEDIAL ACTION ..................................................... 23
XXVI. PERIODIC REVIEW ................................................................................................. 23
3 XXVII. PUBLIC PARTICIPATION ....................................................................................... 24
XXVIII. DURATION OF DECREE ......................................................................................... 25
4 XXIX. CLAIMS AGAINST THE STATE ............................................................................ 25
XXX. EFFECTIVE DATE.................................................................................................... 26
5 XXXI. WITHDRAWAL OF CONSENT ............................................................................... 26
6 EXHIBIT A Site Diagram
EXHIBIT B Cleanup Action Plan
7 EXHIBIT C Scope of Work and Schedule
EXHIBIT D SEPA Checklist
8 EXHIBIT E List of Applicable or Relevant and Appropriate Requirements
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 I. INTRODUCTION
2 A. The mutual objective of the State of Washington, Department of Ecology
3 (Ecology) and Port of Seattle (Defendant) under this Decree is to provide for remedial action at
4 a facility where there has been a release or threatened release of hazardous substances. This
5 Decree requires Defendant to perform final cleanup of the Terminal 30 Site in Seattle,
6 Washington. The final cleanup includes the installation and operation of an air sparging/soil
7 vapor extraction (AS/SVE) treatment system, the recovery of light non-aqueous phase liquid
8 (LNAPL), and the performance of reporting and monitoring activities.
9 B. Ecology has determined that these actions are necessary to protect human health
10 and the environment.
11 C. The Complaint in this action is being filed simultaneously with this Decree. An
12 Answer has not been filed, and there has not been a trial on any issue of fact or law in this case.
13 However, the Parties wish to resolve the issues raised by Ecology’s Complaint. In addition,
14 the Parties agree that settlement of these matters without litigation is reasonable and in the
15 public interest, and that entry of this Decree is the most appropriate means of resolving these
16 matters.
17 D. By signing this Decree, the Parties agree to its entry and agree to be bound by
18 its terms.
19 E. By entering into this Decree, the Parties do not intend to discharge non-settling
20 parties from any liability they may have with respect to matters alleged in the Complaint. The
21 Parties retain the right to seek reimbursement, in whole or in part, from any liable persons for
22 sums expended under this Decree.
23 F. This Decree shall not be construed as proof of liability or responsibility for any
24 releases of hazardous substances or cost for remedial action nor an admission of any facts;
25 provided, however, that Defendant shall not challenge the authority of the Attorney General
26 and Ecology to enforce this Decree.
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 G. The Court is fully advised of the reasons for entry of this Decree, and good
2 cause having been shown:
3 Now, therefore, it is HEREBY ORDERED, ADJUDGED, AND DECREED as follows:
4 II. JURISDICTION
5 A. This Court has jurisdiction over the subject matter and over the Parties pursuant
6 to the Model Toxics Control Act (MTCA), RCW 70.105D.
7 B. Authority is conferred upon the Washington State Attorney General by
8 RCW 70.105D.040(4)(a) to agree to a settlement with any potentially liable person (PLP) if,
9 after public notice and any required hearing, Ecology finds the proposed settlement would lead
10 to a more expeditious cleanup of hazardous substances. RCW 70.105D.040(4)(b) requires that
11 such a settlement be entered as a consent decree issued by a court of competent jurisdiction.
12 C. Ecology has determined that a release or threatened release of hazardous
13 substances has occurred at the Site that is the subject of this Decree.
14 D. Ecology has given notice to Defendant of Ecology’s determination that
15 Defendant is a PLP for the Site, as required by RCW 70.105D.020(26) and WAC 173-340-500.
16 E. The actions to be taken pursuant to this Decree are necessary to protect public
17 health and the environment.
18 F. This Decree has been subject to public notice and comment.
19 G. Ecology finds that this Decree will lead to a more expeditious cleanup of
20 hazardous substances at the Site in compliance with the cleanup standards established under
21 RCW 70.105D.030(2)(e) and WAC 173-340.
22 H. Defendant has agreed to undertake the actions specified in this Decree and
23 consents to the entry of this Decree under MTCA.
24 III. PARTIES BOUND
25 This Decree shall apply to and be binding upon the Parties to this Decree, their
26 successors and assigns. The undersigned representative of each party hereby certifies that he
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 or she is fully authorized to enter into this Decree and to execute and legally bind such party to
2 comply with this Decree. Defendant agrees to undertake all actions required by the terms and
3 conditions of this Decree. No change in ownership or corporate status shall alter Defendant’s
4 responsibility under this Decree. Defendant shall provide a copy of this Decree to all agents,
5 contractors, and subcontractors retained to perform work required by this Decree, and shall
6 ensure that all work undertaken by such agents, contractors, and subcontractors complies with
7 this Decree.
8 IV. DEFINITIONS
9 Unless otherwise specified herein, all definitions in RCW 70.105D.020 and
10 WAC 173-340-200 shall control the meanings of the terms in this Decree.
11 A. Site: The Site is referred to as Terminal 30 (T30) and is generally located at
12 1901 East Marginal Way South, Seattle, Washington, approximately one mile southwest of
13 downtown Seattle, in King County, Washington on the shoreline of the East Waterway. The
14 Site is defined by the extent of contamination caused by the release of hazardous substances,
15 more particularly described in the Site Diagram (Exhibit A). The Site constitutes a facility
16 under RCW 70.105D.020(8).
17 B. Parties: Refers to the State of Washington, Department of Ecology and the Port
18 of Seattle.
19 C. Defendant: Refers to the Port of Seattle.
20 D. Consent Decree or Decree: Refers to this Consent Decree and each of the
21 exhibits to this Decree. All exhibits are integral and enforceable parts of this Consent Decree.
22 The terms “Consent Decree” or “Decree” shall include all exhibits to this Consent Decree.
23 V. FINDINGS OF FACTS
24 Ecology makes the following findings of fact without any express or implied
25 admissions of such facts by Defendant.
26
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 A. The Site is located at 1901 East Marginal Way South, Seattle, Washington,
2 approximately one mile southwest of downtown Seattle, in King County, across the East
3 Waterway from Harbor Island. The Site location is depicted in Exhibit A. The facility is
4 depicted in Exhibit A. The Site is listed on the Department of Ecology’s Cleanup Sites List as
5 “Port of Seattle Terminal 30” with the Facility Site ID No. 2055.
6 B. The Defendant is the owner of the Site, and has owned the Site continuously
7 since 1985. Since 1905, a Chevron bulk fuel terminal occupied a portion of T30. The Chevron
8 bulk fuel terminal consisted of above-ground fuel storage tanks and associated piping and
9 equipment. The Port purchased T30 from Chevron on January 2, 1985. The fuel terminal was
10 demolished between December 1984 and about November 1985. The Port redeveloped the
11 33.9 acre Terminal 30 as a container facility.
12 C. Since the early 1990s, petroleum contamination caused by releases at the former
13 Chevron bulk fuel terminal has been the subject of a number of investigations and interim
14 actions.
15 D. A product recovery system was installed in the 1980s that removed more than
16 171,000 gallons of petroleum product. As part of the redevelopment in 2007, a site-wide
17 asphalt cover was constructed, and more than 24,000 cubic yards of petroleum-impacted soil
18 were disposed of offsite. However, substantial petroleum product remained in the soil and
19 groundwater at the Site.
20 E. The primary contaminants identified in soil and groundwater are:
21 Petroleum Hydrocarbons
22 Diesel-Range Organics
23 Gasoline-Range Organics
24 Oil-Range Organics
25 BTEX: Benzene, Toluene, Ethylbenzene, Xylenes (total)
26
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 Semi-Volatile Organic Compounds
2 2-methylnapthalene
3 Polynuclear Aromatic Hydrocarbons (PAHs)
4 F. As required by the 1991 Agreed Order (AO), a draft Remedial
5 Investigation/Feasibility Study (RI/FS) was developed in 1998 by GeoEngineers (1998 RI/FS)
6 to document the nature and extent of contamination and to evaluate remedial alternatives.
7 Ecology did not approve the draft RI/FS.
8 G. A draft final RI/FS was prepared by Pacific Groundwater Group (PGG) in 2013
9 to update the status of petroleum contamination at the site, to identify a preferred final remedial
10 action, and to fulfill the requirements of the 1991 AO.
11 H. Section V of the 1991 AO was amended on October 23, 2013, such that the Port
12 would prepare and submit a draft Cleanup Action Plan (dCAP) for Ecology review and
13 approval.
14 I. All requirements under the 1991 AO, as amended, have been completed to
15 Ecology’s satisfaction.
16 VI. WORK TO BE PERFORMED
17 This Decree contains a program designed to protect human health and the environment
18 from the known release, or threatened release, of hazardous substances or contaminants at, on,
19 or from the Site.
20 A. The defendant shall perform a cleanup action at the Site by implementing the
21 Cleanup Action Plan (CAP) (Exhibit B), which establishes the required remedial actions at the
22 Site in accordance with the Scope of Work and Schedule (Exhibit C) and all other
23 requirements of this Decree. The CAP, and Scope of Work and Schedule are incorporated by
24 reference and form an integral and enforceable part of this Decree These remedial actions
25 include implementing air sparging/soil vapor extraction (AS/SVE) treatment in the Sheen Area
26 in the vicinity of monitoring wells (going south to north) MW-36, MW-39, and MW-42; light
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 non-aqueous phase liquid (LNAPL) recovery and AS/SVE treatment in the vicinity of RW-12
2 and MW-59; and confirmation, performance, and compliance monitoring.
3 B. Defendant agrees not to perform any remedial actions outside the scope of this
4 Decree unless the Parties agree to modify the CAP (Exhibit B) and Scope of Work and
5 Schedule (Exhibit C) to cover these actions. All work conducted by Defendant under this
6 Decree shall be done in accordance with WAC 173-340 unless otherwise provided herein.
7 C. All plans or other deliverables submitted by the Port of Seattle for Ecology’s
8 review and approval under the CAP (Exhibit B) and Scope of Work and Schedule (Exhibit C)
9 shall, upon Ecology’s approval, become integral and enforceable parts of this Decree.
10 VII. DESIGNATED PROJECT COORDINATORS
11 The project coordinator for Ecology is:
12 Sunny Becker
3190 160th Avenue SE
13 Bellevue, WA 98008
hlin461@ecy.wa.gov
14 (425) 649-7187
15 The project coordinator for Defendant is:
16 Roy Kuroiwa
Port of Seattle
17 2711 Alaskan Way
Seattle, WA 98121
18 kuroiwa.r@portseattle.org
(206) 787-3814
19
Each project coordinator shall be responsible for overseeing the implementation of this
20
Decree. Ecology’s project coordinator will be Ecology’s designated representative for the Site.
21
To the maximum extent possible, communications between Ecology and Defendant and all
22
documents, including reports, approvals, and other correspondence concerning the activities
23
performed pursuant to the terms and conditions of this Decree shall be directed through the
24
project coordinators. The project coordinators may designate, in writing, working level staff
25
26
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 contacts for all or portions of the implementation of the work to be performed required by this
2 Decree.
3 Any party may change its respective project coordinator. Written notification shall be
4 given to the other party at least ten (10) calendar days prior to the change.
5 VIII. PERFORMANCE
6 All geologic and hydrogeologic work performed pursuant to this Decree shall be under
7 the supervision and direction of a geologist or hydrogeologist licensed by the State of
8 Washington or under the direct supervision of an engineer registered by the State of
9 Washington, except as otherwise provided for by RCW 18.43 and 18.220.
10 All engineering work performed pursuant to this Decree shall be under the direct
11 supervision of a professional engineer registered by the State of Washington, except as
12 otherwise provided for by RCW 18.43.130.
13 All construction work performed pursuant to this Decree shall be under the direct
14 supervision of a professional engineer or a qualified technician under the direct supervision of
15 a professional engineer. The professional engineer must be registered by the State of
16 Washington, except as otherwise provided for by RCW 18.43.130.
17 Any documents submitted containing geologic, hydrologic, or engineering work shall
18 be under the seal of an appropriately licensed professional as required by RCW 18.43
19 and 18.220.
20 Defendant shall notify Ecology in writing of the identity of any engineer(s) and
21 geologist(s), contractor(s) and subcontractor(s), and others to be used in carrying out the terms
22 of this Decree, in advance of their involvement at the Site.
23 IX. ACCESS
24 Ecology or any Ecology authorized representative shall have access to enter and freely
25 move about all property at the Site that Defendant either owns, controls, or has access rights to
26 at all reasonable times for the purposes of, inter alia: inspecting records, operation logs, and
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 contracts related to the work being performed pursuant to this Decree; reviewing Defendant’s
2 progress in carrying out the terms of this Decree; conducting such tests or collecting such
3 samples as Ecology may deem necessary; using a camera, sound recording, or other
4 documentary type equipment to record work done pursuant to this Decree; and verifying the
5 data submitted to Ecology by Defendant. Defendant shall make all reasonable efforts to secure
6 access rights for those properties within the Site not owned or controlled by Defendant where
7 remedial activities or investigations will be performed pursuant to this Decree. Ecology or any
8 Ecology authorized representative shall give reasonable notice before entering any Site
9 property owned or controlled by Defendant unless an emergency prevents such notice. All
10 Parties who access the Site pursuant to this section shall comply with any applicable health and
11 safety plan(s) in compliance with Transportation Worker Identification Credential (TWIC)
12 requirements, or will be TWIC escorted. Ecology employees and their representatives shall
13 not be required to sign any liability release or waiver as a condition of Site property access.
14 X. SAMPLING, DATA SUBMITTAL, AND AVAILABILITY
15 With respect to the implementation of this Decree, Defendant shall make the results of
16 all sampling, laboratory reports, and/or test results generated by it or on its behalf available to
17 Ecology. Pursuant to WAC 173-340-840(5), all sampling data shall be submitted to Ecology
18 in both printed and electronic formats in accordance with Section XI (Progress Reports),
19 Ecology’s Toxics Cleanup Program Policy 840 (Data Submittal Requirements), and/orany
20 subsequent procedures specified by Ecology for data submittal.
21 If requested by Ecology, Defendant shall allow Ecology and/or its authorized
22 representative to take split or duplicate samples of any samples collected by Defendant
23 pursuant to the implementation of this Decree. Defendant shall notify Ecology seven (7) days
24 in advance of any sample collection or work activity at the Site. Ecology shall, upon request,
25 allow Defendant and/or its authorized representative to take split or duplicate samples of any
26 samples collected by Ecology pursuant to the implementation of this Decree, provided that
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 doing so does not interfere with Ecology’s sampling. Without limitation on Ecology’s rights
2 under Section IX (Access), Ecology shall notify Defendant prior to any sample collection
3 activity unless an emergency prevents such notice.
4 In accordance with WAC 173-340-830(2)(a), all hazardous substance analyses shall be
5 conducted by a laboratory accredited under WAC 173-50 for the specific analyses to be
6 conducted, unless otherwise approved by Ecology.
7 XI. PROGRESS REPORTS
8 Defendant shall submit to Ecology written calendar quarterly Progress Reports that
9 describe the actions taken during the previous quarter to implement the requirements of this
10 Decree. The Progress Reports shall include the following:
11 A. A list of onsite activities that have taken place during the quarter;
12 B. Detailed description of any deviations from required tasks not otherwise
13 documented in project plans or amendment requests;
14 C. Description of all deviations from the CAP (Exhibit B) and Scope of Work and
15 Schedule (Exhibit C) during the previous quarter and any planned deviations in the upcoming
16 quarter;
17 D. For any deviations in schedule, a plan for recovering lost time and maintaining
18 compliance with the schedule;
19 E. All quality assurance/quality control reviewed data (including laboratory
20 analyses) received by Defendant during the past quarter and an identification of the source of
21 the sample; and
22 F. A list of deliverables for the upcoming month if different from the schedule.
23 All Progress Reports shall be submitted during the month following completion of a
24 quarter. At Ecology’s discretion, the frequency of progress reports may be adjusted. Unless
25 otherwise specified, Progress Reports and any other documents submitted pursuant to this
26
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 Decree shall be sent by certified mail, return receipt requested, to Ecology’s project
2 coordinator.
3 XII. RETENTION OF RECORDS
4 During the pendency of this Decree, and for ten (10) years from the date this Decree is
5 no longer in effect as provided in Section XXVIII (Duration of Decree), Defendant shall
6 preserve all records, reports, documents, and underlying data in its possession relevant to the
7 implementation of this Decree and shall insert a similar record retention requirement into all
8 contracts with project contractors and subcontractors. Upon request of Ecology, Defendant
9 shall make all records available to Ecology and allow access for review within a reasonable
10 time.
11 Nothing in this Decree is intended by Defendant to waive any right it may have under
12 applicable law to limit disclosure of documents protected by the attorney work-product
13 privilege and/or the attorney-client privilege. If Defendant withholds any requested records
14 based on an assertion of privilege, Defendant shall provide Ecology with a privilege log
15 specifying the records withheld and the applicable privilege. No Site-related data collected
16 pursuant to this Decree shall be considered privileged.
17 XIII. TRANSFER OF INTEREST IN PROPERTY
18 No voluntary conveyance or relinquishment of title, easement, leasehold, or other
19 interest in any portion of the Site shall be consummated by Defendant without provision for
20 continued operation and maintenance of any containment system, treatment system, and/or
21 monitoring system installed or implemented pursuant to this Decree.
22 Prior to Defendant’s transfer of any interest in all or any portion of the Site, and during
23 the effective period of this Decree, Defendant shall provide a copy of this Decree to any
24 prospective purchaser, lessee, transferee, assignee, or other successor in said interest; and, at
25 least thirty (30) days prior to any transfer, Defendant shall notify Ecology of said transfer.
26 Upon transfer of any interest, Defendant shall notify all transferees of the restrictions on the
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 activities and uses of the property under this Decree and incorporate any such use restrictions
2 into the transfer documents.
3 XIV. RESOLUTION OF DISPUTES
4 A. In the event that Defendant elects to invoke dispute resolution, Defendant must
5 utilize the procedure set forth below.
6 1. Upon the triggering event (receipt of Ecology’s project coordinator’s
7 written decision or an itemized billing statement), Defendant has fourteen (14) calendar
8 days within which to notify Ecology’s project coordinatorin writing of its dispute
9 (Informal Dispute Notice).
10 2. The Parties’ project coordinators shall then confer in an effort to resolve
11 the dispute informally. The parties shall informally confer for up to fourteen (14)
12 calendar days from receipt of the Informal Dispute Notice. If the project coordinators
13 cannot resolve the dispute within those 14 calendar days, then within seven (7) calendar
14 days Ecology’s project coordinator shallissue a written decision (Informal Dispute
15 Decision) stating: the nature o f the dispute; the Defendant’s position with regards to
16 the dispute; Ecology’s position with regards to the dispute; and the extent of resolution
17 reached by informal discussion.
18 3. Defendant may then request regional management review of the dispute.
19 This request (Formal Dispute Notice) must be submitted in writing to the Northwest
20 Region Toxics Cleanup Section Manager within seven (7) calendar days of receipt of
21 Ecology’s Informal Dispute Decision. The Formal Dispute Notice shall include a
22 written statement of dispute setting forth: the nature of the dispute; the disputing
23 Party’s position with respect to the dispute; and the information relied upon to support
24 its position.
25
26
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 4. The Section Manager shall conduct a review of the dispute and shall
2 issue a written decision regarding the dispute (Decision on Dispute) within thirty (30)
3 calendar days of receipt of the Formal Dispute Notice.
4 5. If Defendant finds Ecology’s Regional Section Manager’s decision
5 unacceptable, Defendant may then request final management review of the decision.
6 This request (Final Review Request) shall be submitted in writing to the Toxics
7 Cleanup Program Manager within seven (7) calendar days of Defendant’s receipt of the
8 Decision on Dispute. The Final Review Request shall include a written statement of
9 dispute setting forth: the nature of the dispute; the disputing Party’s position with
10 respect to the dispute; and the information relied upon to support its position.
11 6. Ecology’s Toxics Cleanup Program Manager shall conduct a reviewof
12 the dispute and shall issue a written decision regarding the dispute (Final Decision on
13 Dispute) within thirty (30) calendar days of receipt of the Final Review Request. The
14 Toxics Cleanup Program Manager’s decision shall be Ecology’s final decisionon the
15 disputed matter.
16 B. If Ecology’s Final Decision on Dispute is unacceptable to Defendant, Defendant
17 has the right to submit the dispute to the Court for resolution. The Parties agree that one judge
18 should retain jurisdiction over this case and shall, as necessary, resolve any dispute arising
19 under this Decree. In the event Defendant presents an issue to the Court for review, the Court
20 shall review the action or decision of Ecology on the basis of whether such action or decision
21 was arbitrary and capricious and render a decision based on such standard of review.
22 C. The Parties agree to only utilize the dispute resolution process in good faith and
23 agree to expedite, to the extent possible, the dispute resolution process whenever it is used.
24 Where either party utilizes the dispute resolution process in bad faith or for purposes of delay,
25 the other party may seek sanctions.
26
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 D. Implementation of these dispute resolution procedures shall not provide a basis
2 for delay of any activities required in this Decree, unless Ecology agrees in writing to a
3 schedule extension or the Court so orders.
4 E. In case of a dispute, failure to either proceed with the work required by this
5 Decree or timely invoke dispute resolution may result in Ecology’s determination that
6 insufficient progress is being made in preparation of a deliverable, and may result in Ecology
7 undertaking the work under Section XXV (Implementation of Remedial Action).
8 XV. AMENDMENT OF DECREE
9 The project coordinators may agree to minor changes to the work to be performed
10 without formally amending this Decree. Minor changes will be documented in writing by
11 Ecology.
12 Substantial changes to the work to be performed shall require formal amendment of this
13 Decree. This Decree may only be formally amended by a written stipulation among the Parties
14 that is entered by the Court, or by order of the Court. Such amendment shall become effective
15 upon entry by the Court. Agreement to amend the Decree shall not be unreasonably withheld
16 by any party.
17 Defendant shall submit a written request for amendment to Ecology for approval.
18 Ecology shall indicate its approval or disapproval in writing and in a timely manner after the
19 written request for amendment is received. If the amendment to the Decree is a substantial
20 change, Ecology will provide public notice and opportunity for comment. Reasons for the
21 disapproval of a proposed amendment to the Decree shall be stated in writing. If Ecology does
22 not agree to a proposed amendment, the disagreement may be addressed through the dispute
23 resolution procedures described in Section XIV (Resolution of Disputes).
24 XVI. EXTENSION OF SCHEDULE
25 A. An extension of schedule shall be granted only when a request for an extension
26 is submitted in a timely fashion, generally at least thirty (30) days prior to expiration of the
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 deadline for which the extension is requested, and good cause exists for granting the extension.
2 All extensions shall be requested in writing. The request shall specify:
3 1. The deadline that is sought to be extended;
4 2. The length of the extension sought;
5 3. The reason(s) for the extension; and
6 4. Any related deadline or schedule that would be affected if the extension
7 were granted.
8 B. The burden shall be on Defendant to demonstrate to the satisfaction of Ecology
9 that the request for such extension has been submitted in a timely fashion and that good cause
10 exists for granting the extension. Good cause may include, but may not be limited to:
11 1. Circumstances beyond the reasonable control and despite the due
12 diligence of Defendant including delays caused by unrelated third parties or Ecology,
13 such as (but not limited to) delays by Ecology in reviewing, approving, or modifying
14 documents submitted by Defendant;
15 2. Acts of God, including fire, flood, blizzard, extreme temperatures,
16 storm, or other unavoidable casualty; or
17 3. Endangerment as described in Section XVII (Endangerment).
18 However, neither increased costs of performance of the terms of this Decree nor
19 changed economic circumstances shall be considered circumstances beyond the reasonable
20 control of Defendant.
21 C. Ecology shall act upon any written request for extension in a timely fashion.
22 Ecology shall give Defendant written notification of any extensions granted pursuant to this
23 Decree. A requested extension shall not be effective until approved by Ecology or, if required,
24 by the Court. Unless the extension is a substantial change, it shall not be necessary to amend
25 this Decree pursuant to Section XV (Amendment of Decree) when a schedule extension is
26 granted.
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 D. An extension shall only be granted for such period of time as Ecology
2 determines is reasonable under the circumstances. Ecology may grant schedule extensions
3 exceeding ninety (90) days only as a result of:
4 1. Delays in the issuance of a necessary permit which was applied for in a
5 timely manner;
6 2. Other circumstances deemed exceptional or extraordinary by
7 Ecology; or
8 3. Endangerment as described in Section XVII (Endangerment).
9 XVII. ENDANGERMENT
10 In the event Ecology determines that any activity being performed at the Site under this
11 Decree is creating or has the potential to create a danger to human health or the environment,
12 Ecology may direct Defendant to cease such activities for such period of time as it deems
13 necessary to abate the danger. Defendant shall immediately comply with such direction.
14 In the event Defendant determines that any activity being performed at the Site under
15 this Decree is creating or has the potential to create a danger to human health or the
16 environment, Defendant may cease such activities. Defendant shall notify Ecology’s project
17 coordinator as soon as possible, but no later than twenty-four (24) hours after making such
18 determination or ceasing such activities. Upon Ecology’s direction, Defendant shall provide
19 Ecology with documentation of the basis for the determination or cessation of such activities.
20 If Ecology disagrees with Defendant’s cessation of activities, it may direct Defendant to
21 resume such activities.
22 If Ecology concurs with or orders a work stoppage pursuant to this section, Defendant’s
23 obligations with respect to the ceased activities shall be suspended until Ecology determines
24 the danger is abated, and the time for performance of such activities, as well as the time for any
25 other work dependent upon such activities, shall be extended, in accordance with Section XVI
26
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 (Extension of Schedule), for such period of time as Ecology determines is reasonable under the
2 circumstances.
3 Nothing in this Decree shall limit the authority of Ecology, its employees, agents, or
4 contractors to take or require appropriate action in the event of an emergency.
5 XVIII. COVENANT NOT TO SUE
6 A. Covenant Not to Sue: In consideration of Defendant’s compliance with the
7 terms and conditions of this Decree, Ecology covenants not to institute legal or administrative
8 actions against Defendant regarding the release or threatened release of hazardous substances
9 covered by this Decree.
10 This Decree covers only the Site specifically identified in the Site Diagram (Exhibit A)
11 and those hazardous substances that Ecology knows are located at the Site as of the date of
12 entry of this Decree. This Decree does not cover any other hazardous substance or area.
13 Ecology retains all of its authority relative to any substance or area not covered by this Decree.
14 This Covenant Not to Sue shall have no applicability whatsoever to:
15 1. Criminal liability;
16 2. Liability for damages to natural resources; and
17 3. Any Ecology action, including cost recovery, against PLPs not a party to
18 this Decree.
19 If factors not known at the time of entry of this Decree are discovered and present a
20 previously unknown threat to human health or the environment, the Court shall amend this
21 Covenant Not to Sue.
22 B. Reopeners: Ecology specifically reserves the right to institute legal or
23 administrative action against Defendant to require it to perform additional remedial actions at
24 the Site and to pursue appropriate cost recovery, pursuant to RCW 70.105D.050 under the
25 following circumstances:
26 1. Upon Defendant’s failure to meet the requirements of this Decree;
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 2. Failure of the remedial action to meet the cleanup standards identified in
2 the Cleanup Action Plan (CAP) (Exhibit B);
3 3. Upon Ecology’s determination that remedial action beyond the terms of
4 this Decree is necessary to abate an imminent and substantial endangerment to human
5 health or the environment;
6 4. Upon the availability of new information regarding factors previously
7 unknown to Ecology, including the nature or quantity of hazardous substances at the
8 Site, and Ecology’s determination, inlight of this information, that further remedial
9 action is necessary at the Site to protect human health or the environment; or
10 5. Upon Ecology’s determination that additional remedial actions are
11 necessary to achieve cleanup standards within the reasonable restoration time frame set
12 forth in the CAP.
13 C. Except in the case of an emergency, prior to instituting legal or administrative
14 action against Defendant pursuant to this section, Ecology shall provide Defendant with
15 fifteen (15) calendar days’ notice of such action.
16 XIX. CONTRIBUTION PROTECTION
17 With regard to claims for contribution against Defendant, the Parties agree that
18 Defendant is entitled to protection against claims for contribution for matters addressed in this
19 Decree as provided by RCW 70.105D.040(4)(d).
20 XX. LAND USE RESTRICTIONS
21 In consultation with Defendant, Ecology will prepare the Environmental (Restrictive)
22 Covenant consistent with WAC 173-340-440 and RCW 64.70. After approval by Ecology,
23 Defendant shall record the Environmental (Restrictive) Covenant with the office of the King
24 County Auditor within three (3) months of completion of performance monitoring. The
25 Environmental (Restrictive) Covenant shall restrict future activities and uses of the Site as
26
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 agreed to by Ecology and Defendant. Defendant shall provide Ecology with the original
2 recorded Environmental (Restrictive) Covenant within thirty (30) days of the recording date.
3 XXI. FINANCIAL ASSURANCES
4 Pursuant to WAC 173-340-440(11), Defendant shall maintain sufficient and adequate
5 financial assurance mechanisms to cover all costs associated with the operation and
6 maintenance of the remedial action at the Site, including institutional controls, compliance
7 monitoring, and corrective measures.
8 Within sixty (60) days of the effective date of this Decree, Defendant shall submit to
9 Ecology for review and approval an estimate of the costs that it will incur in carrying out the
10 terms of this Decree, including operation and maintenance, and compliance monitoring.
11 Within sixty (60) days after Ecology approves the aforementioned cost estimate, Defendant
12 shall provide proof of financial assurances sufficient to cover all such costs in a form
13 acceptable to Ecology.
14 Defendant shall adjust the financial assurance coverage and provide Ecology’s project
15 coordinator with documentation of the updated financial assurance for:
16 A. Inflation, annually, within thirty (30) days of the anniversary date of the entry of
17 this Decree; or if applicable, the modified anniversary date established in accordance with this
18 section, or if applicable, ninety (90) days after the close of Defendant’s fiscal year if the
19 financial test or corporate guarantee is used.
20 B. Changes in cost estimates, within thirty (30) days of issuance of Ecology’s
21 approval of a modification or revision to the CAP that result in increases to the cost or
22 expected duration of remedial actions. Any adjustments for inflation since the most recent
23 preceding anniversary date shall be made concurrent with adjustments for changes in cost
24 estimates. The issuance of Ecology’s approval of a revised or modified CAP will revise the
25 anniversary date established under this section to become the date of issuance of such revised
26 or modified CAP.
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 XXII. INDEMNIFICATION
2 Defendant agrees to indemnify and save and hold the State of Washington, its
3 employees, and agents harmless from any and all claims or causes of action (1) for death or
4 injuries to persons, or (2) for loss or damage to property to the extent arising from or on
5 account of acts or omissions of Defendant, its officers, employees, agents, or contractors in
6 entering into and implementing this Decree. However, Defendant shall not indemnify the State
7 of Washington nor save nor hold its employees and agents harmless from any claims or causes
8 of action to the extent arising out of the negligent acts or omissions of the State of Washington,
9 or the employees or agents of the State, in entering into or implementing this Decree.
10 XXIII. COMPLIANCE WITH APPLICABLE LAWS
11 A. All actions carried out by Defendant pursuant to this Decree shall be done in
12 accordance with all applicable federal, state, and local requirements, including requirements to
13 obtain necessary permits, except as provided in RCW 70.105D.090. The permits or other
14 federal, state, or local requirements that the agency has determined are applicable and that are
15 known at the time of entry of this Decree have been identified in the List of Applicable or
16 Relevant and Appropriate Requirements (Exhibit E).
17 B. Pursuant to RCW 70.105D.090(1), Defendant is exempt from the procedural
18 requirements of RCW 70.94, 70.95, 70.105, 77.55, 90.48, and 90.58 and of any laws requiring
19 or authorizing local government permits or approvals. However, Defendant shall comply with
20 the substantive requirements of such permits or approvals. The exempt permits or approvals
21 and the applicable substantive requirements of those permits or approvals, as they are known at
22 the time of entry of this Decree, have been identified in the List of Applicable or Relevant and
23 Appropriate Requirements (Exhibit E).
24 Defendant has a continuing obligation to determine whether additional permits or
25 approvals addressed in RCW 70.105D.090(1) would otherwise be required for the remedial
26 action under this Decree. In the event either Ecology or Defendant determines that additional
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 permits or approvals addressed in RCW 70.105D.090(1) would otherwise be required for the
2 remedial action under this Decree, it shall promptly notify the other party of this determination.
3 Ecology shall determine whether Ecology or Defendant shall be responsible to contact the
4 appropriate state and/or local agencies. If Ecology so requires, Defendant shall promptly
5 consult with the appropriate state and/or local agencies and provide Ecology with written
6 documentation from those agencies of the substantive requirements those agencies believe are
7 applicable to the remedial action. Ecology shall make the final determination on the additional
8 substantive requirements that must be met by Defendant and on how Defendant must meet
9 those requirements. Ecology shall inform Defendant in writing of these requirements. Once
10 established by Ecology, the additional requirements shall be enforceable requirements of this
11 Decree. Defendant shall not begin or continue the remedial action potentially subject to the
12 additional requirements until Ecology makes its final determination.
13 C. Pursuant to RCW 70.105D.090(2), in the event Ecology determines that the
14 exemption from complying with the procedural requirements of the laws referenced in
15 RCW 70.105D.090(1) would result in the loss of approval from a federal agency that is
16 necessary for the state to administer any federal law, the exemption shall not apply and
17 Defendant shall comply with both the procedural and substantive requirements of the laws
18 referenced in RCW 70.105D.090(1), including any requirements to obtain permits.
19 XXIV. REMEDIAL ACTION COSTS
20 Defendant shall pay to Ecology costs incurred by Ecology pursuant to this Decree and
21 consistent with WAC 173-340-550(2). These costs shall include work performed by Ecology
22 or its contractors for, or on, the Site under RCW 70.105D, including remedial actions and
23 Decree preparation, negotiation, oversight, and administration. These costs shall include work
24 performed both prior to and subsequent to the entry of this Decree. Ecology’s costs shall
25 include costs of direct activities and support costs of direct activities as defined in
26 WAC 173-340-550(2). Ecology has accumulated $10,840.09 in remedial action costs related
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 to this facility as of March 3, 2015. Payment for this amount shall be submitted within thirty
2 (30) days of the effective date of this Decree. For all costs incurred subsequent to March 3,
3 2015, Defendant shall pay the required amount within thirty (30) days of receiving from
4 Ecology an itemized statement of costs that includes a summary of costs incurred, an
5 identification of involved staff, and the amount of time spent by involved staff members on the
6 project. A general statement of work performed will be provided upon request. Itemized
7 statements shall be prepared quarterly. Pursuant to WAC 173-340-550(4), failure to pay
8 Ecology’s costs within ninety (90) days of receipt of the itemized statement of costs will result
9 in interest charges at the rate of twelve percent (12%) per annum, compounded monthly.
10 In addition to other available relief, pursuant to RCW 70.105D.055, Ecology has
11 authority to recover unreimbursed remedial action costs by filing a lien against real property
12 subject to the remedial actions.
13 XXV. IMPLEMENTATION OF REMEDIAL ACTION
14 If Ecology determines that the Defendant has failed to make sufficient progress or
15 failed to implement the remedial action, in whole or in part, Ecology may, after notice to
16 Defendant, perform any or all portions of the remedial action or at Ecology’s discretion allow
17 the Defendant opportunity to correct. The Defendant shall reimburse Ecology for the costs of
18 doing such work in accordance with Section XXIV (Remedial Action Costs).
19 Except where necessary to abate an emergency situation, Defendant shall not perform
20 any remedial actions at the Site outside those remedial actions required by this Decree, unless
21 Ecology concurs, in writing, with such additional remedial actions pursuant to Section XV
22 (Amendment of Decree).
23 XXVI. PERIODIC REVIEW
24 As remedial action, including groundwater monitoring, continues at the Site, the Parties
25 agree to review the progress of remedial action at the Site, and to review the data accumulated
26 as a result of monitoring the Site as often as is necessary and appropriate under the
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 circumstances. At least every five (5) years after the initiation of cleanup action at the Site the
2 Parties shall meet to discuss the status of the Site and the need, if any, for further remedial
3 action at the Site. At least ninety (90) days prior to each periodic review, Defendant shall
4 submit a report to Ecology that documents whether human health and the environment are
5 being protected based on the factors set forth in WAC 173-340-420(4). Under Section XVIII
6 (Covenant Not to Sue), Ecology reserves the right to require further remedial action at the Site
7 under appropriate circumstances. This provision shall remain in effect for the duration of this
8 Decree.
9 XXVII. PUBLIC PARTICIPATION
10 A Public Participation Plan is required for this Site. Ecology shall review any existing
11 Public Participation Plan to determine its continued appropriateness and whether it requires
12 amendment, or if no plan exists, Ecology shall develop a Public Participation Plan alone or in
13 conjunction with Defendant.
14 Ecology shall maintain the responsibility for public participation at the Site. However,
15 Defendant shall cooperate with Ecology, and shall:
16 A. If agreed to by Ecology, develop appropriate mailing lists, prepare drafts of
17 public notices and fact sheets at important stages of the remedial action, such as the submission
18 of work plans, remedial investigation/feasibility study reports, cleanup action plans, and
19 engineering design reports. As appropriate, Ecology will edit, finalize, and distribute such fact
20 sheets and prepare and distribute public notices of Ecology’s presentations and meetings.
21 B. Notify Ecology’s project coordinator prior to the preparation of all press
22 releases and fact sheets, and before major meetings with the interested public and local
23 governments. Likewise, Ecology shall notify Defendant prior to the issuance of all press
24 releases and fact sheets, and before major meetings with the interested public and local
25 governments. For all press releases, fact sheets, meetings, and other outreach efforts by
26 Defendant that do not receive prior Ecology approval, Defendant shall clearly indicate to its
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 audience that the press release, fact sheet, meeting, or other outreach effort was not sponsored
2 or endorsed by Ecology.
3 C. When requested by Ecology, participate in public presentations on the progress
4 of the remedial action at the Site. Participation may be through attendance at public meetings
5 to assist in answering questions, or as a presenter.
6 D. When requested by Ecology, arrange and/or continue information repositories at
7 the following locations:
8 1. Seattle Public Library
Beacon Hill Branch
9 2821 Beacon Avenue South
Seattle, WA 98144
10
2. Ecology’s Northwest Regional Office
11 3190 160th Avenue SE
Bellevue, WA 98008
12
At a minimum, copies of all public notices, fact sheets, and documents relating to public
13
comment periods shall be promptly placed in these repositories. A copy of all documents
14
related to this Site shall be maintained in the repository at Ecology’s Northwest Regional
15
Office in Bellevue, Washington.
16
XXVIII. DURATION OF DECREE
17
The remedial program required pursuant to this Decree shall be maintained and
18
continued until Defendant has received written notification from Ecology that the requirements
19
of this Decree have been satisfactorily completed. This Decree shall remain in effect until
20
dismissed by the Court. When dismissed, Section XVIII (Covenant Not to Sue) and
21
Section XIX (Contribution Protection) shall survive.
22
XXIX. CLAIMS AGAINST THE STATE
23
Defendant hereby agrees that it will not seek to recover any costs accrued in
24
implementing the remedial action required by this Decree from the State of Washington or any
25
of its agencies; and further, that Defendant will make no claim against the State Toxics Control
26
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
1 Account or any local Toxics Control Account for any costs incurred in implementing this
2 Decree. Except as provided above, however, Defendant expressly reserves its right to seek to
3 recover any costs incurred in implementing this Decree from any other PLP. This section does
4 not limit or address funding that may be provided under WAC 173-322.
5 XXX. EFFECTIVE DATE
6 This Decree is effective upon the date it is entered by the Court.
7 XXXI. WITHDRAWAL OF CONSENT
8 If the Court withholds or withdraws its consent to this Decree, it shall be null and void
9 at the option of any party and the accompanying Complaint shall be dismissed without costs
10 and without prejudice. In such an event, no party shall be bound by the requirements of this
11 I Decree.
12 STATE OF WASHINGTON T W.
DEPARTMENT OF ECOLOGY
13 e
14
James J. Pendowski, Program Manager Nels Johns BA #28616
15 Toxics Cleanup Program Assistant tt rney General
(360) 407-7177 (360) 586- 14
16
Date: S Date: 21-2117
17 -
18 PORT OF SEATTLE
19
/' 0""'A /" -~
20 David Soike
Interim Chief Executive Officer
21 (206) 728-3000
22 Date:
23
ENTERED this day of 2017.
24
25
26 JUDGE, King County Superior Court
CONSENT DECREE 26 ATTORNEY GENERAL OF WASHINGTON
Ecology Division
PO Box 40117
Olympia, WA 98504-0117
(360) 586-6770
King County Superior Court
Judicial Electronic Signature Page
Case Number: 17-2-19080-2
Case Title: Not available at this time
Document Title: DECREE
Signed by: Catherine Shaffer
Date: 7/19/2017 12:19:45 PM
Judge/Commissioner: Catherine Shaffer
This document is signed in accordance with the provisions in GR 30.
Certificate Hash: 02A0B1FE28017BAC78E9BF6CE00C462718609D94
Certificate effective date: 7/29/2013 11:40:17 AM
Certificate expiry date: 7/29/2018 11:40:17 AM
Certificate Issued by: C=US, E=kcscefiling@kingcounty.gov, OU=KCDJA,
O=KCDJA, CN="Catherine
Shaffer:PCh7R3n44hGZOTo3YYhwmw=="
Page 27 of 27
100 Gate House Feet 0 West Vault Soil Area ! A North ([KLELW $ Site Layout Port of Seattle Terminal 30 MW-90 ! A MW-76A Substation
Slip 36
MW-87A MW-91 ! A Jack Perry Park US Coast Guard MW-87B ! A ! A MW-52A ! A MW-92 ! A ! A MW-49 MW-89
T30
MW-42 ! A ! A T18
! A ! A MW-86B MW-86C MW-54 ! A East Waterway Pier 28 ! A
Alaska Way Viaduct
Slip 27
RW-5A
Pier 27 ! A ! A MW-38 MW-77 1,000
MW-58A ! A MW-39 ! A RW-1 ! A T25 Feet 0
MW-85A T30 Vessel To w e r RW-9 ! A e ! ! A a c A te F MW-85B MW-36 ! A RW-11A ! A o to h
c re o p Scales o n East Marginal Way S rth
o f C ! A S O East Waterway e d g MW-46 ! A S G U E South Vault Soil Area MW-35 Truck K
1 2 2 0
! ! A A MW-84B
MW-59
MW-45 ! A ! A ! A ! A MW-64 Port of Seattle RW-12 Police Office MW-84A MW-88 ! A MW-81A ! A Truck Scales Gaging/Recovery Well Water Quality Monitoring Well Conditional Point of Compliance T-30 Site Boundary Soil Areas Not Associated with T-30 w Sheet Pile Wall Center Line N e ite S ! A ! A ( (CPOC) Wells
12/3/2015 K:\PONY\T30\GIS\mxds\SiteLayout_2015.mxd
CLEANUP ACTION PLAN
PORT OF SEATTLE TERMINAL 30
December 15, 2015
CLEANUP ACTION PLAN
PORT OF SEATTLE TERMINAL 30
Prepared by:
Washington State Department of Ecology
December 15, 2015
TABLE OF CONTENTS
1.0 INTRODUCTION ............................................................................................. 1
1.1 General Facility Information ............................................................................................ 1
1.2 Background ...................................................................................................................... 2
1.3 Site Description ................................................................................................................ 2
1.3.1 Current Operations .................................................................................................. 3
1.3.2 Potential Future Development ................................................................................. 3
1.3.3 Roads and Utilities Infrastructure ........................................................................... 3
1.3.4 Site Access ................................................................................................................ 3
1.4 Hydrogeologic Setting ..................................................................................................... 4
1.5 Contaminants of Concern................................................................................................. 5
1.6 Points of Compliance ....................................................................................................... 6
1.7 Cleanup Levels ................................................................................................................. 6
1.7.1 Soil ........................................................................................................................... 6
1.7.2 Groundwater ............................................................................................................ 6
1.7.3 LNAPL ...................................................................................................................... 6
1.8 Remediation Levels ......................................................................................................... 6
1.9 Nature and Extent of Contamination ............................................................................... 7
1.9.1 Soil ........................................................................................................................... 7
1.9.2 Groundwater ............................................................................................................ 8
1.9.3 LNAPL ...................................................................................................................... 8
2.0 CONSIDERED ALTERNATIVES ......................................................................... 8
3.0 SELECTED CLEANUP ACTIONS ....................................................................... 8
3.1 AS/SVE System ............................................................................................................... 9
3.1.1 System Configuration ............................................................................................. 10
3.1.2 Phase 1 AS/SVE Configuration .............................................................................. 10
3.1.3 Phase 2 AS/SVE Configuration .............................................................................. 11
3.1.4 System Operation ................................................................................................... 11
3.1.5 Vapor Treatment .................................................................................................... 12
3.1.6 Operation Criteria ................................................................................................. 12
3.2 LNAPL Recovery .......................................................................................................... 13
3.2.1 Conceptual Model for System Operation ............................................................... 13
3.2.2 Recovery Well Design ............................................................................................ 14
3.2.3 Vacuum-Enhanced Recovery ................................................................................. 15
3.2.4 LNAPL Recovery Termination ............................................................................... 16
3.2.5 Recovery Documentation ....................................................................................... 16
3.2.6 Phase II AS/SVE System Installation ..................................................................... 17
4.0 MONITORING .............................................................................................. 17
4.1.1 LNAPL Monitoring ................................................................................................ 18
4.1.2 CPOC Groundwater Monitoring ........................................................................... 18
i
Port of Seattle Terminal 30 Cleanup Action Plan
4.1.3 Performance Groundwater Monitoring ................................................................. 19
4.1.4 Interior Groundwater Monitoring ......................................................................... 19
4.1.5 Schedule ................................................................................................................. 19
4.2 Institutional Controls ..................................................................................................... 20
4.3 Contaminated Material Left On-Site .............................................................................. 20
5.0 SCHEDULE ................................................................................................. 21
5.1 Engineering Design Report ............................................................................................ 21
5.2 AS/SVE .......................................................................................................................... 21
5.3 LNAPL Recovery .......................................................................................................... 22
5.4 Groundwater Monitoring ............................................................................................... 22
6.0 CONTINGENCY ACTIONS .............................................................................. 22
6.1 Contingency Action Evaluation ..................................................................................... 22
6.1.1 Unrecognized Environmental Condition................................................................ 23
6.1.2 Change in Site Conditions ...................................................................................... 23
6.1.3 Concentrations Above Cleanup Levels .................................................................. 24
6.1.4 Remedial Action Progress ...................................................................................... 24
6.2 Contingency Action Process .......................................................................................... 24
6.3 Contingency Action Schedule ........................................................................................ 25
7.0 REFERENCES ............................................................................................. 26
ii
Port of Seattle Terminal 30 Cleanup Action Plan
TABLES
Table 1-1: Soil Cleanup Levels
Table 1-2: Groundwater Cleanup Levels
Table 1-3: Groundwater Remediation Levels
Table 1-4: Select Groundwater Monitoring Data
Table 3-1: Groundwater Monitoring Schedule
FIGURES
Figure 1-1: Site Vicinity
Figure 1-2: Site Layout
Figure 1-3: Site Underground Utilities
Figure 1-4: Extent of Contamination
Figure 3-1: Cleanup Action Components
Figure 3-2: AS/SVE Subsurface Components
Figure 3-3: LNAPL Extraction Well Details
Figure 6-1: Contingency Action Decision Framework
Figure 6-2: Contingency Action Process
APPENDICES
Appendix A Supporting LNAPL Information
iii
Port of Seattle Terminal 30 Cleanup Action Plan
1.0 INTRODUCTION
This Cleanup Action Plan (CAP) describes the cleanup action selected by the
Washington State Department of Ecology (Ecology) for Terminal 30 (T30) Site.
The Site is generally located at 1901 East Marginal Way South, Seattle,
Washington, approximately one mile southwest of downtown Seattle, in King
County, Washington on the shoreline of the East Waterway.
This CAP was developed using information presented in the Remedial
Investigation/Feasibility Study (RI/FS) for the Site, which was prepared by
Pacific Groundwater Group (PGG) in 2013 on behalf of the Port of Seattle (Port)
in accordance with the Agreed Order (AO) entered between Ecology and Port in
1991.
The CAP:
• presents selected cleanup alternatives
• presents site cleanup standards and remediation levels
• provides the schedule to implement the cleanup action
The T30 Site is being cleaned up under the authority of Model Toxics Control Act
Chapter 70.105D of the Revised Code of Washington (RCW), and the Model
Toxics Control Act (MTCA) Cleanup Regulation, Chapter 173-340 of the
Washington Administrative Code (WAC).
1.1 GENERAL FACILITY INFORMATION
The location and layout of T30 are presented in Figures 1-1 and 1-2.
Site Name: Port of Seattle Terminal 30
Facility Site ID: 2055
Site Address: 1901 East Marginal Way South, Seattle, Washington
Parcel Number: 7666207830
Current Owner: Port of Seattle, Roy Kuroiwa Project Manager
Current Operator: SSA Marine (Port of Seattle Tenant)
Project Consultant: Pacific Groundwater Group, Janet Knox Project Manager
2377 Eastlake Avenue East, Seattle WA 98102
206-329-0141
1
Port of Seattle Terminal 30 Cleanup Action Plan
1.2 BACKGROUND
A Chevron Bulk fuel terminal occupied a portion of the T30 site since 1905. The
Chevron bulk fuel terminal consisted of above-ground fuel storage tanks and
associated piping and equipment. The Port purchased the T30 Site from Chevron
on January 2, 1985. The fuel terminal was demolished between December 1984
and about November 1985. The Port redeveloped the 33.9 acres Terminal 30 as a
container facility
The Port of Seattle (Port) and Ecology entered into an Agreed Order (AO) for
cleanup at T30 in 1991, which was amended in 2013 to include preparation of this
CAP.
As required by the 1991 AO, a draft Remedial Investigation/Feasibility Study
(RI/FS) was developed in 1998 by GeoEngineers (1998 RI/FS) to document the
nature and extent of contamination and to evaluate remedial alternatives. The
draft RI/FS was not approved by Ecology.
A product recovery system was installed in the early 1990s that removed more
than 171,000 gallons of product. As part of the redevelopment in 2007, a sitewide
asphalt cover was constructed and more than 24,000 cubic yards of
petroleum-impacted soil was disposed of offsite. However, substantial petroleum
product remains in the soil and groundwater at the Site.
A final remedial investigation/feasibility study (RI/FS) was prepared by Pacific
Groundwater Group (PGG) in 2013 to update the status of petroleum
contamination at the site, to evaluate final remedial actions, and to fulfill the
requirements of the 1991 AO.
1.3 SITE DESCRIPTION
T30 is located approximately one mile southwest of downtown Seattle, in King
County, Washington on the shoreline of the Duwamish River East Waterway
(Figure 1-1). The 2013 RI/FS and this CAP focus on approximately 11 acres in
the northern portion of the larger 33.9 acre T30 property. The term “T30 site” or
“site” refers to the extent of petroleum contamination in the northern portion of
T30, inclusive of light non-aqueous phase liquid (LNAPL), soil, and groundwater
contamination; the site boundary is shown in Figure 1-2. Soil contamination
located at the West Vault and South Vault are from separate sources, and are not
considered part of the Terminal 30 site.
The T30 site is bordered on the north by an area of public shoreline access to the
East Waterway, on the east by East Marginal Way South, on the south by the
southern portion of T30, and on the west by the East Waterway. The East
Waterway is an operable unit of the Harbor Island Superfund Site as ordered by
the U.S. Environmental Protection Agency (EPA).
2
Port of Seattle Terminal 30 Cleanup Action Plan
1.3.1 Current Operations
T30 and the contiguous Terminal 25 to the south are currently operated as a 70-
acre container storage and transfer facility by the Port’s tenant SSA Marine, who
is leasing the facility through 2023. Containerized freight is transferred between
ships, trucks, and temporary terminal storage using a series of rail-mounted
overhead cranes and forklifts. Activities are directed from the Vessel Tower and
Gate House. The Vessel Tower is within the T30 site, while the Gate House is not
(Figure 1-2). The T30 site is entirely paved with asphalt; runoff is controlled by a
stormwater management system operated and maintained by SSA Marine
(Figures 1-2 and 1-3).
1.3.2 Potential Future Development
The Port anticipates continued and long-term ownership of T30 and long-term use
as a container facility. The Port has no plans to redevelop this property for
alternate use.
1.3.3 Roads and Utilities Infrastructure
Vehicle access to T30 is directly from East Marginal Way and is controlled at the
security Gate House. The City of Seattle provides water, electricity, and sanitary
sewer service to T30. Stormwater runoff is managed by SSA Marine using best
management practices. The stormwater management system treats runoff with
oil/water separators and filtration media prior to discharge at outfalls to the East
Waterway. Two of these outfalls, Hanford and Lander, enter the East Waterway
south (upstream) of the site.
Utilities on the T30 site have been modified many times with varying levels of
documentation. Most recently, additional subsurface utilities including electrical,
sanitary sewer, and water were installed during the 2007-2009 container terminal
construction (ENSR|AECOM 2010). Underground utilities documented in Port
and Seattle Public Utility files are presented in Figure 1-3; additional abandoned
or undocumented subsurface utility infrastructure may be present on the site.
1.3.4 Site Access
The site is accessed via the Main Gate on East Marginal Way. Site entry is
managed at a staffed gate house at the Main Gate. A Transportation Worker
Identification Card (TWIC) is required for access to the site to meet Department
of Homeland Security regulations for access to marine port facilities. Site access
must be arranged in advance with the Port of Seattle and the site tenant, which is
currently SSA Terminals. Tenant contact information will be provided by the Port
of Seattle as needed.
3
Port of Seattle Terminal 30 Cleanup Action Plan
1.4 HYDROGEOLOGIC SETTING
Two stratigraphic units have been identified at the T30 site: fill and native
deposits. Fill was derived at least in part from dredging and can be difficult to
physically differentiate from similar native tidal flat and alluvial deposits
(GeoEngineers, 1998). Key characteristics of these units include:
• Fill Unit—consists of sand and gravel with varying amounts of silt,
wood, bricks, and construction debris; the unit thickens and dips
westward toward the East Waterway (GeoEngineers, 1998). Fill units
identified in the 1998 RI/FS by GeoEngineers were described as
“laterally discontinuous” with a lower contact approximately 15 to 20
ft below ground surface (bgs) or the approximate historic MLLW tide
line. Most of the fill materials tested for grain size distribution were
classified as well-sorted sands and less commonly as sandy gravels,
silty sand, and silts. During construction of the T30 facility in 1984-
1985, additional fill for an engineered slope was placed after dredging
operations were completed. This fill included sand with a surface layer
of rip-rap extending to the base of the East Waterway.
• Native Deposits—consist of non-glacial, fluvial and estuarine, black,
fine-to-medium sand with varying amounts of silt. Shell fragments and
occasional organic materials were frequently observed in the native
deposits.
Native soils and overlying fill comprise a shallow water table aquifer at the T30
site. Average depth to water ranges from 8 to 14 feet across the site. Recharge to
the water table aquifer originates as precipitation in uplands and unpaved areas
offsite; insignificant recharge originates at the T30 site due to the asphalt cover
and the stormwater management system.
In the Duwamish Valley groundwater moves from upland recharge zones
downgradient to Duwamish Waterway discharge zones. Groundwater at the T30
site generally flows toward the East Waterway, although discharge to the
waterway is strongly influenced by tidal fluctuations and man-made structures.
The average hydraulic gradient across the site is 0.0028 ft/ft with a slight increase
near the sheet pile wall (Figure 1-2). Groundwater contours curve slightly
northeast at the north end of the sheet pile wall, which is consistent with increased
discharge around the end of the sheet pile wall. As tides rise and fall, flow
between the East Waterway and the aquifer reverses in a tidal mixing zone that is
relatively narrow; however, the zone of tidal influence on groundwater gradients
is significantly wider.
Hydraulic conductivity of the shallow aquifer at the T30 site has been estimated
based on tidal studies and grain size analysis (GeoEngineers, 1998). Estimates
based on grain size analyses range from 0.02 to 0.1 cm/s (57 to 284 ft/day).
4
Port of Seattle Terminal 30 Cleanup Action Plan
Estimates based on tidal studies range from 0.2 to 9 cm/s (567 to 25,500 ft/day)
and likely overestimate the hydraulic conductivity of the aquifer given the native
and fill lithologies observed at the T30 site. The higher tidal study estimates are
typical hydraulic conductivities for clean gravels not for silty sands, which are
observed in most borings at the site.
Additional discussion of the T30 hydrogeologic setting and tidal influence are
included the RIFS (PGG, 2013b).
1.5 CONTAMINANTS OF CONCERN
The contaminants of concern (COC) in soil and groundwater include:
Petroleum Hydrocarbons
• Diesel-Range Organics
• Gasoline-Range Organics
• Oil-Range Organics
• BTEX: Benzene, Toluene, Ethylbenzene, Xylenes (total)
Semi-Volatile Organic Compounds
• 2-methylnapthalene
Polynuclear Aromatic Hydrocarbons (PAHs)
• Acenaphthene
• Acenaphthylene
• Anthracene
• Benzo(a)anthracene
• Benzo(a)pyrene
• Benzo(b)fluoranthene
• Benzo(g,h,i)perylene
• Benzo(k)fluoranthene
• Chrysene
• Dibenzo(a,h)anthracene
• Fluoranthene
• Fluorene
• Indeno(1,2,3-cd)pyrene
• Naphthalene
• Phenanthrene
• Pyrene
5
Port of Seattle Terminal 30 Cleanup Action Plan
1.6 POINTS OF COMPLIANCE
For soil at the T30 site, the point of compliance extends through the soil profile to
a depth of 15 feet for the direct contact exposure pathway.
The standard MTCA groundwater point of compliance is groundwater throughout
the site. For the T30 site, a conditional point of compliance (CPOC) for
groundwater is selected to be located as close as practical to the source of the
petroleum sheen area and LNAPL area. Monitoring wells MW-45, MW-46, MW-
58A, MW-89, and MW-92 (Figure 1-2), located at the edge of tidal flushing and
between the sheen and LNAPL area and surface water receptors, are selected as
compliance monitoring wells.
1.7 CLEANUP LEVELS
Soil and groundwater cleanup levels are listed in Tables 1-1 and 1-2.
1.7.1 Soil
Soil cleanup levels in Table 1-1, applied to the T30 site, are MTCA Method A
values for industrial land use or soil leaching to groundwater protective of surface
water values.
1.7.2 Groundwater
The groundwater cleanup levels in Table 1-2 are surface water criteria for marine
water. The marine surface water criteria are applicable for groundwater at the T30
site because groundwater discharges to the East Waterway.
Surface water criteria are not established for diesel-, heavy oil-, and gasolinerange
organics, and total xylenes. Therefore, MTCA Method A groundwater
criteria were selected for those parameters.
1.7.3 LNAPL
Measurable thickness of LNAPL in monitoring wells will be considered an
exceedance of WAC 173-340-747(10) regardless of groundwater concentrations
in samples collected from the well. A measurable thickness is 0.01-feet, the
practical measurement limit with an interface probe. The presence of sheen will
not be considered an exceedance of the LNAPL criteria.
1.8 REMEDIATION LEVELS
Remediation levels will be used to track remediation progress in non-CPOC
wells. Remediation levels are developed for a subset of COCs that are indicative
6
Port of Seattle Terminal 30 Cleanup Action Plan
of TPH abundance, including: benzene, toluene, ethylbenzene, xylenes (BTEX);
diesel range organics; and gasoline range organics. Remediation levels are used to
demonstrate reduction in petroleum compound contaminant mass in the sheen
area. In this context, remediation levels are a concentration reduction target for
operation of the AS/SVE system, and are not a maximum concentration for
compliance at performance monitoring wells. Remediation levels (RELs) in Table
1-3 are the maximum of either:
• 75% of the estimated solubility limit or
• twice the cleanup level
The composition of petroleum varies across the T30 site with variable amounts of
weathered gasoline and diesel. The equilibrium concentrations of T30’s COCs
depend on soil and groundwater concentrations and on the petroleum mixtures in
that part of the site. As shown in Table 1-3, the solubilities of individual
compounds in equilibrium with different petroleum mixtures vary significantly.
Therefore, a conservative EPA reference mixture is used to estimate effective
solubilities rather than attempting to develop well-specific effective solubilities or
one “T30 Product” effective solubility.
The solubility limit is estimated based on equilibration with an EPA 1994 Diesel
Fuel Oil reference petroleum mixture. The use of 75% of the solubility is based
on the assumption that petroleum at the site is primarily sorbed mass rather than
residual saturation when groundwater concentrations are 75% of solubility
groundwater concentrations.
Toluene, ethylbenzene and xylenes have cleanup levels above their respective
effective solubilities and are not detected above cleanup levels in current
groundwater data (see Table 1-4 and T30 RI/FS Table 2-4; PGG, 2013). For these
compounds, the remediation level is set at twice the cleanup level. For benzene,
the 75% effective solubility and twice the cleanup level criteria are nearly
equivalent. Diesel and gasoline remediation levels are set as 75% of the total
BTEX effective solubility. Achieving these remediation levels will indicate a
significant reduction in sheen area contaminant mass to residual sorbed levels.
1.9 NATURE AND EXTENT OF CONTAMINATION
The nature and extent of contamination are described in the Terminal 30 RI/FS
(PGG, 2013). For context, this section briefly describes petroleum contamination
at the site pertaining to cleanup action components (Figure 1-4).
1.9.1 Soil
The extent of soil contamination is similar to the maximum historical extent of
LNAPL with exceedances of cleanup levels for diesel-, oil- and gasoline-range
7
Port of Seattle Terminal 30 Cleanup Action Plan
hydrocarbons, and toluene. The extent of soil contamination is shown of Figure 1-
4. Please refer to the T30 RI/FS for additional information (PGG, 2013).
1.9.2 Groundwater
Groundwater at the site has exceedances of cleanup levels for benzene, PAHs, and
diesel-, oil-, and gasoline-range hydrocarbons. The most recent BTEX, diesel, and
gasoline data at wells are shown on Figure 1-4, and data are summarized in Table
1-4.
There are no exceedances of cleanup levels at the CPOC in the most recent
monitoring data from CPOC wells (Figure 1-4, Table 1-4).
1.9.3 LNAPL
Light non-aqueous phase liquid (LNAPL) is present in measureable quantities at
MW-59. Measured product thicknesses range up to 1.3 feet at MW-59 (PGG,
2013).
2.0 CONSIDERED ALTERNATIVES
The 2013 RI/FS considered five remedial alternatives for the T30 site:
• Alternative 1: In-Situ Thermal Desorption
• Alternative 2: Expanded Sheen-Area AS/SVE with Targeted Excavation
• Alternative 3a: Sheen-Area AS/SVE Treatment with LNAPL Recovery
• Alternative 3b: Sheen-Area AS/SVE Treatment with LNAPL Recovery
(Expanded Area)
• Alternative 4: Compliance Monitoring with LNAPL Recovery
All remedial alternatives included groundwater monitoring and institutional
controls. Additional details for each of the considered alternatives are included in
the T30 RI/FS (PGG, 2013a).
Alternative 3a was selected as the preferred alternative through a disproportionate
cost analysis and is the cleanup action described in this CAP. As described in
Section 3.1, some changes have been made to optimize the remedy. The cleanup
actions for the Site were selected in accordance with and comply with the
requirements of WAC 173-340-360, Selection of Cleanup Actions.
3.0 SELECTED CLEANUP ACTIONS
Selected cleanup actions at the T30 site will include air sparging/soil vapor
extraction (AS/SVE) treatment, LNAPL recovery, long-term compliance
8
Port of Seattle Terminal 30 Cleanup Action Plan
monitoring, and institutional controls. These actions are intended to address
specific cleanup goals, including:
• Protect human health and the environment
• Maintain cleanup levels at the conditional point of compliance
(CPOC) for protection of surface water
• Reduce Light Non-Aqueous Phase Liquid (LNAPL) thickness near
MW-59 to sheen
• Reduce contaminant mass in the sheen area
AS/SVE will reduce groundwater concentrations in the portion of the sheen area
between MW-42 and MW-36 (Figure 3-1). LNAPL recovery will address the last
remaining area with free product at the water table near MW-59. A later phase of
AS/SVE will reduce contaminant mass in the MW-59 area after product thickness
has been reduced to sheen. In addition, natural attenuation processes will reduce
groundwater concentrations across the site. Institutional controls will prevent
contact with subsurface soil and groundwater contamination by maintaining the
asphalt cap as a protective barrier and by establishing procedures that prevent
exposure below the asphalt cap without appropriate health and safety procedures
and Ecology notification.
Targeted groundwater monitoring will confirm compliance with cleanup levels at
the CPOC, track performance of the AS/SVE system, and document concentration
trends in the interior of the site. Details of the cleanup action components are
described in the following sections.
3.1 AS/SVE SYSTEM
The purpose of the AS/SVE system is to reduce contaminant mass in the sheen
area. The AS/SVE system is not intended to reduce CPOC concentrations;
concentrations are currently below cleanup levels at the CPOC. The AS/SVE
system will extend from near MW-42 to MW-36 (Figure 3-1), bounded on the
north by the extent of groundwater exceedances and on the south by the edge of
the LNAPL area. The AS/SVE will extend into the LNAPL area once the LNAPL
thickness is reduced to sheen as sparging could increase LNAPL migration.
AS/SVE will reduce contaminant mass in the sheen area to address primarily
gasoline-range organics (Figures 3-1 and 3-2). Contaminant mass reduction will
be achieved through a combination of direct extraction of volatile-phase
petroleum compounds within the SVE radius of influence and biostimulation in
the area downgradient of the AS/SVE system. The AS/SVE system is not
expected to reduce contaminant mass upgradient of the sparge well radius of
influence (nominally 20 feet).
9
Port of Seattle Terminal 30 Cleanup Action Plan
3.1.1 System Configuration
The AS/SVE system will be operated in two arrays (Figure 3-1):
• Phase 1 array extending from near MW-36 north to near MW-42
• Phase 2 array extending from near MW-36 to near MW-59
Phase 2 will be implemented after LNAPL in the area near MW-59 has been
reduced to sheen. Sparging in this area before LNAPL is reduced to sheen could
result in LNAPL mobilization. AS/SVE distribution piping for Phase 2 will be
installed during Phase 1 construction, but SVE trenching and sparge wells will not
be installed until LNAPL has been reduced to sheen.
The AS/SVE system has been modified from the layout presented in the 2013
RI/FS based on subsequently collected soil and groundwater quality and further
communications with Ecology (PGG, 2013a; 2013b; 2014).
3.1.2 Phase 1 AS/SVE Configuration
The Phase 1 AS/SVE system will include 14 air sparge wells, soil vapor
extraction piping in distribution trenches, an equipment shed, and trenching to
connect the system components to the equipment shed (Figure 3-1). The location
of the equipment shed and other infrastructure will be established in the
Engineering Design Report based on evaluation of site operations, electrical
infrastructure, and underground utilities. The location of the equipment shed will
not substantially influence the operation of the system. Air sparge (AS) wells will
be constructed with 2-inch PVC riser pipe and screens 12- to 14-feet below the
water table or approximately 21- to 23-feet below ground surface (Figure 3-2).
Compressed air will be delivered to groups of AS wells (sparge zones) through 2-
inch, horizontal PVC or HDPE pipes running below ground surface from a
distribution manifold in the equipment shed. Each AS wellhead will be
instrumented with a pressure gauge and valve to allow adjustment of air sparge
rates at each sparge well.
Soil vapor extraction will include a horizontal 4-inch slotted pipe set
approximately 4 to 5 feet below ground surface in trenches parallel to AS well
alignments (Figures 3-1 and 3-2).
The air sparge compressor, soil vapor extraction blower, and exhaust gas
treatment/filtering equipment will be housed in an on-site equipment shed just
north of monitoring well MW-87A at the approximate location shown on Figure
3-1. The location of the equipment shed may be revised to accommodate tenant
terminal operations or to facilitate connection to electrical infrastructure.
Equipment location and utility infrastructure details will be refined in the
Engineering Design Report, but will not alter the in-situ function of the AS/SVE
system.
10
Port of Seattle Terminal 30 Cleanup Action Plan
3.1.3 Phase 2 AS/SVE Configuration
The Phase 2 AS/SVE system will include 6 air sparge wells and soil vapor
extraction piping in the distribution trenches. The system will connect to
distribution piping near MW-36 installed during Phase 1 construction (Figure 3-
1). Phase 2 AS/SVE wells and extraction lines will be operated from equipment in
the equipment shed established during Phase 1.
3.1.4 System Operation
The 14 Phase 1 air sparge wells will be operated in three zones. Zones will
initially be sparged sequentially with 30-minutes on and 60-minutes off to allow
sparging-induced air channels to close between sparge cycles; sparge cycling may
be adjusted based on operational data. The duration of sparging and recovery is
based on empirical observations at other AS/SVE systems and run times may be
further optimized based on pressure trends observed during system startup and
operation. Phase 1 sparge zones will include (Figure 3-1):
• Zone 1: AS-1 through AS-5
• Zone 2: AS-6 through AS-9
• Zone 3: AS-10 through AS-14
Phase 2 sparge zones will be operated as separate zones after installation. Phase 2
sparge zones will include (Figure 3-1):
• Zone 4: AS-15 through AS-17
• Zone 5: AS-18 through AS-20
Figure 3-1 shows conceptual Phase 2 locations. Actual Phase 2 locations will be
proposed based on the improved understanding of subsurface contamination and
air-flow from several years of Phase 1 AS/SVE operation and the LNAPL
recovery operations. The proposed Phase 2 design will be provided to Ecology for
approval prior to implementation.
Each sparge zone will have a cumulative air flow of 40-60 standard cubic feet per
minute (scfm). Each zone will be supplied air from a central manifold at the air
compressor in the equipment enclosure. Pressure drop between the compressor
and wellheads is estimated to be less than 2 pounds per square inch (psi) assuming
17 psi at the wellhead, 60 scfm flow rate, and 500 feet of 2-inch distribution pipe.
The air sparge system will be operated at wellhead pressures of approximately 15
psi. With screens located at 12 to 14 feet below the water table, approximately 5.2
to 6 psi will be required to displace water from the well to the screen interval. The
remaining pressure will overcome capillary forces in the aquifer and force air into
the formation. Each well will be sparged at 10 to 20 scfm.
11
Port of Seattle Terminal 30 Cleanup Action Plan
The SVE system will withdraw a minimum of twice the sparge air quantity to
control vapor migration from the treatment area. For example, if the AS system
delivers 50 scfm, the SVE system will extract a minimum of 100 scfm. A vacuum
blower installed in the equipment shed will draw the extracted vapors into
treatment (Section 3.1.3). The onsite stormwater system is the primary
accumulation point for vapors that may migrate away from the AS/SVE system.
Air spaces in the adjacent stormwater system will be checked for accumulated
vapors with a PID during system startup when the potential for elevated vapor
concentrations is greatest. The AS and SVE flow rates will be adjusted if vapors
above acceptable limits are detected in the stormwater system; monitoring criteria
will be specified in the EDR.
3.1.5 Vapor Treatment
Exhaust vapors from the SVE system will require treatment prior to discharge
because of elevated volatiles. Initial vapor concentrations are likely to exceed
1,000 parts per million by volume (ppmV), above which thermal oxidation is
generally the most cost-effective treatment technology. Thermal oxidation air
treatment uses either a catalytic oxidizer or propane flame to combust volatileladen
exhaust vapors; thermal oxidizers typically achieve approximately 99%
reduction in VOC concentrations. SVE exhaust vapor concentrations will be
periodically monitored in the airstream before treatment to estimate mass loss
from the SVE system. The system will be transitioned to carbon filtration as
concentrations decrease to below 1,000 ppmV. Exhaust treatment equipment will
be specified in the EDR.
Soil vapor extraction discharge concentrations will likely require a permit from
the Puget Sound Clean Air Authority (PSCAA) as a condition of operation. The
permit may require additional vapor concentration monitoring unrelated to
achieving remedial objectives.
3.1.6 Operation Criteria
The AS/SVE system will be operated in the following progression:
• Operate system until groundwater concentrations at performance wells
MW-36, MW-39, MW-42, and RW-9 achieve remediation levels
(Table 1-3).
• Collect SVE exhaust vapor field photoionization detector (PID)
measurements during routine system operations and maintenance visits
to estimate mass removal rate, coupled with the SVE flow rate.
• Cycle the AS/SVE system on as concentrations rebound at MW-36,
MW-39, MW-42, and RW-9. Rebound from upgradient groundwater
influx is anticipated to occur over a 3- to 9-month timeframe.
12
Port of Seattle Terminal 30 Cleanup Action Plan
• Discontinue AS/SVE on-off cycling when the system is no longer
significantly reducing contaminant mass in the sheen area, or
remediation levels are maintained. Rebound concentrations may
exceed remediation levels for some constituents even once the
AS/SVE is no longer significantly reducing contaminant mass because
of the proximity of performance wells to the upgradient edge of the
treatment area. If the system is no longer effectively removing
contaminant mass beyond the contaminant mass influx from
upgradient, then AS/SVE cycling will be discontinued even if rebound
exceeds remediation levels. Efficiency of mass removal will be
evaluated from AS/SVE system operational data and groundwater data
from performance monitoring wells. With Ecology approval, the
AS/SVE system may be decommissioned at this time.
• Operational criteria for Phase 1 and Phase 2 of the AS/SVE system
may be met and/or evaluated independently.
The AS wells will be decommissioned in accordance with WAC 173-160.
3.2 LNAPL RECOVERY
The area with remaining free-product is in an active portion of the shipping
terminal operations, with most of the area between the rubber tire gantry runways
(Figure 3-1). Vacuum-enhanced recovery is preferred over other technologies
such as skimmers because it has the smallest equipment footprint, does not
require trenching across sensitive structures, and is an effective recovery option.
LNAPL will be recovered from a network of recovery wells by vacuum-truck
total fluids recovery. Recovery wells will be installed across the area where wells
have measurable LNAPL thickness (Figure 3-1). Recovery events will include
purging the wells with a vacuum truck. The recovery program will continue until
equilibrium LNAPL remains below measurable thickness. Recovery event
frequency will decrease with LNAPL thickness to allow the wells time to recover
to equilibrium thicknesses between recovery events.
3.2.1 Conceptual Model for System Operation
LNAPL is present in pore spaces above and below the water table near MW-59.
Recoverable LNAPL estimates are based on the soil type, LNAPL density and
viscosity, and historic maximum LNAPL thickness. LNAPL that can drain from
pore spaces through gravity drainage accumulates in monitoring wells as
recoverable LNAPL. LNAPL that cannot drain from pore spaces under gravity is
residual LNAPL. The historic maximum LNAPL thickness and pore size
distribution of the aquifer determine the residual saturation. Greater LNAPL
thicknesses are able to push LNAPL into smaller pore spaces (greater capillary
pressure). The resulting capillary forces to push LNAPL into pore spaces can
13
Port of Seattle Terminal 30 Cleanup Action Plan
exceed the gravity drainage forces and leave LNAPL trapped in small pore spaces
as residual saturation. Intuitively, LNAPL from small pores will drain more
slowly than LNAPL from larger pores will drain. Therefore, the amount of
LNAPL observed in a well and the maximum historic saturation together provides
the best estimates of LNAPL recovery.
LNAPL recovery estimate calculations and modeling estimates are included in
Appendix A. Modeling results and empirical field data indicate that:
• Recovery will reduce the LNAPL pore-space saturation by
approximately 0.1 based on modeling the LNAPL maximum and
current thickness at MW-59.
• Approximately 275 gallons of LNAPL in the vicinity of MW-59 is
recoverable.
• At a measurable LNAPL thickness of 0.5 feet, a two hour vacuumenhanced
recovery event is expected to recover between 3 and 15
gallons of LNAPL per well; range includes both modeled recovery
rates and recorded recovery volumes at RW-12.
• The optimal recovery well will have a nominal 17 foot radius of
influence (well spacing of 35 feet) to balance between LNAPL
recovery rate and number of wells installed in an infrastructure-dense
portion of the site.
Applied vacuum in the well casing will increase the head (pressure) gradient from
the surrounding aquifer into the well (Charbeneau, 2007a,b). The increased head
gradient will increase flow of LNAPL into the well proportional to the LNAPL
transmissivity (e.g. proportional to the LNAPL conductivity corrected for
physical properties and degree of saturation). LNAPL transmissivity will decrease
with progressive product recovery, which will decrease LNAPL saturation.
Vacuum enhanced recovery does not rely on volatilization of LNAPL for
enhanced recovery. The SVE effect of vacuum extraction events is expected to be
negligible relative to fluid recovery due to the low vapor pressure of weathered
diesel.
LNAPL recovery rate is expected to vary between wells depending on the local
variations in grain size within the soil matrix and distribution of LNAPL
saturation. Therefore some wells will reach the endpoint for LNAPL recovery
before others, even if the product thickness is similar at the beginning of the
vacuum recovery program (see Section 3.2.4).
3.2.2 Recovery Well Design
Recovery wells will be constructed to enhance LNAPL migration from the
surrounding aquifer and to accommodate vacuum enhanced extraction (Figure 3-
14
Port of Seattle Terminal 30 Cleanup Action Plan
3). The recovery well network will include 10 new wells and will continue
recovery at existing wells MW-59 and RW-12. New recovery wells will be
constructed of 4-inch diameter Schedule 40 PVC in a 12-inch borehole. Well
screens will extend from 2 feet above the water table at the combined seasonal
and tidal high to 2 feet below the seasonal low at low tide. Combined seasonal
and tidal variation near MW-59 is approximately 1.5 feet (nominal 6 foot screen).
A 3 foot sump will be installed below the screen to allow the contingent use of
alternate skimmer or pump configurations.
Between recovery events, the recovery wells will be capped with 4-inch diameter
expanding well caps and protected by flush-to-grade well monuments. During
recovery events, temporary vacuum-caps will be placed in the wellheads that are
capable of maintaining a vacuum and yet have ports for extraction piping, an airbleed
valve that can also pass a sounder or interface probe, and a pressure gauge
(Figure 3-3).
3.2.3 Vacuum-Enhanced Recovery
LNAPL will be removed using a vacuum truck to pump total fluids from recovery
wells. Total fluids will be extracted from the wells through a siphon tube with the
inlet set below the LNAPL-water interface. A vacuum-cap will be placed at the
top of the PVC well casing to maintain negative pressure inside the recovery well,
and the vacuum-cap will have an air-bleed valve to regulate pressure in the well.
The air bleed valve will be used to reduce pressure in the well if adverse effects
such as drawing excessive sediment through the well screen are observed. The top
of the siphon tube will be connected to the vacuum truck by a flexible hose. The
vacuum truck will apply approximately 5 psi of negative pressure to the well. The
negative pressure will create a pressure gradient in the aquifer that will draw
LNAPL and water into the well enhancing LNAPL recovery rates (Appendix A).
Vacuum enhanced recovery will be conducted for approximately 1 to 2 hours at
each well each event, and initially may recover about 250 gallons of total fluid per
event. Wells will be allowed to recover to equilibrium LNAPL thickness between
events. Equilibration/recovery times will increase as LNAPL saturation and
transmissivity decrease. Because of uncertainties in equilibration/recovery times,
the following schedule of recovery events is subject to change based on actual
recovery rates:
15
Port of Seattle Terminal 30 Cleanup Action Plan
Project Year Event Frequency Cumulative Events
1 Monthly 12
2 Bi-Monthly 18
3 Bi-Monthly 24
4 Bi-Monthly 30
5 Bi-Monthly 36
6 Based on Review --
Approximately 5 to 10 gallons of product per well will be recovered in the initial
recovery events and is expected to decrease to less than 0.5 gallons per well in the
later events. Equilibrium product thickness is estimated to approach 0.01 feet after
approximately 34 extraction events (Appendix A); Phase II AS/SVE system may
be installed at the end of Project Year 5 pending review of LNAPL recovery
progress. Individual recovery wells may be removed from the recovery events
when they meet termination criteria (Section 3.2.4).
LNAPL thickness will be measured at the beginning and end of each extraction
event. Recovery wells that do not have measurable thickness (0.01 ft) will not be
pumped during that recovery event.
3.2.4 LNAPL Recovery Termination
LNAPL recovery events at a well will be terminated when product thickness has
been reduced to less than a measureable thickness (0.01 feet) for a period of one
year of quarterly measurements. Product thickness will be measured with an
interface probe. A clear plastic bailer will be used to measure product thickness if
a reliable measurement cannot be obtained with the interface probe.
This recovery termination criterion will result in sequential removal of recovery
wells from recovery events as the area with measureable LNAPL thickness
shrinks. Wells will be left in place for 1 year after the last well meets the
termination criteria, after which they will be decommissioned consistent with
WAC 173-160.
3.2.5 Recovery Documentation
LNAPL remediation progress will be monitored by documenting total recovered
fluids per well and per event, estimated product recovery per event, and LNAPL
thickness at each recovery well at the start and finish of each recovery event.
Direct measurement of recovered product is unlikely to be feasible due to
emulsification of total fluids during recovery. Therefore, a sample of the total
recovered fluids will be collected from the vacuum truck tank and the
concentration used to estimate the recovered product quantity; for example 1,000
16
Port of Seattle Terminal 30 Cleanup Action Plan
gallons total fluids at 5,000 mg/L is the equivalent of approximately 5.8 gallons of
recovered product, based on a LNAPL density of 0.876 g/mL.
Recovered LNAPL will be recycled or disposed of off-site by the vacuum truck
contractor.
3.2.6 Phase II AS/SVE System Installation
At the end of Project Year 5, the equilibrium product thickness is estimated to
approach 0.01 feet. The Phase II AS/SVE system may be then installed to further
extract lighter fraction petroleum.
4.0 MONITORING
Monitoring will include measurements of LNAPL thickness and groundwater
monitoring at wells across the site (Table 3-1). Groundwater will be monitored at
conditional point of compliance (CPOC) wells, performance monitoring wells,
and interior groundwater monitoring wells. Wells are grouped as follows:
• LNAPL Thickness: MW-59 and adjacent LNAPL recovery wells
• CPOC Wells: MW-45, MW-46, MW-58A, MW-89, and MW-92
• Performance Monitoring Wells : MW-36, MW-39, MW-42, and RW-
9
• Interior Monitoring Wells: RW-1, RW-5A, and MW-38
The following contaminants of concern (COC) will be analyzed in performance
and compliance monitoring wells.
Petroleum Hydrocarbons
• Diesel-Range Organics
• Gasoline-Range Organics
• Oil-Range Organics
• BTEX: Benzene, Toluene, Ethylbenzene, Xylenes (total)
Semi-Volatile Organic Compounds
• 2-methylnapthalene
Polynuclear Aromatic Hydrocarbons (PAHs) (filtered and unfiltered)
• Acenaphthene
• Acenaphthylene
17
Port of Seattle Terminal 30 Cleanup Action Plan
• Anthracene
• Benzo(a)anthracene
• Benzo(a)pyrene
• Benzo(b)fluoranthene
• Benzo(g,h,i)perylene
• Benzo(k)fluoranthene
• Chrysene
• Dibenzo(a,h)anthracene
• Fluoranthene
• Fluorene
• Indeno(1,2,3-cd)pyrene
• Naphthalene
• Phenanthrene
• Pyrene
Key elements of the monitoring are described below.
4.1.1 LNAPL Monitoring
LNAPL thickness will be measured at MW-59 during groundwater compliance
monitoring events and at MW-59 and surrounding LNAPL extraction wells at the
beginning of LNAPL recovery events.
4.1.2 CPOC Groundwater Monitoring
Groundwater monitoring at the CPOC will be used to assess concentrations of site
COCs at the CPOC relative to cleanup levels. Due to the considerable sorbed
mass contributing to the dissolved phase exceedances, natural attenuation
processes are expected to take between 30 and 60 years to reach cleanup levels
across the site. Calculations for petroleum hydrocarbon degradation to cleanup
levels indicated approximately 30 years based on typical T30 site soil
concentrations and estimated groundwater degradation rates from monitoring well
data trends (PGG, 2013; AECOM, 2008).
Based on the petroleum degradation calculations, groundwater quality will be
monitored at the CPOC for 30 years (Table 3-1). Groundwater monitoring at the
CPOC may be continued beyond 30 years depending on the status of site-wide
groundwater concentrations.
Groundwater concentrations above cleanup levels may persist in some non-CPOC
wells after the estimated 30 year natural attenuation period due to residual
hotspots or physical characteristics of COCs. Residual contamination associated
with buried utilities or infrastructure may leave hot spots with localized elevated
groundwater concentrations after the majority of the site has reached cleanup
18
Port of Seattle Terminal 30 Cleanup Action Plan
levels. PAHs have lower biodegradation rates and higher soil sorption coefficients
than gasoline-, diesel-, and oil-range hydrocarbons. Therefore, natural attenuation
of PAHs is expected to be slower than for the petroleum hydrocarbons and may
persist as localized hotspots in areas where gasoline- through oil-range
hydrocarbons have reached cleanup levels. However, because PAHs sorb more
strongly to soil particles than petroleum hydrocarbons, they are not as mobile in
groundwater; therefore, the downgradient extent of residual PAH hotspots is
expected to be limited.
4.1.3 Performance Groundwater Monitoring
Performance monitoring wells are located within the AS/SVE system radius of
influence and will be used to track system effectiveness. Concentrations are
expected to decline as contaminant mass is reduced within the AS/SVE treatment
area. Groundwater concentrations are expected to rebound over 3- to 9-months
after the AS/SVE system is cycled off and groundwater with elevated
concentrations from the interior area flows through the AS/SVE treatment area.
4.1.4 Interior Groundwater Monitoring
Interior monitoring wells are located upgradient of the AS/SVE system within the
portion of the site with sheen but no measureable product thickness. Interior
monitoring wells will be used to track long-term reductions in contaminant mass.
Concentrations at the wells furthest upgradient (RW-1 and RW-5A) are expected
to first decline to remediation and then to cleanup levels. Groundwater
concentrations at MW-38 are expected to decline more slowly due to the
downgradient position, and may remain static for 10 or more years due to the
persistence of sheen that may maintain groundwater concentrations near
saturation for the residual petroleum mixture.
4.1.5 Schedule
Monitoring wells will be sampled on a schedule consistent with the anticipated
rate of change at that location and a well’s role in operational decision making.
Biodegradation processes will continue to reduce groundwater concentrations in
the interior sheen area in year to multi-year time scales. AS/SVE will locally
reduce groundwater concentrations in month-to-year time scales. Proposed
monitoring includes (Table 3-1):
Performance Monitoring
• Performance monitoring will be conducted when the AS/SVE system
(Phase I and II) is in operation and when the AS/SVE system is
temporarily shut down.
19
Port of Seattle Terminal 30 Cleanup Action Plan
• Performance monitoring wells will be sampled semi-annually when
the AS/SVE system is in operation (Phase I and II) and when the
AS/SVE system is temporarily shut down.
• The CPOC wells will be sampled biannually when the AS/SVE system
is in operation and when the AS/SVE system is temporarily shut down.
• The AS/SVE system is estimated to be in operation for seven years.
At the end of seventh year, the system will be temporarily shut down.
Compliance Monitoring
• Once both Phase I and Phase II AS/SVE system are permanently shut
down, long term compliance monitoring begins.
• The CPOC wells will be sampled annually for the first 5 years of
compliance monitoring, bi-annually for years 5-10, and every 5 years
for year 10 and beyond.
• Supplemental monitoring may be conducted to inform AS/SVE
operational decision making.
Interior Monitoring
• Interior monitoring wells will be sampled biannually for the first 7
years (4 events), followed by sampling every 5 years. The Interior
monitoring well schedule is independent of the transition from
Performance to Compliance monitoring at CPOC and Performance
monitoring wells.
Individual performance or interior groundwater monitoring wells may be removed
from the monitoring program early if concentrations achieve cleanup levels for
two consecutive sampling events; this does not apply to CPOC wells or wells
within the AS/SVE treatment zone while the AS/SVE system is operating.
4.2 INSTITUTIONAL CONTROLS
A restrictive environmental covenant consistent with the requirements of WAC
173-340-440 will be filed after construction of the AS/SVE and LNAPL recovery
systems.
4.3 CONTAMINATED MATERIAL LEFT ON-SITE
The selected remedy may leave concentrations of COCs elevated above soil
cleanup levels on site. WAC 173-340-380(1)(a)(ix) requires that remedies with
20
Port of Seattle Terminal 30 Cleanup Action Plan
on-site containment specify the amount of hazardous substances left on site and
the measures that will be used to prevent migration.
The volume of impacted soil or material left on site above cleanup levels is
estimated to be the volume of soil between the base of asphalt and the water table
within the historic extent of measurable LNAPL. This calculation over-estimates
the amount of material left on site because LNAPL initially spread laterally at the
water table from the release area. We estimate that approximately 63,000 cubic
yards of impacted soil will remain on site following completion of the selected
remedy.
5.0 SCHEDULE
The schedule for major deliverables and work tasks associated with cleanup
actions is included as Exhibit C to this Consent Decree. The schedule provides
anticipated submittal task duration for deliverables and actions associated with
site cleanup, including progress reports, financial assurances, engineering design
documents. Refer to Exhibit C for details on project deliverables and schedules.
5.1 ENGINEERING DESIGN REPORT
The forthcoming T30 Engineering Design Report (EDR) will provide technical
details and drawings for system installation including equipment specifications,
construction drawings, connections to utility infrastructure, and specific
permitting issues. The EDR will be completed within the schedule in the new
Consent Decree for the cleanup actions.
The EDR will include specifications for the Port of Seattle bidding process, which
is expected to take between 3 and 6 months from Port Commissioner approval to
proceed.
5.2 AS/SVE
After construction contract award, the AS/SVE system will be installed.
Construction activities will be coordinated with tenant operations.
The AS/SVE system will operate until groundwater monitoring meets the
shutdown criteria. The system is nominally expected to operate for 5 years in the
Phase 1 and Phase 2 areas.
21
Port of Seattle Terminal 30 Cleanup Action Plan
5.3 LNAPL RECOVERY
After construction contract award, the LNAPL recovery wells will be installed.
LNAPL recovery will continue until measurable LNAPL thickness is less than
0.01 feet at MW-59, RW-12, and additional recovery wells installed during
system setup. Recovery operations are anticipated to continue for 10 years with a
nominal completion date in 2026 assuming system startup in 2016.
5.4 GROUNDWATER MONITORING
Groundwater monitoring will be conducted for 30 years, with possible extension
at selected wells based on monitoring results at that time. The forthcoming T30
Compliance Monitoring Plan will describe long term- and operationalgroundwater
monitoring associated with the AS/SVE and LNAPL recovery
actions. The groundwater monitoring schedule for CPOC wells and additional
operational groundwater monitoring for the AS/SVE system will be detailed in
the plan.
6.0 CONTINGENCY ACTIONS
The selected remedial actions are expected to meet remedial objectives within a
reasonable time frame. However, contingency actions may be implemented
during the course of remedial activities in response to changes in site conditions,
identification of previously unrecognized environmental conditions, or if remedial
objectives are not met (Figures 6-1 and 6-2). Section 6.1 describes the process to
determine if a contingency action is appropriate. If a contingency action is
appropriate, Section 6.2 describes the process for selecting the contingency
action. Section 6.3 describes the notification schedule for beginning the
contingency action evaluation process.
6.1 CONTINGENCY ACTION EVALUATION
This section describes the process for evaluating if a contingency action is
appropriate. Broadly speaking, a contingency action is appropriate if the selected
remedial actions are not adequately protective of human health and the
environment. This situation could arise due to the following conditions:
• Identification of a previously unrecognized environmental condition
• Change in site conditions
• Groundwater concentrations of site COCs above cleanup level(s) at the
CPOC
• Remedial actions not achieving remedial objectives in a reasonable
timeframe
22
Port of Seattle Terminal 30 Cleanup Action Plan
Not all occurrences of the conditions listed above will trigger a contingency
action. Figure 6-1 diagrams an evidence-driven decision framework for evaluating
if contingency action is appropriate. The process and context for evaluating
conditions that might trigger a contingency action is described in the following
sections.
6.1.1 Unrecognized Environmental Condition
Substantial characterization has been completed at the T30 site since
environmental investigations began in the 1980s. It is unlikely that substantial
new environmental conditions will be identified at the site. The most probable
scenario for an unrecognized environmental condition is discovery of localized
hot-spots associated with historic buried materials. These would most likely be
encountered during excavation associated with utility work1 or construction of the
AS/SVE or LNAPL recovery systems.
Unrecognized environmental conditions will be assessed on a case by case basis
in the following steps:
1. Do CPOC groundwater concentrations exceed site cleanup levels?
Contingency action is not appropriate under MTCA if concentrations are
below cleanup levels.
2. If CPOC groundwater concentrations exceed site cleanup levels, do existing
remedial actions adequately address the contamination? Contingency action is
not appropriate within the site context if remedial actions already in progress
will address the contamination in a reasonable timeframe.
Contingency action will be initiated if an environmental condition is recognized
with concentrations above groundwater cleanup levels that will not be addressed
by ongoing remedial actions.
6.1.2 Change in Site Conditions
Changes in site conditions that alter potential exposure pathways could trigger
contingency action specific to the exposure pathway. Examples could include:
• Change in groundwater flow system
• Change in site infrastructure resulting in an increased exposure
potential
• Natural disaster (flood, earthquake, etc.) causes redistribution of
contamination or site boundaries
1 Future excavation work will be conducted consistent with institutional controls discussed in Section 4.2
23
Port of Seattle Terminal 30 Cleanup Action Plan
Changes in site conditions will be evaluated on a case by case basis with
consideration of concentrations relative to T30 site cleanup levels and whether
remedial actions already in progress will address the change in site conditions.
6.1.3 Concentrations Above Cleanup Levels
Contingency action could be initiated if groundwater concentrations of site COCs
are both above cleanup levels at COPC wells and are demonstrated to have a
statistically significant increasing trend. An increasing trend at concentrations
below cleanup levels, or exceedances at performance or interior monitoring wells
would not trigger contingency action.
Concentrations may exceed site cleanup levels at some CPOC wells at the
beginning of remedial action. Therefore, an exceedance of cleanup levels at the
CPOC will not automatically trigger a contingency action if remedial measures to
reduce concentrations are already in progress. Satisfactory progress towards
cleanup objectives is discussed in Section 6.1.4.
Increasing trends will be evaluated using the statistically-based methods for
evaluating plume status (Ecology, 2005). The method uses the non-parametric
Mann-Kendall and Whitney-U tests to evaluate if constituent concentration trends
at monitoring wells are increasing, stable, or decreasing. These tests require four
or more independent sampling events to produce valid results.
6.1.4 Remedial Action Progress
Remedial progress will be tracked through groundwater monitoring described in
Section 4 and the forthcoming T30 Compliance Monitoring Plan.
Progress relative to remedial objectives will be evaluated during Ecology periodic
reviews. Contingency actions will be considered if remedial actions do not meet
the remedial goals.
6.2 CONTINGENCY ACTION PROCESS
This section describes the process for planning contingency actions if a
contingency action is appropriate after the evaluation in Section 6.1. The
contingency action process is divided into three phases:
1. Action Selection: this phase describes the nature and extent of the exceedance
triggering contingency action and selects an appropriate remedy. This phase
may determine that a contingency action is not required to meet remedial
objectives.
24
Port of Seattle Terminal 30 Cleanup Action Plan
2. Design: this phase prepares the necessary engineering and design plans and
reports, addendum to the Compliance Groundwater Monitoring Plan, or other
documentation to implement the contingency action.
3. Implementation: this phase implements the selected contingency action.
The contingency action process parallels the remedial investigation and feasibility
process under MTCA, but is intended to be streamlined towards efficient
implementation. Steps may be combined for efficiency.
The action selection phase will define the media to be addressed, the nature and
extent of the contamination to be addressed, and the objectives of the contingency
action. Depending on the scope of the identified environmental issue, this first
phase may also include investigation to fill data gaps and focused assessment of
contingency action alternatives.
6.3 CONTINGENCY ACTION SCHEDULE
The Port of Seattle will notify Ecology within 14 days of identifying an
environmental issue that potentially meets the criteria for contingency action. The
Port of Seattle will provide a schedule and preliminary plan for moving through
contingency action selection in consultation with Ecology. The plan may include
additional investigation and characterization prior to selecting a contingency
action.
Environmental issues that do not meet the criteria for contingency action will be
discussed as appropriate in routine monitoring reports submitted to Ecology under
the forthcoming T30 Compliance Monitoring Plan.
25
Port of Seattle Terminal 30 Cleanup Action Plan
7.0 REFERENCES
Charbeneau, R., 2007a. LNAPL Distribution and Recovery Model (LDRM)
Volume 1: Distribution and Recovery of Petroleum Liquids in Porous Media.
API Publication 4760. January, 2007.
Charbeneau, R., and Beckett, G., 2007b. LNAPL Distribution and Recovery Model
(LDRM) Volume 2: User and Parameter Selection Guide. API Publication
4760. January, 2007. Pacific Groundwater Group, 2013. Terminal 30
Supplemental Remedial Investigation / Feasibility Study. June 11, 2013.
Ecology, 1991. In the Matter of Remedial Action by: Port of Seattle Agreed
Order: Terminal 30. Effective Date: August 30, 1991.
Ecology, 2013. First Amendment to Agreed Order: Terminal 30. Port of Seattle.
Effective Date: October 23, 2013.
ENSR|AECOM, 2008. Supplemental Data Report, Revision 2. Prepared for Port
of Seattle Terminal 30 by ENSR., Seattle, Washington. June.
ENSR|AECOM, 2010. Terminal 30 Cargo Terminal Construction Completion
Report. Prepared for Port of Seattle Terminal 30 by AECOM. Seattle,
Washington. January 2010.
Ecology, 2012a. Ecology online CLARC Database.
https://fortress.wa.gov/ecy/clarc/Reporting/CLARCReporting.aspx. Accessed
January 2012.
GeoEngineers, Inc., 1998. Terminal 30 Final Report Remedial Investigation/
Feasibility Study. Prepared for the Port of Seattle. December.
Pacific Groundwater Group, 2013a. Terminal 30 Monitoring Well Installation and
Data Gaps Sampling. November 6, 2013.
Pacific Groundwater Group, 2013b. Terminal 30 Remedial Investigation /
Feasibility Study. November 2013.
Pacific Groundwater Group, 2014. Port of Seattle Terminal 30 Draft Cleanup
Action Plan Key Revisions. March 26, 2014.
26
Port of Seattle Terminal 30 Cleanup Action Plan
Table 1-1. Soil Cleanup Levels
3RUW RI 6HDWWOH 7HUPLQDO
Cleanup Levels
Constituent
(mg/kg)
BTEX Compounds
%HQ]HQH 0.03
7ROXHQH 7
(WK\OEHQ]HQH 6
;\OHQHV WRWDO 9
Semivoliatile Organic Compounds
0HWK\OQDSKWKDOHQH NV
PAH Compounds
$FHQDSKWKHQH NV
$FHQDSKWK\OHQH NV
$QWKUDFHQH NV
%HQ]R>D@DQWKUDFHQH NV
%HQ]R>D@S\UHQH 0.35
%HQ]R>E@IOXRUDQWKHQH 0.44
%HQ]R>J K L@SHU\OHQH NV
%HQ]R>N@IOXRUDQWKHQH 0.44
&KU\VHQH 0.14
'LEHQ]R>D K@DQWKUDFHQH 0.64
)OXRUDQWKHQH 89
)OXRUHQH 547
,QGHQR> FG@S\UHQH 1.25
3KHQDQWKUHQH NV
3\UHQH 3,532
1DSKWKDOHQH 5
Petroleum Hydrocarbons
7SK GLHVHO UDQJH RUJDQLFV 2,000
7SK KHDY\ RLOV 2,000
7SK JDVROLQH UDQJH RUJDQLFV EHQ]HQH SUHVHQW 30
7SK JDVROLQH UDQJH RUJDQLFV QR GHWHFWDEOH EHQ]HQH 100
19 LQGLFDWHV WKDW QR YDOXH LV DYDLODEOH
Port of Seattle Terminal 30
Table 1-2. Groundwater Cleanup Levels
3RUW RI 6HDWWOH 7HUPLQDO
Cleanup Levels
Constituent
(ug/L)
BTEX Compounds
%HQ]HQH 23
7ROXHQH 15,000
(WK\OEHQ]HQH 2,100
;\OHQHV WRWDO 1,000
Semivoliatile Organic Compounds
0HWK\OQDSKWKDOHQH NV
PAH Compounds
$FHQDSKWKHQH 643
$FHQDSKWK\OHQH NV
$QWKUDFHQH 25,900
%HQ]R>D@DQWKUDFHQH 0.018
%HQ]R>D@S\UHQH 0.018
%HQ]R>E@IOXRUDQWKHQH 0.018
%HQ]R>J K L@SHU\OHQH NV
%HQ]R>N@IOXRUDQWKHQH 0.018
&KU\VHQH 0.018
'LEHQ]R>D K@DQWKUDFHQH 0.018
'LEHQ]RIXUDQ NV
)OXRUDQWKHQH 90
)OXRUHQH 3,460
,QGHQR> FG@S\UHQH 0.018
3KHQDQWKUHQH NV
3\UHQH 2,590
1DSKWKDOHQH 4,940
Petroleum Hydrocarbons
7SK JDVROLQH UDQJH RUJDQLFV QR GHWHFWDEOH EHQ]HQH 1,000
7SK JDVROLQH UDQJH RUJDQLFV EHQ]HQH SUHVHQW 800
7SK GLHVHO UDQJH RUJDQLFV 500
7SK KHDY\ RLOV 500
19 LQGLFDWHV WKDW QR YDOXH LV DYDLODEOH
Port of Seattle Terminal 30
93 Octane lin e o s a G s e e o lin Va l u 87 Octane s G a c e ) e n k a f e r s Re i t y il (Ala i l Diesel Fuel O l u b l s e e So No. 2 ie D t i v e c Ef f e l A ie s E P No. 1 D 1994 Diesel il e l O F u 75% Effective *** b ility o lu S Remediation l** e v ZLOO EH UHGXFWLRQ WR VKHHQ QR PHDVXUDEOH WKLFNQHVV L e D SHWUROHXP PL[WXUH LV ORZHU WKDQ ZKHQ LQ FRQWDFW ZLWK D SXUH VRXUFH VXFK DV D SXUH EHQ]HQH UHOHDVH ROXELOLW\ &DOFXODWRU DW KWWS ZZZ HSD JRY DWKHQV OHDUQ PRGHO SDUW WZR RQVLWH HV KWPO RI HLWKHU WZLFH WKH FOHDQXS OHYHO RU RI WKH HIIHFWLYH VROXELOLW\ )RU GLHVHO DQG JDVROLQH UDQJHV WKLV LV WDNHQ DV WKH DWLYH DV %7(; FRPSRXQGV FRQVWLWXWH OHVV WKDQ RI WKRVH SHWUROHXP PL[WXUHV 7KH (3$ 'LHVHO )XHO 2LO HIIHFWLYH VROXELOLWLHV DUH DOVR LQFOXGHG IRU FRPSDULVRQ
e l v L e Table 1-3. Remediation Levels Cleanup Units XJ / XJ / XJ / XJ / XJ / XJ / /XJ
3RUW RI 6HDWWOH 7HUPLQDO LF V D Q U J
Constituent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
Motor Oil mg/L .5 0 8 8 8 8 8 8 28 8 Diesel mg/L 0 .5 8 8 8 120 Gasoline mg/L .8 0 8 1.3 8 1.7 Total ug/L 00 1 0 8 8 8 8 o-Xylene ug/L 00 1 0 8 8 8 8 8 m, p-Xylene ug/L 00 0 1 8 8 8 Table 1-4. Summary of Most-Recent Analytical Results Ethylbenzen ug/L 00 1 2 8 Sheen Present, No Measurable Product Thickness, No Analytical Data Available Sheen Present, No Measurable Product Thickness, No Analytical Data Available 8 8 Sheen Present, No Measurable Product Thickness, No Analytical Data Available Sheen Present, No Measurable Product Thickness, No Analytical Data Available Toluene ug/L 00 5 0 1 8 8 8 8 8
Benzene ug/L 23 Conditional Point of Compliance (CPOC) Wells 8 8 8 8 8 28 8
3RUW RI 6HDWWOH 7HUPLQDO Sample Date el Le v u p a n
C le 0: 0: 0: $ 0: 0: Performance Monitoring Wells 0: 0: 0: 5: Interior Wells 0: Well 5: $ 5 : %ROG LQGLFDWHV H[FHHGDQFH RI WKH FOHDQXS OHYHO &8/ :HOOV ZKHUH VKHHQ RU SURGXFW ZDV REVHUYHG ZHUH W\SLFDOO\ QRW VDPSOHG 3RUW RI 6HDWWOH 7HUPLQDO
2 3 X X X 2 5 X X X X X 2 7 X X X 0 2 X X X X X 2 2 X X X 1 5 X X X X X 1 7 X
X
X 1 0 5-Year Interval X
X
X
X
X 6 1 9 1 5 8 X X X X X 1 4 7 3 1 6 Bi-Annual X X X X X 2 1 X X X 5 X X X X X 1 1 d 4 X X X X X r io 0 1 Pe 3 X X X X X in g 9 l it o r r v a n Mo 2 X X X X X 8 Inte r e a e c X X X X X - Y n 1 5 lia Annual 7 X X p m : Co r a Y e X X X X X X X X X X
Table 3-1. Groundwater Monitoring Schedule 6 X X X X
5 X X X d ** X X X X X X X X X
io 4 r g Pe X X X X
in r
3 X n it o X X X X X X X X X X X e Mo
Port of Seattle Terminal 30 2 * Interior Monitoring Wells c l X X X X
l
n a
a
a u n
n u
n
X X X r m o r f X X X X X i- A X n
1
X
X
X P e Bi-Annual m S e i- A B
r MW-38 a RW-1 RW-5A Conditional Point of Compliance Wells MW-45 MW-46 MW-58A MW-89 MW-92 Performance Monitoring Wells Y e t j e c -9 r o W P MW-36 MW-39 MW-42 R Notes: Project Year 1 sampling will be conducted just prior to AS/SVE system startup. * The Interior monitoring well schedule is independent of the transition from Performance to Compliance monitoring at CPOC and Performance monitoring wells. ** The duration of the Performance monitoring period is determined by the operation of the AS/SVE system. The bi-annual and semi-annual monitoring frequency at CPOC and Performance monitoring wells will continue until Compliance monitoring begins. LNAPL thickness will be measured at MW-59 and surrounding wells will on the recovery event schedule. Sampling may continue beyond year 32 on the 5-year compliance monitoring schedule, as discussed in text. Monitoring may be discontinued at individual monitoring wells when concentrations achieve cleanup levels for two consecutive events. x indicates a year with sampling at the indicated wells Port of Seattle Terminal 30
. ?321 Sheen Area 2011 Groundwater Extent Soil Extent Performance Monitoring Wells Interior Wells ! A ! A ( (CPOC) Wells Analytical data shown are most recent results, as summarized in Table 1-4. Analytical data not available for MW-36, MW-38, RW-1 and RW-9 NMT: No Measurable Thickness ) ) Bold indicates exceedance of the cleanup level CUL: Cleanup Level MW-90 Isolated “hot spots” may exist beyond the outlined soil and groundwater extent. Extent of Contamination* *Extents based on a combination of the historic extent of LNAPL, historic and recent data, and distribution of exceedances. ! A ! A 100 MW-87A ! A MW-52A MW-91 MW-87B ! A ! A lt u e s U 1 lt R 0.15 0.36 0.25 U K Feet
s u U L R e 0.17 0.59 0.25 U 1 3 C U 0.5 0.8 0.5 2 L
2012 USGS Orthophoto 0 ! A U 3 its /L C 0.5 0.8 0.5 2 n U g u MW-49 its mg/L mg/L mg/L /L n t ! A U n mg/L mg/L mg/L u g e e MW-92 u lt t titu n U s z e 1 s e 1.3 0.5 U e n n o n e R 0.25 U n e C Diesel Gasoline Motor Oil
B s titu e lt L n z u
3
U o n s C 0.5 0.8 0.5 2 8 C Diesel Gasoline e e 0.17 0.65 1 MW-89 Motor Oil
B R 0.25 U ! A MW-42 ! A L its n
/L g
U
mg/L mg/L mg/L u
U 3 C 0.5 0.8 0.5 t 2 n e e
n its /L n
U mg/L mg/L mg/L u g titu s e z
e MW-86B n o e n ! A
n t ? C Diesel Gasoline Motor Oil B
F ac ! A ! A e n e MW-54
re te titu s e
! A
n z o e n Co nc MW-86C C Diesel Gasoline Motor Oil
B
RW-5A T
eof lt u 8
M
T
E d g u lt s 1.7 28
2 M t, N
s e R 120 e n
R e 0.18 0.25 0.25 U 1 U t, N e n s e r ! A
U L 0.5 0.8 0.5 2 3 MW-38 s MW-77 ! A r e n P
U L 0.5 0.8 0.5 23 C MW-39 P n - 1 e e e e W h
C h R S ! A its /L ! A S ! A U n mg/L mg/L mg/L g u ? its U n mg/L t mg/L mg/L ug/L t n n e e e titu n s z e MW-58A s titu n n n o C Diesel Gasoline Motor Oil e B
C o Diesel Gasoline Motor Oil Benzene To w e r
! A RW-9 Sheen Present, NMT ! A RW-11A T30 Vessel ! ! A A MW-85A East Waterway U lt n e u L i e s 0.05 U 0.05 U 0.25 U r 0 .5 ! A e R t
s
n MW-85B
e
e
l
a
C
c W a l l L ? U 0.5 0.8 0.5 2 3
i l e
S C ! A MW-36
e t P k
c
u
MW-46 n its /L g ! A
S h e r
T U mg/L mg/L mg/L u t MW-35 n e w titu e Sheen Present, NMT n e N e y S n s n z Wa C o Diesel Gasoline Motor Oil e B al rg in ! ! A lt ! A MW-59 Ma u ! A ! A st MW-84A A MW-84B s MW-45 R e 0.05 U 0.05 U 0.25 U ?
0.5 U MW-64 Ea L ! A U C 0.5 0.8 0.5 23 RW-12 its U n mg/L mg/L mg/L ug/L t tt l e ce e n titu ea ff i s f S e O o n o C Diesel Gasoline Motor Oil Benzene ! A MW-88 MW-81A ! A or t Po li c
4 1 0 2 / 4 1 / 4 d x m . 4 1 0 2 _ n o i t a n i m a t n o C f o t n e t x E \ s d x m \ S I G \ 0 3 T \ Y N O P \ : K P
Phase I Air Sparge Well with Radius of Influence Phase I SVE Pipe in Trench Future Phase II AS/SVE Performance Monitoring Wells Interior Wells Phase II Air Sparge Well with Radius of Influence Site Extent of Contamination Gaging/Recovery Well Soil Extent LNAPL Extraction Well with Radius of Influence Water Quality Monitoring Well Decommissioned Wells Conditional Point of Compliance (CPOC) Wells LNAPL > 0.1 Feet 2011 Sheen Area Groundwater Extent ! . ) ) *Extents based on a combination of the historic extent of LNAPL, historic and recent data, and distribution of exceedances. Isolated “hot spots” may exist beyond the outlined soil and groundwater extent. ! . Figure 3-1 Cleanup Action Components Port of Seattle inal 30 Term ! A Remediation Elements ! A ! A ( Extent of Contamination* ! A CO-1 ! A MW-75 ! A MW-90 MW-91 ! A ! A MW-14 ! A ! A MW-52 CO-3 ! A ! A CO-2 MW-51 ! A MW-11 ! A ! A ! A 100 MW-87
K
MW-50 MW-87A Feet ! A ! A MW-52A ! A MW-6 ! A MW-49 MW-87B MW-56 ! A CO-4
2012 USGS Orthophoto
! A 0 ! A MW-25 MW-53 ! A MW-5 ! A MW-92 ! A MW-62 MW-86 ! A ! A MW-4 ! A ! A ! A AS-1 ! . R4 ! A MW-62A MW-17 ! A ! A MW-78A MW-89 ! A ! A -2 A S ! . MW-61 MW-78 U2 ! A MW-42 ! A -3 ! A MW-86B S A ! . e MW-43 ! A MW-79 ! A ! A ! A ! A MW-54 MW-74 ?
a c ! A ! A -4 MW-41 S ! . te F ! A A ! A c re 2 R7 MW-79A o n -7 ! A W ! A ! A
RW-5A
! A -5 S ! . R8 o f C M MW-86C ! A MW-40 A g e -6 S ! . E d MW-72A MW-38 R5 ! A MW-77
! A A -7 R6 ! A S A ! . ! A
! A MW-58 MW-58A ! A MW-26 ! A R10 ! A MW-39 ! A -8 RW-1 MW-55
A S ! . MW-1 ! A ! A ! A
-9 MW-8
A !
S . ?
MW-33 0
! A -1 ! . A S
85 -11 ! . MW-24 ! A
M W - ! A S
MW-37 ! A A ! A 2 RW-9 ! A -1 RW-11 MW-47
!
! . ! A
! A A MW-85A T30 Vessel To w e r S A 3 ! A MW-9 ! A
ay S -1 ! . ! A A RW-11A
East Waterw MW-71 ! A MW-85B ! . ! A MW-46 MW-36 ! A MW-73 ! A AS-14 ales
c
MW-34
S AS-15 ! . ? AS-16 ! . ! A Truck MW-35 ! A MW-44 ! A AS-17 ! . MW-80 AS-18 ! . MW-10 ! A MW-45 ! A ! A ! A ! . MW-29 ! MW-84 AS-20 ! A A MW-84B MW-59 ! A ! A ! . MW-64 ! A MW-46A ! A Li ne AS-14
?
East Marginal Way S en t er MW-66 ! A RW-12 ! A ! A MW-84A MW-63 l l C MW-69 Wa i l
P e MW-60 ! A MW-65 e t ! A S h e MW-67 ! A f Seattle ! A MW-88 w N e ! A MW-70 MW-81A ! A Port o Police Office
12/3/2015 K:\PONY\T30\GIS\mxds\Remediation_Well_Network_Layout_2015.mxd
:HOOKHDG ZLWK 3UHVVXUH *DXJH 9DOYH /DWHUDO &RQQHFWLRQ WR :HOO
LQ )OXVK 0RXQW +LJK 7UDIILF 0RQXPHQW 6FKHPDWLF
Asphalt
$6 'LVWULEXWLRQ 3LSLQJ
LQFK 39&
%DFNILOO ZLWK
&RPSDFWLRQ
*UDYHO 3DFN
+RUL]RQWDO 69( 3LSLQJ
VORWWHG LQFK 39&
*URXWHG $QQXODU
6HDO
'HSWK %HORZ *URXQG 6XUIDFH IHHW 3RWHQWLDO *URXQGZDWHU 0RXQGLQJ
'HSWK WR :DWHU a IW EJV
LQFK 39& 5LVHU
5DGLXV RI ,QIOXHQFH
%HQWRQLWH $QQXODU 6HDO
6DQG 3DFN
IRRW 6FUHHQ ,QWHUYDO
LQFK VORW 39&
LQFK IHHW Figure 3-2. AS/SVE Subsurface
Components
3RUW RI 6HDWWOH
7HUPLQDO
)ORZ WR 9DFXXP 7UXFN
6LSKRQ 7XEH SVL YDFXXP
:HOOKHDG LQ )OXVK 0RXQW
+LJK 7UDIILF 0RQXPHQW
$LU %OHHG ,QOHW 9DOYH
:HOO 6HDO
Asphalt
+\GUDWHG %HQWRQLWH LQFK ERUHKROH
$QQXODU 6HDO
LQFK 39& 5LVHU
'HSWK %HORZ *URXQG 6XUIDFH IHHW LNAPL Saturation Profiles
Maximum Historic LNAPL Saturation
*URXQGZDWHU 0RXQGLQJ
Current LNAPL Saturation
'HSWK WR :DWHU IW EJV
IRRW 6FUHHQ ,QWHUYDO
epth LQFK 39&
D Maximum Historic and
Current Measured
LNAPL Thicknesses
6DQG 3DFN Residual LNAPL Saturation
0 0.2 0.4 0.6 0.8 1
Pore-Space Saturation
IRRW VXPS
:HOO QRW GUDZQ WR KRUL]RQWDO VFDOH YHUWLFDO VFDOH LQFK IHHW Figure 3-3. High-Vacuum LNAPL
'HSWK WR ZDWHU LV WKH HVWLPDWHG HTXLOLELUXP ZDWHU OHYHO DFFRXQWLQJ IRU Recovery Components
/1$3/ ZLWK GHQVLW\ RI J P/
/1$3/ VDWXUDWLRQ SURILOHV EDVHG RQ $3, PRGHO RI SURGXFW DW 0: 3RUW RI 6HDWWOH
*URXQGZDWHU PRXQG VFKHPDWLF QRW TXDQWLWDWLYH 7HUPLQDO
Figure 6Ͳ1. Contingency Action Decision Framework
Port of Seattle Terminal 30
Start
Identification of previously
unrecognized environmental Yes
condition?
Concentrations below
No cleanup levels?
Change in site conditions that alters
potential receptor pathway? No Ye s
No contingency Yes
action required No
Adequately addressed by
existing remedial
approach? 3
Concentrations above cleanup
No
levels at CPOC?
No
Yes
Demonstration of expanding
Yes
plume? 1
Begin contingency
No action planning 4
Remediation meeting scheduled
Yes No
objectives? 2
Notes:
1 Plume expansion to be evaluated using the statistical approach described in Appendix D of Ecology Publication 05Ͳ09Ͳ091, Guidance on Remediation of
PetroleumͲContaminated Ground Water By Natural Attenuation . July 2005. Evaluation will include at least 5 years of monitoring data.
2 Scheduled objectives described in Sections 4 and 5, including objectives for LNAPL removal, AS/SVE system biostimulation, and compliance monitoring.
3 This will be assessed through a combination of technical analysis and professional judgement in communication with Ecology.
4 Contingency action will be selected to address the identified environmental condition. See Figure 5Ͳ2.
Additional data beyond groundwater monitoring described in the Compliance Monitoring Plan (not yet complete) may be required to evaluate if contingency
action is warranted.
3RUW RI 6HDWWOH 7HUPLQDO
Figure 6Ͳ2. Contingency Action Process
Port of Seattle Terminal 30
Start: contingency action triggered
(See Figure 5Ͳ1)
Notify Ecology within 14 days of
determination
Develop prelminary plan and schedule
for evaluation phase
Ecology review 1
Prepare evaluation and design reports
2
Ecology review 1
Implement contingency action
Notes:
1 Ecology review step includes revision to address Ecology comments.
2 Evaluation report may be submitted separately depending on complexity of selected contingency action, or if
the evaulation demonstrates that no additional contingency actions are required to meet remedial objectives.
Evaluation and design reports described in Secton 5.2.
3RUW RI 6HDWWOH 7HUPLQDO
APPENDIX A
SUPPORTING LNAPL INFORMATION
LNAPL RECOVERY CALCULATIONS
This appendix outlines calculations and modeling results conducted in support of LNAPL recovery
planning for the Terminal 30 Draft Cleanup Action Plan (PGG, 2013). Modeling was performed using the
API LDRM model (Charbeneau, 2007).
Baseline LNAPL saturation is based on historic LNAPL measurements at MW-59 and RW-12
(GeoEngineers, 1998; ENSR|AECOM, 2008). LNAPL saturation models were used to estimate current
LNAPL saturation profiles, which form the basis for estimating recoverable LNAPL at MW-59 and RW-
12. Other wells to be installed in the vicinity are expected to have similar or thinner LNAPL thicknesses
and similar soil conditions.
Baseline LNAPL saturation modeling inputs are listed in Table A1:
Table A1. LNAPL Input Parameters
,QSXW 3DUDPHWHU 9DOXH 8QLWV 6RXUFH
0D[LPXP /1$3/ 7KLFNQHVV P *HR(QJLQHHUV
&XUUHQW /1$3/ 7KLFNQHVV DW W P 3**
*URXQG 6XUIDFH P $VVLJQHG
$VVLJQHG EDVHG RQ QRPLQDO
:DWHU 7DEOH 'HSWK P GHSWK
:DWHU 9HUWLFDO *UDGLHQW $VVXPHG ]HUR
/1$3/ 'HQVLW\ J P/ 3**
/1$3/ 9LVFRVLW\ FS 3**
$LU :DWHU 6XUIDFH 7HQVLRQ G\QH FP /LWHUDWXUH
$LU /1$3/ 6XUIDFH 7HQVLRQ G\QH FP /LWHUDWXUH
/1$3/ :DWHU 6XUIDFH 7HQVLRQ G\QH FP /LWHUDWXUH
3RURVLW\ 'HIDXOW IRU VHOHFWHG
YDQ*HQXFKWHQ 3DUDPHWHUV
+\GUDXOLF &RQGXFWLYLW\ P G 3**
9DQ*HQXFKWHQ 1 (165_$(&20
9DQ*HQXFKWHQ D P (165_$(&20
,UUHGXFLEOH :DWHU 6DWXUDWLRQ (165_$(&20
5HVLGXDO /1$3/ 6DWXUDWLRQ 9DULDEOH &DOFXODWHG
5HVLGXDO /1$3/ I IDFWRU 'HIDXOW
Table A2 lists the symbols used in the API LDRM output plots.
Table A2. LNAPL Plot Parameters
3DUDPHWHU 'HVFULSWLRQ
6Z :DWHU 6DWXUDWLRQ DW ,QLWLDO /1$3/ 7KLFNQHVV
6Z W :DWHU 6DWXUDWLRQ DW ,QWHUPHGLDWH 7LPH W
6Q /1$3/ 6DWXUDWLRQ DW ,QLWLDO /1$3/ 7KLFNQHVV
6Q W /1$3/ 6DWXUDWLRQ DW ,QWHUPHGLDWH 7LPH W
6UQ 5HVLGXDO /1$3/ 6DWXUDWLRQ
:DWHU 7DEOH (OHYDWLRQ RI (TXLOLEULXP :DWHU 7DEOH
LNAPL and water saturation is measured as the fraction of pore space filled by LNAPL or water while
porosity is the fraction of the aquifer not occupied by solids. An LNAPL saturation of 0.1 in an aquifer
with a porosity of 0.4 is equivalent to 0.04 of the total soil volume being filled with LNAPL.
Modeled LNAPL saturation curves at peak measured LNAPL thickness (Sn (0)) in the MW-59 area (1.25
meters, or 4.1 feet shown as vertical bars at the right of plots) are:
Product thickness at MW-59 ranged from 0.59 to 0.21 meters (1.93 to 0.69 feet) in 13 measurements
between 2006 and 2008 with an average of 0.3 meters (1.0 foot) (ENSR|AECOM, 2008). LNAPL
saturation curves at 0.3 meters LNAPL thickness (current condition, time t) after the peak LNAPL
thickness of 1.25 meters is:
The maximum recoverable product by gravity drainage at each well is the difference in
saturation between the current saturation (Sn(t)) and the residual saturation (Srn). The total
volume of recoverable product is the difference in saturation scaled to the recovery radius. For
the plot above with an average 0.1 difference between current and residual LNAPL saturation,
and a recovery radius of 17 feet (well spacing), there is approximately 275 gallons of recoverable
LNAPL in the vicinity of MW-59. Note that this likely overestimates the practically recoverable
LNAPL because LNAPL transmissivity will decrease with LNAPL thickness and LNAPL may
not be adequately mobile to migrate even under the gradient induced by the applied vacuum.
Uncertainties in recovery rate increase as the recovery progresses because small-scale
heterogeneity becomes more important in overall LNAPL migration.
PRODUCT RECOVERY
The API model predicts approximately 2.25 gallons of recovery per well, per event with an
initial product thickness of 0.3 meters (1.0 foot); 5 psi vacuum; an assumed water production rate
of 1 gpm; and a 2 hour duration.
Records of manual recovery events at MW-59 and RW-12 suggest that the modeled recovery
rates are overly conservative. Approximately 3 gallons of product were manually recovered from
MW-59 starting at an initial thickness of 0.96 feet in November 2008. Recovery rates and
product thickness relative to actual recovery at RW-12 suggest that recovery rates on the order of
5 to 20 gallons per well per event are reasonable during initial recovery events. Recovery rates
will decrease to less than a gallon per event as product thickness decreases to below 0.1 feet.
Vacuum-truck total fluids recovery is a more aggressive approach than manual purging and
recovery rates are expected to be greater than manual recovery.
Recorded RWͲ12 LNAPL Recovery
0.8
0.7
(ft)
0.6
0.5
0.4
LNAPL Thickness 0.3
0.2
0.1
0
0 5 10 15 20 25
Gallons Per Manual Recovery Event
Assuming a nominal 8 gallons of LNAPL per recovery event, approximately 34 extraction events would
be required to remove the estimated 275 gallons of recoverable LNAPL in the vicinity of MW-59.
LNAPL recovery rates will decrease substantially as product thickness declines below 0.1 feet, and 50
LNAPL recovery events are assumed. The actual number of product recovery events is likely to vary due
to the uncertainties in the actual LNAPL saturation at MW-59 and at the new recovery wells to be
installed.
Exhibit C Scope of Work and Schedule
Deliverable/Milestone Estimated Start Date/Period Estimated Time Required
to Complete Task After
Start Date
Signed Consent Decree November 2016 --
Progress Reports Calendar Quarterly after effective --
date of Consent Decree
Cost Estimate for 60 days after effective date of 2 months
Consent Decree Consent Decree
Implementation (per
Consent Decree Section
XXI)
Proof of Financial 60 days following Ecology approval 2 months
Assurances (per of the Cost Estimate for Consent
Consent Decree Section Decree implementation
XXI)
Annual Financial Annually, within 30 days of the 2 months
Assurance Report (per anniversary date of Consent Decree
Consent Decree Section
XXI)
Engineering Design Immediately following execution of 18 months
Report (EDR) Consent Decree
Construct and Operate Within 12 months following 60 months*
AS/SVE approval of EDR
Construct and Operate Within 12 months following 120 months
LNAPL Recovery approval of EDR
Performance 3 months after the start of the 60 to 120 months
Monitoring AS/SVE system
Submit proof of Within 10 days of completion of --
recording of performance monitoring
Environmental
Covenants to Ecology
Periodic Reviews Every 5 years from the effective --
Conducted by Ecology date of Consent Decree
Compliance Monitoring 3 months after the start of the 360 **
AS/SVE system
* AS/SVE operation and associated performance monitoring may be adjusted based on operational
information, including possible extension beyond 5 years. Note that the schedule in Phase 1 and Phase 2
AS/SVE areas will be staggered with a later start date for the Phase 2 area. The AS/SVE system will be
discontinued when the system is no longer significantly reducing contaminant mass in the sheen area, as
described in the EDR.
**The duration of Compliance Monitoring will be based on achieving compliance goals specified in the
Cleanup Action Plan.
Implementation of Cleanup Action Plan (CAP)
T30 Cleanup Site
December 15, 2015
Page 1 of 16
Environmental Checklist
Implementation of Cleanup Action Plan (CAP) at the Port of Seattle Terminal 30 Cleanup Site
A. BACKGROUND
1. Name of proposed project, if applicable:
Implementation of Cleanup Action Plan (CAP) at the Port of Seattle Terminal 30 (T30) Cleanup Site
2. Name of applicant:
Port of Seattle
3. Address and phone number of applicant and contact person:
Paul Meyer Sunny Becker
Environmental Permitting Manager Site Manager
Port of Seattle Washington State Department of Ecology
2711 Alaskan Way 3190 160th Avenue SE
Seattle, Washington 98121 Bellevue, WA 98008
206-787-3127 425-649-7187
4. Date checklist prepared:
December, 2015
5. Agency requesting checklist:
Washington State Department of Ecology (Ecology)
6. Proposed timing or schedule (including phasing, if applicable):
In 1991, Ecology, and the Port of Seattle (Port), entered into a legal agreement in the form of an
Agreed Order (AO). This AO specified that the Port shall prepare and submit a final remedial
investigation and feasibility study (RI/FS) for the site. A 2013 RI/FS was prepared to update the status
of petroleum contamination at the site and to identify a final, preferred remedial action. The
requirements under the 1991 Agreed Order were completed to Ecology’s satisfaction in 2013.
An amendment to the AO requires the Port to prepare a draft Cleanup Action Plan (CAP) and an
Environmental Checklist in accordance with the State Environmental Policy Act (SEPA) process. The
checklist is essential in determining the environmental impacts anticipated from the CAP proposed for
the site. This document is the SEPA checklist.
Ecology conducted a 30-day public comment period for the CAP and RI/FS in the second quarter of
2015. Final design and cleanup will commence once the final CAP is approved under a new Consent
Decree (CAP CD). This schedule anticipates the design and construction of the cleanup system will
occur during the 2018 to 2019 timeframe. Ongoing operation of the below ground systems will occur
over 10 years in conjunction with long term monitoring.
1
Implementation of Cleanup Action Plan (CAP)
T30 Cleanup Site
December 15, 2015
Page 2 of 16
Cleanup Action Task Estimated Completion Date
Public Review of Draft CAP and CD Q2 2015 (actual)
Finalize CAP Q2 2016
Finalize Consent Decree (CAP CD) 6 months from CAP finalization
Draft and Finalize Engineering Design 18 months from CAP CD effective
Report date
Cleanup Action Construction 2018-2019
Operation -AS/SVE and LNAPL recovery 2018-2028
30 years from construction
Monitoring completion
7. Do you have any plans for future additions, expansion, or further activity related to or connected with
this proposal? If yes, explain.
The Port will maintain the project area in a manner consistent with the terms of the CAP CD
following implementation of the cleanup remedy. The site is currently operated as an active marine
cargo facility, a use that is not expected to change in the future. As an active terminal, the site is
currently paved and fenced and access is restricted to industrial adults with appropriate
identification and clearance. The Port will coordinate with Ecology as required by the restrictive
environmental covenant so that the site remains protective of human health and the environment.
8. List any environmental information you know about that has been prepared, or will be prepared,
directly related to this proposal.
The following documents are related to this proposal:
x Ecology, 1991. In the Matter of Remedial Action by: Port of Seattle Agreed Order: Terminal
30. Effective Date: August 30, 1991.
x GeoEngineers, Inc., 1998. Terminal 30 Final Report Remedial Investigation/ Feasibility Study.
Prepared for the Port of Seattle. December.
x Ecology, 2013. First Amendment to Agreed Order: Terminal 30. Port of Seattle. Effective
Date: October 23, 2013.
x Pacific Groundwater Group, 2013. Terminal 30 Remedial Investigation / Feasibility Study.
November 2013.
x WA Department of Ecology, 2015. Cleanup Action Plan, Port of Seattle Terminal 30.
December 15, 2015.
9. Do you know whether applications are pending for governmental approvals of other proposals directly
affecting the property covered by your proposal? If yes, explain.
The CAP received public comment and review in Q2 2015 with final CAP anticipated in 2016 Q2.
The CAP will direct the work to meet CAP CD remedial requirements.
10. List any government approvals or permits that will be needed for your proposal, if known.
Remedial actions at a facility under an AO are exempt from state and local government permits or
approvals for the remedial actions. Ecology ensures substantive compliance with requirements of
state and local authorization and permits.
2
Implementation of Cleanup Action Plan (CAP)
T30 Cleanup Site
December 15, 2015
Page 3 of 16
11. Give brief, complete description of your proposal, including the proposed uses and the size of the project
and site. There are several questions later in this checklist that askyou to describe certain aspects ofyour
proposal. You do not need to repeat those answers on this page. (Lead agencies may modify thisform to inclide
additional specific information on project description.)
The Port of Seattle is proposing a cleanup action for the T30 site (Figure 1) to fulfill requirements
of Ecology’s proposed CAP and subsequent CAP CD. The Ecology-preferred cleanup action plan .
and is described in the CAP, which was prepared by the Port with Ecology review.
The selected alternative described in the CAP focuses on approximately 7 acres in the northern
portion of the larger 33.9 acre Terminal 30 property. Cleanup actions at the T30 site will include
construction and operation of an air sparging/soil vapor extraction (AS/SVE) treatment system, a
non-aqueous phase liquid (LNAPL) product recovery system, long-term compliance monitoring,
and institutional controls (Figure 2). :
The AS/SVE system injects pressurized air into contaminated groundwater enabling the soluble
hydrocarbons to transition from a water-dissolved phase to a vapor phase in the injected bubbles.
The injected air and contaminated vapor is extracted from the subsurface through vacuum pipes
installed in soil above the water table that transport the vapors to a treatment system above ground.
The AS/SVE system’s primary purpose is to reduce the concentrations of contaminants in
groundwater to below state cleanup levels. AS/SVE is most effective on lighter petroleum mixtures
such as gasoline. The AS/SVE system will consist of approximately 20 sparge wells, three soil
for utilities to connect the system
vapor extraction trenches, one equipment shed, and trenching
components. The AS/SVE system will include two phases: phase 1 will include 14 wells to be
activated upon system completion; phase 2 will consist of 6 additional air-sparge wells to be
activated after completion of LNAPL recovery.
The LNAPL recovery system will include 10 new extraction wells. A vactor truck will apply a
vacuum to these wells to recover total fluids (includes groundwater, dissolved petroleum in the
groundwater, and free-phase LNAPL) from each extraction well. LNAPL recovery operations will
continue at each recovery well (anticipated for about 5 to 10 years) until equilibrium LNAPL
thicknesses measured in wells are 0.01-feet or less.
The compliance monitoring phase of the project will assess the effectiveness of remediation efforts.
Specified wells will be monitored for an estimated 30 years after remediation efforts are completed.
Any deviations from compliance will be documented and preventive actions implemented.
Institutional controls will prevent contact with subsurface soil and groundwater contamination by
maintaining an asphalt pavement cover over the treatment area as a protective barrier and by
establishing procedures that prevent exposure below the asphalt cap without appropriate health and
safety procedures and Ecology notification.
12. Locationof the proposal. Give sufficient information for a person to understand the precise location of
if any, and section, township, and range, if known. Ifa
your proposed project, including a street address,
proposal would occur over a range of area, provide the range or boundaries of the site(s). Provide a legal
description, site plan, vicinity map, and topographic map, if reasonably available. While you should submit
to duplicate maps or detailed plans submittedwith
any plans required by the agency, you are not required
any permit applications related to this checklist.
Terminal 30 is located at 2715 E Marginal Way South, Seattle, Washington 98134. It is located on the
East Waterway that drains directly to Elliot Bay and the Puget Sound. The approximate latitude and
longitude of the site is 47.579 by -122.34013. The Township /Range/Section is 24N/4E/7 respectively
Implementation of Cleanup Action Plan (CAP)
T30 Cleanup Site
December 15, 2015
Page 4 of 16
(Figure 1). T30 is bordered on the north by an area of public shoreline access to the East
Waterway, on the east by East Marginal Way South, on the south by the southern portion of T30,
and on the west by the East Waterway. The East Waterway is an operable unit of the Harbor Island
Superfund Site as ordered by the U.S. Environmental Protection Agency (EPA).
The 2013 RI/FS and this CAP focus on approximately 7 acres in the northern portion of the larger
33.9 acre T30 property. The term “T30 site” or “site” refers to the extent of petroleum
contamination in the northern portion of T30, inclusive of light non-aqueous phase liquid (LNAPL),
soil, and groundwater contamination (Figure 2).
B. ENVIRONMENTAL ELEMENTS
1) Earth
a) General description of the site (circle one) FlaDrolling, hilly, steep slopes, mountainous,
other.....
The site is generally flat and entirely paved by asphalt.
b) What is the steepest slope on the site (approximate percent slope)?
The entire site is comprised of impervious surface with very little elevation change. The maximum
slope at the site stays within the range of 2% to 5%. The elevation change from the east edge of the
property to the west edge does not exceed +/-7 feet.
What generaltypes of soils are found on the site (for example, clay, sand, gravel, peat,
muck)? If you know the classification of agricultural soils, specify them and note any prime
farmland.
Studies undertaken by the Port at T30 in general have identified several geologic units. Most of T30
is covered with undifferentiated fine-grained fill material designated as the “Shallow Sand Unit”
that overlies native glacial sediment. The fill material layer extends to depths of 15- to 20-feet
below ground surface in the cleanup vicinity. The fill material was taken from upland sources as
well as dredging material from the construction of Harbor Island in the Lower Duwamish
Waterway. Groundwater levels at the site generally range from 8- to 9-feet below ground surface.
d) Are there surface indications or history of unstable soils in the immediate vicinity? If so,
describe.
No
Describe the purpose, type, and approximate quantities of any filling or grading proposed.
Indicate source of fill.
An air sparging/soil vapor extraction (AS/SVE) treatment system will be installed to reduce
contaminant mass in the subsurface soil and groundwater. The air sparging well network will
include 20, 2-inch diameter sparge wells, installed to a depth of approximately 25 feet below
ground surface. Well screens will be installed in the lower 2 feet of the sparge wells.
Soil vapor extraction trenches will be constructed by placing a horizontal PVC pipe running below
ground surface in trenches parallel to air sparging well alignments. A narrow, shallow trench for
electric utilities and air-supply and vapor return piping will connect the AS/SVE system to an
equipment shed.
Implementation of Cleanup Action Plan (CAP)
T30 Cleanup Site
December 15, 2015
Page 5 of 16
The LNAPL recovery system will consist of 10 new extraction wells, each ofwhich will be
approximately 15-feet deep. New recovery wells will be constructed of 4-inch diameter Schedule
40 PVC in a 12-inch borehole.
AS/SVE system well installation will produce approximately 15 cubic yards of soil cuttings. These
cuttings will be profiled for soil disposal and sent off-site to an appropriate and Ecology-approved
disposal facility, likely a Subtitle D landfill. The wells will be decommissioned as per Washington
State regulations (Washington Administrative Code [WAC] 173-160) when they are no longer needed
for remediation.
Approximately 1,100 lineal feet of trenching is expected for utility placement and the SVE
trenches, each about 5 feet deep. In total, an estimated 550 cy of material will be excavated for the
utility and SVE trenches. All excavated materials will be evaluated as to their presence of
. contamination and geotechnical suitability. Based on this evaluation, material will either be
disposed of offsite at an appropriate and Ecology-approved disposal facility, or re-used as fill to
cover the utility and pipes. Native fill material purchased from sand and gravel vendors from offsite
sources may be required to backfill utility trenches and SVE trenches to replace any contaminated
soils encountered during excavation.
f) Could erosion occur as a result of clearing, construction, or use? If so, generally describe.
The site is located in an urban environment; the erosion hazard is slight before and after
construction because all areas to be affected by this cleanup action are currently and will be covered
with impervious surfaces. Construction associated with planned cleanup could have erosion impacts
on soils exposed during construction and temporary soil stockpiles needed during construction.
Some migration of sediment could occur over short distances within the work area in rainy
conditions.
g) About what percent of the site will be covered with impervious surfaces after project
construction (for example, asphalt or buildings)?
The entirety of the cleanup site is now covered with asphalt. An asphalt surface will be reapplied
over the trenches after installation.
a) Proposed measures to reduce or control erosion, or other impacts to the earth, if any:
During construction, temporary erosion and sediment control measures and Best Management Plans
(BMPs) meeting the substantive requirements of the City of Seattle stormwater control and grading
regulations and the Construction General National Pollutant Discharge Elimination System
(NPDES) permit will be implemented as necessary to control erosion. Any exposed soils will be
within an excavated area, below grade, and unlikely to cause off-site sediment transport. Any
stockpiled materials from the project will be contained or covered using appropriate erosion control
BMPs.
2) Air
a) What types of emissions to the air would result from the proposal (i.e., dust, automobile,
odors, industrial wood smoke) during construction and when the project is completed? If
any, generally describe and give approximate quantities if known.
Air emissions are expected from the following sources: emissions from construction equipment,
fugitive dust during trenching and filling, and VOC-impacted vapor from air sparging (AS) and soil
vapor extraction (SVE) process.
Implementation of Cleanup Action Plan (CAP)
T30 Cleanup Site
December 15, 2015
Page 6 of 16
Air sparging increases the rate of volatilization and potential for migration of VOC-impacted vapor
to human and/or ecological receptors at potential levels of concern. Exhaust vapors from the
AS/SVE system will require treatment prior to discharge because of elevated volatiles. The system
will be equipped with emissions control equipment (thermal oxidizer or activated carbon
adsorption).
During the three months of construction, approximately 150 diesel truck trips are expected for
deliveries and removal of trenching material. A truck-mounted drill rig will install the 30 wells for
LNAPL and air sparging system over approximately 10 days. A diesel-powered backhoe will
construct the utility and SVE trenches.
During the operation of the AS/SVE system, support vehicles transporting field operators and
monitoring technicians will visit the site on an average of 10- to 12-times a year. These visits will
decline over time as the product mass is reduced according to schedule in the CAP.
LNAPL will be recovered from the wells by vacuum-truck total fluid recovery. Vacuum enhanced
recovery will be conducted for approximately 1- to 2-hours at each well event. Each recovery event
will last 12- to 24-hours. Well recovery events are scheduled bi-monthly for the first five years of
operation, reducing to quarterly and then semi-annually over the remaining 5 years ofvacuum
enhanced recovery.
Air emissions could result from exposure related to future site development activities. However,
there are currently no plans for the property after the paving is completed and no way to estimate
what air emissions may be associated with future use of the property.
b) Are there any off-site sources of emissions or odor that may affect your proposal? If so,
generally describe.
No
¢) Proposed measures to reduce or control emissions or other impacts to air, if any:
Fugitive dust will be controlled using best management practices such as spraying exposed soil and
storage areas with water during dry periods and/or covering exposed earth stockpiles and loads of
excavated material being transported from the site.
Vehicular emissions associated with construction are anticipated to be short-term in nature.
Measures to minimize vehicular emissions would be implemented as required and may include:
o Requiring contractors to use best available control technologies.
e Proper vehicle maintenance.
¢ Minimizing vehicle and equipment idling.
Measures will be taken to minimize emissions and worker exposure to contaminated soil and
vapors exposed during construction and remediation. A Health and Safety Plan (HASP) developed
for the project will address potential worker exposure to air emissions resulting from construction
activities. The HASP will include a vapor monitoring component and all workers on the project will
be required to adhere to the elements of the HASP to limit potential exposure to air emissions.
Pollution control devices will be installed to mitigate impacts from AS/SVE exhaust. Exhaust
vapors from the SVE system will require treatment prior to discharge because of elevated volatiles.
Initial pre-treatment vapor concentrations are likely to exceed 1,000 parts per million by volume
(ppmV), above which thermal oxidation is generally the most cost-effective treatment technology.
Thermal oxidation air treatment uses either a catalytic oxidizer or propane flame to combust
Implementation of Cleanup Action Plan (CAP)
T30 Cleanup Site
December 15, 2015
Page 7 of 16
volatile laden exhaust vapors; thermal oxidizers typically achieve approximately 99% reduction in
VOC concentrations. SVE exhaust vapor concentrations will be periodically monitored in the
airstream before treatment to estimate mass loss from the SVE system. The system will be
transitioned to carbon filtration as concentrations decrease to below 1,000 ppm. Exhaust treatment
equipment will be specified in the engineering design report.
After construction, the cleanup area will be covered with impervious surfacing and institutional
controls will be implemented to minimize exposure fo workers or trespassers.
3) Water
a) Surface Water:
1) Is there any surface water body on or in the immediate vicinity of the site (including
year-round and seasonal streams, saltwater, lakes, ponds, wetlands)? If yes, describe type
and provide names. If appropriate, state what stream or river it flows into.
The East Waterway of the Duwamish River is directly to the west of the project location.
2) Will the project require any work over, in, or adjacent to (within 200 feet) the described
waters? If yes, please describe and attach available plans.
No overwater work is anticipated for this cleanup. No direct negative impacts are anticipated due to
the minimal land disturbing activity and restriction ofwork to wells and shallow trenches protected
by impervious surfaces after construction.
3) Estimate the amount of fill and dredge material that would be placed in or removed
from surface water or wetlands and indicate the area of the site that would be affected.
Indicate the source of fill material. :
No fill or dredge material will be placed in or removed from surface waters or wetlands.
4) Will the proposal require surface water withdrawals or diversions? Give general
description, purpose, and approximate quantities if known.
No
5) Does the proposal lie within a 100-year floodplain? If so, note location on the site plan.
No
6) Does the proposal involve any discharges of waste materials to surface waters? If so,
describe the type of waste and anticipated volume of discharge.
The proposal does not involve any discharges of waste materials to surface waters.
b) Ground Water:
1) Will ground water be withdrawn, or will water be discharged to ground water? Give
general description, purpose, and approximate quantities if known. {help]
Groundwater will be withdrawn during LNAPL total fluid recovery events. Total fluid extraction
volumes are expected to average approximately 1,500-gallons per event with some variation
depending on the saturation and porosity of the aquifer immediately around each recovery well, and
time spent at each recovery well.
The project will not have water discharges to groundwater.
Implementation of Cleanup Action Plan (CAP)
T30 Cleanup Site
December 15, 2015
Page 8 of 16
2) Describe waste material that will be discharged into the ground from septic tanks or
other sources, if any (for example: Domestic sewage; industrial, containing the
following chemicals. .. ; agricultural; etc.). Describe the general size of the system, the
number of such systems, the number of houses to be served (if applicable), or the number of
animals or humans the system(s) are expected to serve.
No waste material will be discharged into the ground.
Water runoff (including stormwater):
Remediation system installation and operation will not generate new surface water runoff,
Stormwater and surface runoff on the site is managed by a permitted stormwater system.
D Describe the source of runoff (including storm water) and method of collection
and disposal, if any (include quantities, if known). Where will this water flow?
Will this water flow into other waters? If so, describe.
Stormwater generated by precipitation during construction that contacts contaminated material will
be collected and detained within the work area until tested and profiled for appropriate disposal.
Incident precipitation and runoff on existing paved surfaces will be allowed to flow to the existing
on-site permitted storm water system. Analytical testing performed on detained stormwater will be
focused on sanitary discharge requirements or off-site disposal requirements. Other stormwater
management controls include requirements to minimize or eliminate stormwater contact to exposed9
potentially contaminated soils by:
1. covering stockpiles to protect from weather;
2. minimizing the footprint of the open work area;
3. protecting existing catch basin inlets; and
4. sweeping the ground surface in work areas to avoid migration of soils.
A construction Stormwater Pollution Prevention Plan/Temporary Erosion and Sedimentation
Control Plan will be prepared that will detail the proposed plan for stormwater management,
containment, and control; protection of catch basin inlets; and methods of covering soil stockpiles.
Some stormwater falling into the excavated area may infiltrate into the ground.
2) Could waste materials enter ground or surface waters? If so, generally describe.
No waste materials are anticipated to enter the ground or surface waters. Liquid contaminated
material will be removed as a result of the cleanup process reducing the amount of contamination in
groundwater at the site.
d) Proposed measures to reduce or control surface, ground, and runoffwater impacts, if any:
All excavated and fill areas will be covered with asphalt to prevent surface water or precipitation
from coming in contact with any remaining contaminated soils. During construction, all stormwater
from the construction site will be collected, routed, and treated in accordance with Ecology and
City of Seattle requirements. Best management practices will be implemented during construction
to minimize surface water, groundwater, and runoff water impacts. The proposed cleanup actions
are designed to prevent and reduce contaminant mass in soil and groundwater.
Scientists at the University of Washington Climate Impacts Group project that sea level will rise in
the Puget Sound region as a result of climate change. In a range of possible scenarios, the medium
estimate is that the sea level will rise approximately six inches by 2050 (Ecology's August 19, 2010
news release “Ecology helps communities plan for rising sea level”). The post-cleanup monitoring
Implementation of Cleanup Action Plan (CAP)
T30 Cleanup Site
December 15, 2015
Page 9 of 16
of groundwater was projected to continue for a period of 30 years, during which time the projected
medium estimate of sea level rise would be less than 6 inches. Minimal changes in groundwater
levels that might be associated with a 6-inch rise in water levels are not anticipated affect fuel
product recovery or air sparging operations. The monitoring phase of the groundwater sampling
and adaptively manage
program will monitor potential changes in the chemistry of groundwater
changes caused by-unanticipated seawater rise.
4) Plants
a) Check or circle types of vegetation found on the site:
No vegetation exists where the work will occur on the site.
deciduous tree: alder, maple, aspen, other
evergreen tree: fir, cedar, pine, other
shrubs
grass
pasture
crop or grain
wet soil plants: cattail, buttercup, bullrush, skunk cabbage, other
water plants: water lily, eelgrass, milfoil, other
other types of vegetation
b) What kind and amount of vegetation will be removed or altered?
No vegetation will be removed or altered.
¢) List threatened or endangered species known to be on or near the site.
No threatened or endangered plant species are known to occur on the T30 site.
d) Proposed landscaping, use of native plants, or other measures to preserve or enhance
vegetation on the site, if any:
None
3) Animals
a) Circle any birds and animals which have been observed on or near the site or are known to
be on or near the site:
birds:(hawk;heron, eagle songbirds.other: osprey, geese, ducks
mammals: deer, bear, elk, beaver, other: raccoons
fish: bass salmon,trout herringgshellfishy other:
b) List any threatened or endangered species known to be on or near the site.
No threatened or endangered animal species are known to occur on the site. Elliott Bay is known to,
or may, be used by federally listed animal species including the Georgia Basin/Puget Sound
Distinct Population Segments (DPSs) of bocaccio rockfish (Sebastes paucispinis), canary rockfish
(S. pinniger), and yelloweye rockfish (S. Ruberrumis); the Puget Sound Evolutionary Significant
Unit (ESU) of Chinook salmon (Oncorhynchus tshawytscha); the Puget Sound DPS of steelhead
Implementation of Cleanup Action Plan (CAP)
T30 Cleanup Site
December 15, 2015
Page 10 of 16
(O. mykiss); and the Coastal-Puget Sound DPS of bull trout (Salvelinus confluentus). No additional
Washington State listed species are known to occur in Elliott Bay.
¢) Is the site part of a migration route? If so, explain.
The site is within the Pacific Flyway, a major north-south route of travel for migratory birds in the
Americas.
d) Proposed measures to preserve or enhance wildlife, if any:
BMPs will be employed to prevent materials resulting from remedial activities from entering the
East Waterway and Elliot Bay or being available to terrestrial species.
6) Energy and natural resources
a) What kinds of energy (electric, natural gas, oil, wood stove, solar) will be used to meet
the completed project's energy needs? Describe whether it will be used for heating,
manufacturing, etc.
The site will require the use of electrical utilities already located on the site. These will drive the
blower and pump system essential to the AS/SVE system. In addition to electricity usage,
gasoline/diesel generators may be used at the site as a backup system. The site has a substantial
electrical system in place for day to day operations at the Terminal.
b)} Would your project affect the potential use of solar energy by adjacent properties?
If so, generally describe.
No
¢) What kinds of energy conservation features are included in the plans of this proposal?
List other proposed measures to reduce or control energy impacts, if any:
None
7) Environmental health
a) Are there any environmental health hazards, including exposure to toxic chemicals, risk
of fire and explosion, spill, or hazardous waste that could occur as a result of this proposal?
If so, describe.
The proposed CAP has been designed to protect human health and the environment from site-
related contamination. The nature of this work, however, may expose workers to levels of toxic and
carcinogenic vapor, soil, and groundwater during construction. Post-construction air sparging and
soil venting include a vapor treatment system to degrade and remove harmful compounds from the
extracted air. Exhaust vapors from the SVE system will require treatment prior to discharge because
of elevated volatiles.
To address potential risks to workers, a HASP will be developed prior to and implemented during
construction of the project. Public safety concerns have been considered during the development of
the Draft CAP and safeguards are included as part of the project to minimize risks to the public.
Access to and from the areas to be remediated will be controlled to limit the potential for the public
to enter the site.
b) Describe special emergency services that might be required.
No special emergency services are required for the project.
¢) Proposed measures to reduce or control environmental health hazards, if any:
10
Implementation of Cleanup Action Plan (CAP)
T30 Cleanup Site
December 15, 2015
Page 11 of 16
The purpose of the project is the reduction of contaminant mass in soil and groundwater. The HASP
for the project will be strictly followed throughout construction to minimize human and
environmental exposure to contaminated soils and groundwater. Site access will be controlled to
prevent public access and limit public safety concerns.
8) Noise
a) What types of noise exist in the area which may affect your project (for example:
traffic, equipment, operation, other)?
The noise generated at the site consists of industrial container transportation and cargo handling at
Terminal 30, vessel traffic in the Duwamish Waterway and traffic noise from Alaskan Way and State
Route 99. These activities will continue during construction and post-construction cleanup air
sparging operations, and noise from these activities is not expected to affect the project.
b) What types and levels of noise would be created by or associated with the project on a
short-term or a long-term basis (for example: traffic, construction, operation, other)?
Indicate what hours noise would come from the site.
Noise from worker vehicle traffic, support vehicle, and construction equipment including a backhoe
for trenching and hollow stem auger for well drilling will occur during construction of the project.
Such noise could increase the general drone from activity during construction. Noise generated by
construction will be in compliance with the timing restrictions and the noise limits included in the
Seattle noise regulations, Seattle Municipal Code [SMC] 25.08.
The AS/SVE will operate until groundwater monitoring meets the shutdown criteria. The air sparge
will be
compressor, soil vapor extraction blower, and exhaust gas treatment/filtering equipment
housed in an on-site equipment shed near the wells. Noise generated from the system will be
mitigated by the building enclosure. The system is expected to operate for 5 years beginning at
construction completion.
LNAPL will be recovered from the wells by vacuum-truck total fluid recovery. Vacuum enhanced
recovery will be conducted for approximately 1- to 2-hours at each well event. Each recovery event
will last 12- to 24-hours. Well recovery events are scheduled bi-monthly for the first five years of
operation, reducing to quarterly and then semi-annually over the remaining 5 years of vacuum
enhanced recovery. Vacuum trucks are significant contributors to the noise environment. However,
the activity will occur within an industrial, marine container cargo terminal.
¢) Proposed measures to reduce or control noise impacts, if any:
Noise generated by construction and during operation of the system will comply with the timing
restrictions and the noise limits included in the Seattle noise rule (SMC 25.08). These regulations
limit hours of construction and place limits on noise levels from construction impacts and ongoing
operations.
9) Land and shoreline use
a) What is the current use of the site and adjacent properties?
The Site is a shipping container transfer and storage facility. Adjacent facilities, including T-25 and
T-46, are also used for container and berthing activity for the Port.
b) Has the site been used for agriculture? If so, describe.
The site has never been used for agriculture.
11
Implementation of Cleanup Action Plan (CAP)
T30 Cleanup Site
December 15, 2015
Page 12 of 16
¢) Describe any structures on the site.
Multiple structures exist on the entirety of T30; however, these structures will not be impacted by
the remediation activities. The T30 Vessel Tower, used for daily crane operations at the Terminal is
located adjacent to the site.
d) Will any structures be demolished? If so, what?
No structures will be demolished.
¢) What is the current zoning classification of the site?
General Industrial 1 (IG1) - U/85
) What is the current comprehensive plan designation of the site?
Industrial Area
g) IH applicable, what is the current shoreline master program designation of the site?
The shoreline of the East Waterway is designated Urban Industrial.
h) Has any part of the site been classified as an "environmentally sensitive’ area? If so,
specify.
The site itself has not been classified as an environmentally sensitive area. However, the adjacent
East Waterway is a Superfund site as designated by the EPA.
i) Approximately how many people would reside or work in the completed project?
No people would reside or work in the area under this proposal. Future development of the site may
include as of yet unidentified industrial uses, parking, or light open storage of equipment. Future
- uses will be addressed under a separate SEPA process when those uses are identified.
j) Approximately how many people would the completed project displace?
None
kK) Proposed measures to avoid or reduce displacement impacts, if any:
None
I) Proposed measures to ensure the proposal is compatible with existing and projected land
uses and plans, if any:
The proposal will remediate an existing industrial area that will remain an industrial area after
construction. Existing and projected land uses for the area are also industrial in nature. Therefore,
the project is compatible with existing and projected land uses and plans.
10) Housing
a) Approximately how many units would be provided, if any? Indicate whether high, middle,
or low-income housing.
None
b) Approximately how many units, if any, would be eliminated? Indicate whether high,
middle, or low-income housing.
None
12
Implementation of Cleanup Action Plan (CAP)
T30 Cleanup Site
December 15, 2015
Page 13 of 16
¢) Proposed measures to reduce or control housing impacts, if any:
None
11) Aesthetics
a) What is the tallest height of any proposed structure(s), not including antennas; what is
the principal exterior building material(s) proposed?
A small utility building less than 12 feet in height will be constructed to house monitoring
equipment, compressors, and air quality equipment.
b) What views in the immediate vicinity would be altered or obstructed?
None
¢) Proposed measures to reduce or control aesthetic impacts, if any:
None
12) Light and glare
a) What type of light or glare will the proposal produce? What time of day would it mainly
occur?
No light or glare would be produced from the project.
b) Could light or glare from the finished project be a safety hazard or interfere with views?
No
¢) What existing off-site sources of light or glare may affect your proposal?
None
d) Proposed measures to reduce or control light and glare impacts, if any:
None
13) Recreation
a) What designated and informal recreational opportunities are in the immediate vicinity?
Jack Perry Memorial Park is a 1.1 acre park located directly north ofT30 and south of Terminal-46.
The amenities include 120 feet of shoreline access, views of T30 and T-18 crane operations, views of
the U.S. Coast Guard station, and parking facilities.
b) Would the proposed project displace any existing recreational uses? If so,describe.
No recreational uses would be displaced from remediation activities.
¢) Proposed measures to reduce or control impacts on recreation, including recreation
opportunities to be provided by the project or applicant, if any:
None.
14) Historic and cultural preservation
a) Ave there any places or objects listed on, or proposed for, national, state, or local
preservation registers known to be on or next to the site? If so, generally describe.
13
Implementation of Cleanup Action Plan (CAP)
T30 Cleanup Site
December 15, 2015
Page 14 of 16
Two sites of historical importance occur north of the site. The first site, known as the ‘First Service
Station Site’ (Smithsonian #: 45KI100132), is nationally recognized as the first fuel filling station
directly dispensing gasoline to motorists. The site is approximately on the North East side ofT30,
address: Holgate Street and Alaskan Way, and was built in 1907 for the Standard Oil Company
(Chevron) and declared a historical building in 1970. No negative effects from the cleanup activities
are expected at the historical station site.
The second site is characterized as the Pacific Maritime Institute (Historic name: California Ink
Company) and sits on the North side of T30. Although it shows up on the Washington Department of
Archaeology & Historic Preservation’s database, the site carries an ‘Unable to Determine’ tag on its
criteria to meet the requirements of a national historic property. The only reason it is noted in this
document is because of its appearance on the WISAARD database. Regardless, no adverse effects are
anticipated at the property due to cleanup activities.
b) Generally describe any landmarks or evidence of historic, archaeological, scientific, or
cultural importance known to be on or next to the site.
None. Undifferentiated fine-grained fill material designated as the “Shallow Sand Unit” overlies
native glacial sediment. The fill material layer extends to depths of 15 to 20 feet below ground
surface in the cleanup vicinity. Excavations will stop at native soil level where pre-contact or ethnohistoric
archaeological materials could be encountered.
©) Proposed measures to reduce or control impacts, if any:
No measures are proposed to reduce or control impacts to cultural or historic resources.
15) Transportation
a) Identify public streets and highways serving the site, and describe proposed access to the
existing street system. Show on site plans, if any.
The site is accessed via the Alaskan Way Viaduct and E Marginal Way S. S Stacy St. provides direct
access to the site along with S Lander St. Because the entirety of T30 is paved for everyday operations
of a functioning container terminal, direct access to the site is not an issue.
b) Is site currently served by public transit? If not, what is the approximate distance to the
nearest transit stop?
The site is not directly served by any public transportation system. The closest bus stop is found at the
corner of 1% Avenue South and S Hanford St. From there, it is approximately a 0.3 mile walk to the
site.
How many parking spaces would the completed project have? How many would the
project eliminate?
The project would neither create nor eliminate parking spaces.
d) Will the proposal require any new roads or streets, or improvements to existing roads or
streets, not including driveways? If so, generally describe (indicate whether public or
private).
~The proposal will not require any new roads, streets, or improvements to existing public roadways.
Will the project use (or occur in the immediate vicinity of) water, rail, or air
transportation? If so, generally describe.
No
14
Implementation of Cleanup Action Plan (CAP)
T30 Cleanup Site
December 15, 2015
Page 15 of 16
f) How many vehicular trips per day would be generated by the completed project? If known,
indicate when peak volumes would occur.
During the three months of construction, approximately 150 diesel truck trips are expected for
deliveries and removal of trenching material. A truck mounted drill rig will bore the 24 wells for
LNAPL and air sparging system for approximately 10 days. A diesel powered backhoe will
construct the utility and SVE trenches.
During the operation of the AS/SVE system, one to two support pickup trucks and monitoring
equipment trucks transporting field operators and monitoring technicians will visit the site on an
average of 12 times a year over a period of up to 10 years. These visits will decline over time as the
product mass is reduced according to schedule in the CAP.
The LNAPL will be recovered from the wells by vacuum-truck total fluid recovery. Vacuum
enhanced recovery will be conducted for approximately 1 to 2 hours at each well event. Each
recovery event will last 12- to 24-hours. Well recovery events are scheduled bi-monthly for the first
five years of operation, reducing to quarterly and then semi-annularly over the remaining 5 years of
vacuum enhanced recovery.
g) Proposed measures to reduce or control transportation impacts, if any:
None. The number of vehicles from project actions is inconsequential to total vehicle traffic entering
and exiting the site.
16) Public services
a) Would the project result in an increased need for public services (for example: fire
protection, police protection, health care, schools, other)?If so, generally describe.
No.
b) Proposed measures to reduce or control direct impacts on public services, if any.
None.
17) Utilities
a) Circle utilities currently available at the site:
(electricity hatural gasET Se TE water, a
:
;efuse ser vice, telephone;jsanitary sewer;septic system,aT a OT
other
b) Describe the utilities that are proposed for the project, the utility providing the service,
and the general construction activities on the site or in the immediate vicinity which might
be needed.
No new utilities are proposed for the project. Existing utilities will be modified to supply power to
utility shed to run compressors and blowers associated with AS/SVE system.
15
Implementation of Cleanup Action Plan (CAP)
T30 Cleanup Site
December 15, 2015
Page 16 of 16
C. SIGNATURE
The above answers are true and complete to the best ofmy knowledge. I understand that the lead
agency is relying o m to make its decision.
Signature: (
Name of signee: Paul Meyer
Position and Agency/Organization: Port of Seattle, Manager, Environmental Permitting and
Compliance
Date Submitted: -December 15, 2015
16
32 3 3
Elliott Bay 05
06 Terminal 46 ¦ ¨ § 90
04
S ROYAL
BROUGHAM WAY
Slip 36
S AT
LANTIC ST
J ack
P erry C
P ark ALASKAN WAY S S MASSA
HUSETTS ST
« ¬ 9 9
S HOLGATE ST AVE S
Jack 6TH
Blo ck S WALKER ST
Park
E T24N R4E Terminal 18 Terminal 1ST AVE S 4TH AVE S 0 9
07 08
Terminal 10 0
Ha rbor S S
TACY ST R3 3 4 N West Waterway T 2 12 Is l and
S
Terminal 5 S LANDER ST
East Waterway lip 27 EAST MARGINAL WAY S S FO
REST ST
S HAN
FORD ST AIRPORT WAY S
T ermin al
18 Park
ST
E
SW SPOKAN
Ter minal
13 1 02
P ark 17
18
Duw
16
a Terminal
m §¨¦5
106
K:\PONY\T30\GIS\mxds\VicinityMap.mxd , 4/29/2014 ish Waterway Terminal
Terminal 13 ¬ « 99
1 0 7 Par k Maple wo od
Playf iel d
24 Kello gg 20 21
Islan d 19
Slip 1
¨ § ¦ 5
Site Boundary Figure 1
¬«99
Terminal 30 « ¬ 520 Site Location Map
Sections Seattle
0 Feet 2,000 §¨¦90
0 Miles 0.5 K Port of Seattle
¬«509§¨¦ 5 Terminal 30
Figure 2 Site Map Port of Seattle Gaging/Recovery Well Water Quality Monitoring Well Site Extent of Contamination Soil Areas Not Associated with T- 30 Site LNAPL Extraction Well with Radius of Influence Phase I Air Sparge Well with Radius of Influence Phase I SVE Pipe in Trench Future Phase II AS/SVE Expansion Utility Trench Term inal 30 ! A ! A ! . Remediation Elements MW-76A ! A North Substation ! A Soil Area MW-90 ! A 100 ! A MW-87A Equipment Shed West Vault MW-52A MW-91 K 2012 USGS Orthophoto Feet 1:1,000 0 MW-87B ! A ! A MW-49 ! A MW-92 ! A AS-1 ! . MW-86B ! A MW-42 ! A ! . MW-54 ! A MW-89 -3 AS-2 A S ! . ! A ! A MW-86C -4 ! A
A S RW-5A ! . - 5 A S ! A ! . - 6 A S ! . S- 7
! A MW-77
A MW-38 RW-1 ! . MW-58A ! A MW-39 ! A ! A
S -8 . !
A
A S -9 ! . AS-10 ! . AS-11 ! . RW-9
MW-85A ! A
0 Vessel To w er AS-12 ! . ! A
East Waterway MW-85B ! A ! A T3
South Vault Soil Area
AS-13 ! . RW-11A
Scales
! A ! . MW-46 -14 S ! A MW-36 A
k
! A MW-35 Truc
MW-84B ! A MW-45 ! A ! A MW-59 ! A ! A MW-84A MW-64 East Marginal Way S ! A RW-12 attle Office ! A MW-88 MW-81A ! A Port of Se Police
12/3/2015 K:\PONY\T30\GIS\mxds\SiteMap_2014_Fig2.mxd
List of Applicable or Relevant and Appropriate Requirements
- City of Seattle electrical permit or permits for installation of remediation equipment
-
- Puget Sound Clean Air Authority (PSCAA) Air Emission Permit, or Permit Requirements
for discharge from the air sparging system
Limitations of Translatable Documents
PDF files are created with text and images are placed at an exact position on a page of a fixed size.
Web pages are fluid in nature, and the exact positioning of PDF text creates presentation problems.
PDFs that are full page graphics, or scanned pages are generally unable to be made accessible, In these cases, viewing whatever plain text could be extracted is the only alternative.