6b Draft EECA

Lower Duwamish Waterway Superfund Site 
Terminal 117 Early Action Area 


REVISED ENGINEERING EVALUATION/COST ANALYSIS 
DRAFT FINAL 
Prepared for: 
The Port of Seattle 
and 
The City of Seattle 
For submittal to: 
US Environmental Protection Agency, Region 10 
1200 Sixth Avenue 
Seattle, WA 98101 

January 19June 3, 2010 

Prepared by: 


Dalton, Olmsted & Fuglevand, Inc. 
Environmental Consultants

Table of Contents 
List of Tables                                                v 
List of Figures                                              vi 
List of Maps                                              ix 
Acronyms and Abbreviations                              xiii 
1     Introduction                                                  1 
1.1    CERCLA PROJECT PROGRESSION                                    2 
1.1.1     Lower Duwamish Waterway and early action areas               5 
1.1.2     Initial early action area investigations and 2005 EE/CA            5 
1.1.3     2006 time-critical removal action                              6 
1.1.4     Inclusion of the Adjacent Streets                              6 
1.1.5     Dioxin investigations and PCB boundary refinement              6 
1.1.6     Expanded T-117 EAA and the revised EE/CA                   7 
1.2    EE/CA ORGANIZATION                                           8 
2     Site Characterization                                          11 
2.1    SITE DESCRIPTION                                              11 
2.1.1     Location and characteristics                                 11 
2.1.2     Historical activities                                       12 
2.1.3     Current site features                                      15 
2.1.4     Current land use, zoning, ownership, and activities              22 
2.1.5     Physical environment                                     24 
2.1.6     Sensitive ecosystems and habitat                             43 
2.2    PREVIOUS REMOVAL ACTIONS                                     44 
2.2.1     1999 time-critical removal action                             45 
2.2.2     2004 utility corridor cleanout                                46 
2.2.3     2006 time-critical removal action                             47 
2.2.4     Independent cleanup actions in the Adjacent Streets and Residential
Yards Study Area                                48 
2.3    PREVIOUS ENVIRONMENTAL INVESTIGATIONS AND SUMMARY OF
ENVIRONMENTAL DATA                        49 
2.3.1     T-117 Sediment Study Area                                 60 
2.3.2     T-117 Upland Study Area                                  61 
2.3.3     Adjacent Streets and Residential Yards Study Area              64 
2.3.4     Groundwater                                            71 
2.4    RECONTAMINATION ASSESSMENT AREAS                             77 
2.4.1     Basin Oil parcels                                         77 
2.4.2     South Park Marina                                        80 
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3     Streamlined Risk Assessment                                  83 
3.1    CONCEPTUAL SITE MODEL AND PATHWAY IDENTIFICATION               83 
3.1.1     Primary sources                                          84 
3.1.2     Primary release and transport mechanisms                     86 
3.2    STUDY AREA-SPECIFIC TRANSPORT MECHANISMS, RECEPTORS, AND EXPOSURE
PATHWAYS                             88 
3.2.1     T-117 Sediment Study Area                                 88 
3.2.2     T-117 Upland Study Area                                  89 
3.2.3     Adjacent Streets and Residential Yards Study Area  Adjacent Streets
91 
3.2.4     Adjacent Streets and Residential Yards Study Area  Residential
Yards                                       92 
3.3    CONTAMINANTS OF CONCERN SELECTION PROCESS AND RESULTS           93 
3.3.1     Sediment                                               95 
3.3.2     Soil                                                   100 
3.3.3     Groundwater                                          106 
3.3.4     RAA contaminants                                       114 
3.3.5     Summary of streamlined risk assessment                     115 
4     Identification of Removal Action Scope, Goals, and Objectives        119 
4.1    NTCRA SCOPE, GOALS, AND OBJECTIVES                            119 
4.2    REGULATORY REQUIREMENTS AND GUIDANCE                        121 
4.3    REMOVAL ACTION LEVELS                                       122 
4.3.1     Development of sediment removal action levels                123 
4.3.2     Development of soil removal action levels                    129 
4.3.3     Development of groundwater removal action levels             138 
4.3.4     Summary of T-117 EAA removal action levels                 144 
4.4    REMOVAL BOUNDARY DETERMINATION                             147 
4.4.1     T-117 Sediment Study Area                                147 
4.4.2     T-117 Upland Study Area                                 147 
4.4.3     Adjacent Streets and Residential Yards Study Area             148 
5     Recontamination Assessment                                  150 
5.1    OVERALL SOURCE CONTROL STRATEGY                              150 
5.2    POTENTIAL POST-NTCRA RECONTAMINATION SOURCES AND PATHWAYS    151 
5.2.1     Erosion and transport of surface soil                         157 
5.2.2     Stormwater transport                                     161 
5.2.3     Groundwater discharge                                   168 
5.2.4     In-waterway sediment transport and deposition                170 
5.2.5     Surface water transport within the LDW                      172 
5.2.6     Atmospheric deposition                                   172 
5.3    OVERALL SUMMARY AND MONITORING RECOMMENDATIONS             177 

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6     Identification, Evaluation, and Screening of Technologies           181 
6.1    SOIL AND SEDIMENT REMOVAL AND CONTAINMENT TECHNOLOGIES        183 
6.1.1     Land-based technologies                                  184 
6.1.2     Over-water technologies                                  184 
6.2    MATERIAL TREATMENT AND DISPOSAL                              187 
6.3    SUMMARY OF RETAINED TECHNOLOGIES                             195 
7     Removal Action Alternatives                                   197 
7.1    ALTERNATIVE 1: UPLAND SOIL EXCAVATION AND SEDIMENT EXCAVATION/ 
DREDGING COMBINED WITH CAPPING                  201 
7.1.1     Site preparation                                         202 
7.1.2     Soil removal                                            206 
7.1.3     Sediment removal and capping                             218 
7.1.4     Management of excavated and dredged materials              225 
7.1.5     Completion of the removal action and coordination with future site
uses                                           226 
7.1.6     Summary of estimated costs                               227 
7.1.7     Evaluation of Alternative 1                                227 
7.2    ALTERNATIVE 2: UPLAND SOIL REMOVAL AND SEDIMENT EXCAVATION AND
DREDGING                              229 
7.2.1     Site preparation                                         230 
7.2.2     T-117 Upland Study Area and Adjacent Streets and Residential Yards
Study Area removal activities                         230 
7.2.3     T-117 Sediment Study Area removal activities                 230 
7.2.4     Landfill disposal of excavated and dredged materials           231 
7.2.5     Site completion and coordination with future site uses           231 
7.2.6     Summary of estimated costs                               232 
7.2.7     Evaluation of Alternative 2                                232 
7.3    PROJECT COMPLETION OPTIONS                                   232 
8     Comparative Analysis of Removal Action Alternatives               238 
8.1    IMPLEMENTABILITY                                             238 
8.1.1     Technical feasibility and availability                         238 
8.1.2     Administrative feasibility                                 240 
8.1.3     Public involvement                                      241 
8.2    EFFECTIVENESS                                                241 
8.2.1     Overall protection of human health and the environment        241 
8.2.2     Achievement of RAOs                                    241 
8.2.3     Compliance with ARARs and other requirements              242 
8.2.4     Reduction of toxicity, mobility, or volume through treatment     245 
8.2.5     Short-term effectiveness and implementation risk              245 
8.2.6     Long-term effectiveness and permanence                     246 
8.3    COST                                                       248 
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8.4    SUMMARY OF COMPARATIVE ANALYSIS                              249 
9     Recommended Removal Action Alternative and Implementation      252 
9.1    RECOMMENDED REMOVAL ACTION ALTERNATIVE                      252 
9.2    REMOVAL ACTION SEQUENCING AND SCHEDULE                       253 
9.2.1     Sequencing                                             253 
9.2.2     Schedule                                               257 
9.3    NTCRA WORK PLAN DEVELOPMENT                               258 
9.3.1     Health and Safety                                        258 
9.3.2     Site Controls                                            259 
9.3.3     Performance monitoring                                  259 
9.4    ADDITIONAL INFORMATION NEEDS                                 260 
9.4.1     Additional Streets and Yards Study Area information           262 
9.4.2     Additional RAA information                               262 
9.4.3     Additional groundwater and geotechnical information          263 
9.4.4     Refinement of excavation prisms                            263 
9.4.5     Site preparation and constraints                            264 
9.4.6     Coordination of final grade for site restoration transition         264 
9.5    LONG-TERM OPERATION, MAINTENANCE, AND MONITORING PLAN        264 
9.5.1     T-117 Sediment Study Area                                267 
9.5.2     T-117 Upland Study Area                                 267 
9.5.3     Adjacent Streets and Residential Yards Study Area             268 
9.5.4     Long-term OMMP summary                               270 
10   References                                          271 

Appendices 
Appendix A. SOW 
Appendix B. Groundwater 
Appendix C. Data Tables 
Appendix D. Data Management 
Appendix E. COC Screening 
Appendix F. RAA Data Tables 
Appendix G. ARARs and Other Requirements to be Considered 
Appendix H. Risk-Based Disposal Application 
Appendix I. Combined Early Life Stage Adjustments and Soil Exposure Factors
for Residential and Recreational PRG for cPAHsSoil Risk
Calculation Supporting Details 
Appendix J. Cost Details 
Lower Duwamish Waterway Superfund Site:                                  Revised EE/CA 
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Appendix K. Detailed Technology Evaluation 
Appendix L. MIS Variance 
Appendix M. Dioxin Technical Workgroup Presentations 
(Note: Appendices are only provided on CD on inside back cover) 
List of Tables 
Table 2-1.    Summary of 2009 T-117 Upland Study Area catch basin sampling results   17 
Table 2-2.    Summary of previous investigations at T-117 Early Action Area          51 
Table 2-3.    Summary of seep sampling field parameters at T-117 Early Action Area    75 
Table 2-4.    Summary of monitoring well parameters at T-117 Early Action Area       76 
Table 3-1.    Exposure pathways addressed by screening levels                   94 
Table 3-2.    Sediment screening levels                                   95 
Table 3-3.    Sediment COPCs and COCs                                 99 
Table 3-4.    Soil screening levels                                      101 
Table 3-5.    Soil COPCs and COCs in the T-117 Upland Study Area              103 
Table 3-6.    Soil COPCs and COCs for Adjacent Streets                      104 
Table 3-7.    Soil COPCs and COCs for Residential Yards                      106 
Table 3-8.    Groundwater screening levels                                110 
Table 3-9.    Groundwater COPCs and COCs                              114 
Table 3-10.   Summary of exposure pathways and receptors identified in the streamlined
risk assessment                                      116 
Table 3-11.   Summary of COCs identified in the streamlined risk assessment        117 
Table 4-1.    T-117 Sediment Study Area total risks for sediment removal action levels
under the recreational scenario                               125 
Table 4-2.    T-117 Upland Study Area soil removal action levels                 131 
Table 4-3.    T-117 Upland Study Area total risks for soil removal action levels        135 
Table 4-4.    T-117 Adjacent Streets and Residential Yards Study Area total risks for soil
removal action levels                                     138 
Table 4-5.    T-117 Upland Study Area groundwater removal action levels           141 
Table 4-6.    T-117 EAA sediment, soil, and groundwater removal action levels        145 
Table 5-1.    Concentrations of COCs identified at the Marina compared with T-117
Upland Study Area removal action levels                       159 
Table 5-2.    Stormwater sampling results                                 164 
Table 5-3.    Hypothetical contribution of COCs to T-117 Sediment Study Area based on
average atmospheric deposition flux rates                       174 
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Table 5-4.    Evaluation of post-removal recontamination risk from ongoing sources in
the T-117 vicinity                                           177 
Table 6-1.    Review of candidate removal action technologies for the T-117 NTCRA    189 
Table 6-2.    Removal action technologies retained for the T-117 NTCRA            195 
Table 7-1.    Summary of site-wide removal action alternatives                   199 
Table 7-2.    In-place volumes of soil and sediment to be removed and estimated
sediment capping/backfilling volumes under Alternative 1             217 
Table 7-3.    Summary of estimated costs for Alternative 1                      227 
Table 7-4.    In-place volumes of sediment to be removed and estimated sediment
backfill volumes under Alternative 2                            231 
Table 7-5.    Summary of estimated costs for Alternative 2                      232 
Table 8-1.    Comparison of removal action alternatives relative to ARARs and other
requirements TBC                                   243 
Table 8-2.    Comparison of costs for Alternatives 1 and 2                      249 
Table 8-3.    Summary of comparative analysis                             250 
Table 9-1.    Example NTCRA sequencing overview for primary construction tasks     254 
Table 9-2.    Supplementary information needed to support the removal action design   261 
Table 9-3.    Subjects and activities to be addressed in the T-117 OMMP            266 

List of Figures 
Figure 1-1.   Timeline of T-117 project history and regulatory milestones              3 
Figure 2-1.   Cross section locations                                      31 
Figure 2-2.   Geologic cross section A-A of the T-117 EAA                       33 
Figure 2-3.   Geologic cross section B-B of the T-117 EAA                       35 
Figure 2-4.   Geologic cross section C-C of the T-117 EAA                      37 
Figure 2-5.   Geologic cross section D-D of the T-117 EAA                      39 
Figure 3-1.   T-117 conceptual site model for current site conditions                 85 
Figure 4-1.   Conceptual diagram of points of compliance for upland soil and sediment
cleanup                                           128 
Figure 4-2.   Development of soil removal action levels                         130 
Figure 4-3.   Development of groundwater cleanup levels                       140 
Figure 5-1.   Overview of post-NTCRA potential sediment recontamination source areas
and routes at the T-117 EAA                               152 
Figure 5-2.   T-117 EAA possible post-NTCRA recontamination routes              155 
Figure 6-1.   Locations of zones within the shoreline and sediment                 182 
Lower Duwamish Waterway Superfund Site:                                  Revised EE/CA 
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Figure 7-1.   Cross section E1                                          207 
Figure 7-2.   Cross section E2                                          209 
Figure 7-3.   Cross section E3                                          211 
Figure 7-4.   Cross section E4                                          213 
Figure 7-5.   Cross section E5                                          215 
Figure 7-6.   General sediment excavation and cap cross section                 221 
Figure 7-7.   Upland completion options                                   235 
















Lower Duwamish Waterway Superfund Site:                                  Revised EE/CA 
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List of Maps 
All maps are included in a separate folio. 
Map 1-1.    T-117 EAA site overview 
Map 2-1.    T-117 EAA current and historical site features 
Map 2-2.    T-117 EAA site drainage 
Map 2-3.    Zoning designation and commercial and manufacturing activities in the
vicinity of the T-117 EAA 
Map 2-4.    Historical and current LDW configuration 
Map 2-5.    Net groundwater flow direction, tidal efficiencies, and tidal lag times 
Map 2-6.    Previous removal actions in the T-117 EAA 
Map 2-7.    Sampling locations in the T-117 EAA and vicinity 
Map 2-8.    T-117 Sediment Study Area total PCB concentrations in surface sediment 
Map 2-9     T-117 Sediment Study Area total PCB concentrations in subsurface
sediment 
Map 2-10.   T-117 Sediment Study Area sampling locations with full suite SMS
analyses 
Map 2-11.   T-117 Sediment Study Area dioxin/furan TEQs in surface sediment 
Map 2-12.   T-117 Upland Study Area sampling subareas 
Map 2-13a.   T-117 Upland Study Area total PCB concentrations in soil, 0-to-7-ft depth
range 
Map 2-13b.   T-117 Upland Study Area total PCB concentrations in soil, 7-to-15-ft depth
range 
Map 2-13c.   T-117 Upland Study Area total PCB concentrations in soil, >15-ft depth
range 
Map 2-14.   T-117 Upland Study Area Subarea A total PCB concentrations in soil 
Map 2-15.   T-117 Upland Study Area Subarea B total PCB concentrations in soil 
Map 2-16.   T-117 Upland Study Area Subarea C total PCB concentrations in soil 
Map 2-17.   T-117 Upland Study Area Subarea D total PCB concentrations in soil 
Map 2-18.   T-117 Upland Study Area Subarea E and F total PCB concentrations in soil 
Map 2-19a.   T-117 Upland Study Area TPH concentrations in soil, 0-to-7-ft depth range 
Map 2-19b.   T-117 Upland Study Area TPH concentrations in soil, 7-to-15-ft depth
range 
Map 2-19c.   T-117 Upland Study Area TPH concentrations in soil, >15-ft depth range 
Map 2-20.   T-117 Upland Study Area Subarea A TPH concentrations in soil 

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Map 2-21.   T-117 Upland Study Area Subarea B TPH concentrations in soil 
Map 2-22    T-117 Upland Study Area Subarea C TPH concentrations in soil 
Map 2-23.   T-117 Upland Study Area Subarea D TPH concentrations in soil 
Map 2-24.   T-117 Upland Study Area Subarea E and F TPH concentrations in soil 
Map 2-25.   T-117 Upland Study Area cPAH TEQ concentrations in soil, 0-to-4-ft depth
range 
Map 2-26.   T-117 Upland Study Area cPAH TEQ concentrations in soil, 5-to->7-ft
depth range 
Map 2-27.   T-117 Upland Study Area arsenic concentrations in soil 
Map 2-28.   T-117 Upland Study Area dioxin/furan TEQs in soil 
Map 2-29.   Adjacent Streets total PCB concentrations in soil 
Map 2-30.   Adjacent Streets total PCB concentrations in soil, 2008-2009 
Map 2-31    Adjacent Streets and Residential Yards PCB concentrations, removed or
superseded by MIS samples 
Map 2-32.   Adjacent Streets TPH concentrations in soil 
Map 2-33.   Adjacent Streets cPAH TEQs in soil 
Map 2-34.   Adjacent Streets arsenic concentrations in soil 
Map 2-35.   Adjacent Streets dioxin/furan TEQs in soil 
Map 2-36.   Residential Yards PCB concentrations in soil 
Map 2-37.   Residential Yards dioxin/furan TEQs in soil 
Map 2-38    Adjacent Streets and Residential Yards dioxin/furan concentrations,
superseded by MIS samples 
Map 2-39.   Sampling locations in Basin Oil 
Map 2-40.   Sampling locations in the South Park Marina 
Map 3-1    T-117 EAA non-potability designation 
Map 4-1.    T-117 EAA removal boundaries 
Map 4-2.    T-117 EAA, soil interpolated total PCB concentrations, 0-to-7-ft depth
range contours 
Map 4-3.    T-117 EAA, soil interpolated total PCB concentrations, 7-to-15-ft depth
range contours 
Map 4-4.    T-117 EAA, soil interpolated total PCB concentrations, >15-ft depth range
contours 
Map 4-5.    T-117 EAA, soil interpolated TPH concentrations, 0-to-7-ft depth range
contours 
Map 4-6.    T-117 EAA, soil interpolated TPH concentrations, 7-to-15-ft depth range
contours 

Lower Duwamish Waterway Superfund Site:                                  Revised EE/CA 
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Map 4-7.    T-117 EAA, soil interpolated TPH concentrations, >15-ft depth range
contours 
Map 7-1.    Proposed NTCRA, excavation for Alternative 12 
Map 7-2.    Proposed NTCRA, excavation for Alternative 2Removal Alternative 1:
sediment excavation and cap 
Map 7-3     Comparison of Alternative 1 and 2 removal areas 

















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Acronyms and Abbreviations 
AcronymCRONYM  Definition 
AOC         Administrative Order on Consent 
ARAR        applicable or relevant and appropriate requirement 
ASAOC       Administrative Settlement Agreement and Order on Consent 
AST          aboveground storage tank 
ATSDR       Agency for Toxic Substances and Disease Registry 
Basin Oil        Basin Oil Company, Inc. 
BBP          butyl benzyl phthalate 
BEHP        bis(2-ethylhexyl) phthalate 
bgs           below ground surface 
BMP         best management practice 
BTEX         benzene, toluene, ethylbenzene, and xylene 
Boeing         The Boeing Company 
CCC         criteria continuous concentration 
CD           compact disk 
Comprehensive Environmental Response, Compensation, and Liability
CERCLA 
Act (Superfund) 
CFR          Code of Federal Regulations 
cfs              cubic feet per second 
City             City of Seattle 
CMC        criteria maximum concentration 
COC         contaminant of concern 
COPC        contaminant of potential concern 
County        King County 
cPAH         carcinogenic polycyclic aromatic hydrocarbon 
CSGWPP      Comprehensive State Ground Water Protection Program 
CSL          cleanup screening level 
CSM         conceptual site model 
CSO         combined sewer overflow 
CSS          combined sewer system 
CUL          cleanup level 
cy              cubic yard 
DDD         dichlorodiphenyldichloroethane 
DDE          dichlorodiphenyldichloroethylene 
DDT          dichlorodiphenyltrichloroethane 
DOF          Dalton, Olmsted & Fuglevand, Inc. 
DPD          Department of Planning and Development 
DU           decision unit 

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AcronymCRONYM  Definition 
dw           dry weight 
EAA          early action area 
Ecology        Washington State Department of Ecology 
EE/CA         engineering evaluation/cost analysis 
EFH          essential fish habitat 
EPA          US Environmental Protection Agency 
FRTR         Federal Remediation Technologies Roundtable 
FS            feasibility study 
FSP          field sampling plan 
HHRA        human health risk assessment 
HPAH        high-molecular-weight polycyclic aromatic hydrocarbon 
HQ           hazard quotient 
Integral          Integral Consulting, Inc. 
KCBOH       King County Board of Health 
KCCWD1      King County Commercial Waterway District No. 1 
LDW         Lower Duwamish Waterway 
LDWG        Lower Duwamish Waterway Group 
LNAPL        light non-aqueous-phase liquid 
LPAH         low-molecular-weight polycyclic aromatic hydrocarbon 
Malarkey        Malarkey Asphalt Company 
Marina         South Park Marina 
MCL         maximum contaminant level 
MIS           multi-increment sampling 
MLLW        mean lower low water 
MTCA        Model Toxics Control Act 
NMFS        National Marine Fisheries Service 
NOAA        National Oceanic and Atmospheric Administration 
NPDES       National Pollutant Discharge Elimination System 
NPL          National Priorities List 
NRDA        natural resource damage assessment 
NTCRA       non-time-critical removal action 
O&M         operation and maintenance 
OC           organic carbon 
OMMP       operation, maintenance, and monitoring plan 
ORP         oxidation-reduction potential 
OSWER       Office of Solid Waste and Emergency Response 
PAH          polycyclic aromatic hydrocarbon 
RBTC        risk-based threshold concentration 
PCB          polychlorinated biphenyl 
PCE          tetrachloroethylenes 

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AcronymCRONYM  Definition 
Port            Port of Seattle 
PQL          practical quantitation limit 
PRG         preliminary remediation goal 
PSDDA       Puget Sound Dredged Disposal Analysis 
QAPP        quality assurance project plan 
QA/QC        quality assurance/quality control 
RAA         recontamination assessment area 
RAL          remedial action level 
RAO         removal action objective 
RBTC        risk-based threshold concentration 
RCRA        Resource Conservation and Recovery Act 
RI               remedial investigation 
RM          river mile 
ROD         Record of Decision 
ROW        right-of-way 
RvAL         removal action level 
SAIC          Science Applications International Corporation 
SCAP        source control action plan 
SCL          Seattle City Light 
SCWG       Source Control Work Group 
SL            screening level 
SMC         Seattle Municipal Code 
SMS         Washington State Sediment Management Standards 
SOW         statement of work 
SPCC        South Park Community Center 
SPU          Seattle Public Utilities 
SQS          sediment quality standards 
STAR        sediment transport analysis report 
STM          sediment transport model 
SVOC        semivolatile organic compound 
T-117          Terminal 117 
TBT          tributyltin 
TCDD        tetrachlorodibenzo-p-dioxin 
TCLP         toxicity characteristic leaching procedure 
TCRA        time-critical removal action 
TEE          terrestrial ecological evaluation 
TEF           toxic equivalency factor 
TEQ          toxic equivalent 
TOC          total organic carbon 
TPH          total petroleum hydrocarbons 

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AcronymCRONYM  Definition 
TPH-D         diesel-range total petroleum hydrocarbons 
TPH-O         lube oil-range total petroleum hydrocarbons 
TSCA         Toxic Substances Control Act 
UCL          upper confidence limit on the mean 
USACE       US Army Corps of Engineers 
USFWS       US Fish and Wildlife Service 
UST          underground storage tank 
VOC         volatile organic compound 
WAC         Washington Administrative Code 
WSDOH      Washington State Department of Health 
Windward      Windward Environmental LLC 














Lower Duwamish Waterway Superfund Site:                                  Revised EE/CA 
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1    Introduction 
Terminal 117 (T-117) is a site within the Lower Duwamish Waterway (LDW)
Superfund site that was selected for early action in 2003 to address polychlorinated
biphenyl (PCB) contamination in sediment. An upland portion of T-117 was
historically used for the manufacture of asphalt products, as well as other activities
associated with former tenants. Asphalt manufacturing operations at the site included
the use of recycled oils, some of which contained PCBs, and these oils are believed to
be a source of contaminants released to the surrounding soil and sediment. 
In 2005, the Port of Seattle (Port) and the City of Seattle (City) prepared an engineering
evaluation/cost analysis (EE/CA) for a non-time-critical removal action (NTCRA) for
the sediment and adjacent shoreline bank area, which was submitted to the US
Environmental Protection Agency (EPA). EPA approved the 2005 EE/CA (Windward
et al. 2005c) for the T-117 Early Action Area (EAA) sediment and adjacent bank and
issued an action memorandum (EPA 2006a), which set forth the implementation of the
NTCRA. At that time, it was assumed that only minor revisions to the upland side of
the sediment removal action boundary would be needed. However, in 2006, additional
PCB contamination was discovered in the T-117 upland property, the extent of which
was broader than originally anticipated. This resulted in an increased scope for the
NTCRA. In addition, in 2004-2005, PCBs were discovered in the streets adjacent to the
T-117 upland property and removed from two residential yards.;, and in 2008, PCBs
and dioxins and furans were discovered in residential yards near the T-117 EAA. In
March of 2007, the Washington State Department of Ecology (Ecology) notified EPA
that it supported incorporating the work proposed by the City for Dallas Avenue S
into EPA's T-117 NTCRA (Ecology 2007). Thus, the T-117 EAA was expanded by EPA
to include three areas, hereafter referred to as the T-117 Sediment Study Area, the
T-117 Upland Study Area, and the Adjacent Streets and Residential Yards Study Area. 
In 2008, LDW source control samples collected in 2004-2005 were evaluated for dioxins 
and furans, and concentrations were determined to be above the Model Toxics Control
Act (MTCA) Method B cleanup level (CUL) at two locations near T-117. EPA ordered
additional analysis for PCBs and dioxins and furans in 2008, and both contaminants 
were discovered above the MTCA Method B CUL in streets, rights- of- way (ROWs), 
and residential yards. As a result, EPA directed the Adjacent Streets portion of the
T-117 EAA to be expanded to include the area bounded by Dallas Avenue S to the
north and east, 14th Avenue S to west, and S Donovan Street to the south (EPA 2009c).
This area is now referred to as the Adjacent Streets and Residential Yards Study Area. 
The scope of the T-117 EE/CA includes the evaluation of removal action alternatives
for all three of the T-117 study areas. 

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The scope of this EE/CA is set forth in the Terminal 117 Early Action Area Work Plan for
Revised Engineering Evaluation/Cost Analysis (Windward et al. 2008), hereafter referred
to as the EE/CA Work Plan. This EE/CA is being prepared by the Port and the City
pursuant to an Administrative Settlement Agreement and Order on Consent (ASAOC)
with EPA (Docket No.10-2006-0103, December 22, 2005 (EPA 2005b)) and in
accordance with Amendment No. 1 to the statement of work (SOW) dated
September 28, 2007 (EPA 2007c) (Appendix A). 
The SOW also required an assessment of the potential for recontamination of the T-117
EAA by the adjoining Basin Oil Company, Inc. (Basin Oil), property and South Park
Marina (Marina), collectively referred to as the recontamination assessment areas
(RAAs). Map 1-1 shows the T-117 EAA and the RAAs. An evaluation of the RAAs is
included in this EE/CA, which is necessary to ensure the long-term permanence of the
selected removal alternative. 
In addition, the scope of this EE/CA complies with the requirements set forth in EPA's
Guidance on Conducting Non-Time-Critical Removal Actions Under CERCLA (1993),
including a comprehensive compilation of existing site data to support the
identification and analysis of contaminants of concern (COCs), site risks, and the 
removal alternatives necessary to address those contaminants and associated risks.
EPA has specifically requested that the EE/CA include removal action alternatives
that are compatible with the anticipated future unrestricted land use (EPA 2007b) 
(Appendix A). The presentation of removal action alternatives includes a discussion of
different ways in which the removal action can be completed in order to meet EPA's
future land use request. Removal action technologies are similar to those presented in
the 2005 EE/CA (Windward et al. 2005c) and the 2008 EE/CA Work Plan (Windward
et al. 2008) and are further developed and refined in this EE/CA. 
The overall goal of the T-117 EAA NTCRA is to significantly reduce the exposure of
ecological and human receptors to sediment and soil contamination and thereby
reduce or eliminate adverse effects on resources in the EAA. The NTCRA will also
reduce risks to human health by removing or isolating bioaccumulative and toxic
chemicals that are present in sediment and soil at the T-117 EAA (EPA 2005c). In
addition, the removal of contaminated soil will reduce or eliminate groundwater 
contamination. 
1.1   CERCLA PROJECT PROGRESSION 
This section summarizes the history of the LDW as a Superfund site and the
identification of the T-117 as an EAA within the LDW. T-117 has been investigated by
both state and federal agencies prior to the LDW Superfund listing. Additional details
on the regulatory history prior to the LDW Superfund designation are presented in
Sections 2.1.2 and 2.2, respectively. A timeline showing project history and regulatory
milestones is presented in Figure 1-1. 

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Slipsheet (11 x 17) 
Figure 1-1. Timeline of T-117 project history and regulatory milestones 

















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1.1.1  Lower Duwamish Waterway and early action areas 
The T-117 EAA is within the LDW Superfund site. The LDW was added to EPA's
National Priorities List (NPL) defined under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), also known as Superfund, on
September 13, 2001. The Phase 1 remedial investigation (RI) report for the LDW
(Windward 2003a) presented a summary of available data for the waterway. One of
the primary objectives of the Phase 1 RI was to identify candidate areas within the
LDW for early removal action. The Port, the City, King County (County), and The
Boeing Company (Boeing), working together as the Lower Duwamish Waterway
Group (LDWG), prepared a technical memorandum (Windward 2003b) that
recommended seven areas, one of which was T-117, to EPA and the Washington State
Department of Ecology (Ecology) for early removal action. In 2003, EPA required that
T-117 be investigated as an EAA, primarily because of the high concentrations of PCBs
and the potential for those PCBs to contaminate LDW sediment (EPA 2005b). 
1.1.2  Initial early action area investigations and 2005 EE/CA 
Since T-117 was selected as an EAA, the Port and the City have conducted a series of
environmental investigations to further characterize environmental conditions in the
Sediment Study Area, identified a removal action boundary, and investigated
potential sources of contamination. The results of these efforts have included a
summary of existing information and data gaps report (Windward et al. 2003), several
data reports (Windward et al. 2005b, d, e), and the 2005 EE/CA (Windward et al.
2005c). These investigations (and the resulting reports) for the T-117 EAA were
conducted under the existing LDW Administrative Order on Consent (AOC) (EPA
2003) signed by all of the LDWG members, as well as by EPA and Ecology. Although
all four members of LDWG are responsible for the LDW RI (Windward 2009), work at
the T-117 EAA is conducted by only the Port and the City. 
After the approval of the 2005 EE/CA (Windward et al. 2005c) on July 22, 2005, EPA
issued a removal action memorandum (EPA 2005a) to implement the NTCRA design
and removal activities. The removal action memorandum requested further
characterization of PCB contamination in the northern portion of the bank necessary to
finalize the removal action boundary prior to NTCRA implementation. The additional
bank characterization sampling resulted in the discovery of higher-than-expected PCB
concentrations in the bank at the northern part of the T-117 EAA. This led EPA to
require further sampling to delineate the extent of PCBs in the upland soil. An ASAOC
(CERCLA 10-2006-0072) (EPA 2005c) was issued solely to the Port on October 17, 2005,
for an additional T-117 upland soil investigation to determine the nature and extent of
upland PCB soil contamination. In an effort to continue moving forward on NTCRA
activities, on December 22, 2005, an ASAOC (EPA 2005b) was issued jointly to the Port
and the City with a SOW for the NTCRA design and removal. However, in January

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2006, additional site characterization investigations conducted by the Port found high
concentrations of PCBs in soil (Windward and DOF 2006). These data concentrations 
prompted a time-critical removal action (TCRA) to remove contaminated soil from
specific areas within the T-117 Upland Study Area prior to conducting the NTCRA,
which postponed the joint Port and City NTCRA activities. 
1.1.3  2006 time-critical removal action 
At the direction of EPA, the Port implemented the TCRA for the T-117 Upland Study
Area to remove upland source materialcontaminated soil that could potentially
recontaminate the sediment and affect the success of the planned NTCRA for the
Sediment Study Area. A TCRA memorandum (EPA 2006a) to address risks posed by
the upland soil contamination was issued by EPA on June 15, 2006. EPA concluded
that the scope of the TCRA would be limited to those areas of T-117 with the highest
documented concentrations of PCBs in soil, as well as a limited area near the bank
with exposed contaminated soil (i.e., an unpaved area), and that the rest of the upland
contamination would be more efficiently addressed as in the T-117 EAA NTCRA. The
SOW (EPA 2006b) for the implementation of the TCRA to address the most
contaminated areas of the T-117 Upland Study Area was issued to the Port on August 
11, 2006. The Port completed the TCRA in November 2006 (RETEC 2007b). The SOW
required the implementation of the post-TCRA site operation and maintenance (O&M) 
program, which is currently ongoing (RETEC 2007a). Semi-annual O&M reports are
submitted to EPA. Details, such as excavation volumes and depths, of the 2006 TCRA
removal activities are discussed in Section 2.2.3. 
1.1.4  Inclusion of the Adjacent Streets 
In 2007, the City requested that Ecology support the inclusion of the Adjacent Streets
and ROWs in EPA's NTCRA with the intention that the temporary measures
implemented as part oft the City's previous independent cleanup actions (i.e.,
temporary asphalt and gravel on roads and ROWs and surface water collection system
routed to Baker tanks) would be replaced and longer needed after implementation of 
the NTCRA. 
1.1.45 Dioxin investigations and PCB boundary refinement 
The City's source-tracing program for the LDW (Herrera 2004) included the analysis of
11 samples, including two 2 samples collected near T-117, for dioxins and furans. The
two samples included one street dust (i.e., fine soil accumulated on street surfaces and
shoulders) sample collected at the intersection of Dallas Avenue S and 16th Avenue S
(within the area now designated as the Adjacent Streets portion of the T--117 EAA)
and a sample collected from a settling tank (later replaced by an oil-water separator)
located on the Basin Oil property. The LDW source-tracing samples were analyzed for

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a suite of chemicals. Dioxin congener concentrations from this sampling program were
used to calculate toxic equivalents (TEQs),1 concentrations, which were reviewed by
the City in 2008 (Integral 2008b). The dioxin/furan TEQs for the street dust and the
settling tank samples were 90.5 ng/kg and 15.2 ng/kg, respectively. The street dust
sample dioxin/furan TEQ was more than twice the maximum TEQ of the other
11 samples and was found in an area where PCB concentrations were above the
MTCA Method B CUL. Because these data are not related to the T-117 EAA, their
significance is uncertain.two source-tracing samples, it is unclear if these samples
reflect isolated areas with higher levels of dioxin/furan TEQs. 
As a result of these findings, the City proposed an additional investigation (Integral
2008a) of residential yards to examine the presence of dioxins and furans in the
vicinity of the street dust sample, which was to include the collection of samples in 
several yards and from borings in the streets. EPA requested that additional
investigations be conducted in all three T-117 EAA study areas. These investigations
were conducted in 2008 and 2009 (Windward and Integral 2009; Integral 2009). The
2008 investigation resulted in detections of dioxins and furans, and PCBs in sediment,
upland soil, streets, parking strips, and yards. These results led to EPA's request for
additional sampling in yards and the Adjacent Streets using multi-increment sampling
(MIS) techniques in order to refine the boundaries and determine mean exposure
concentrations in the yards. The 2008-2009 MIS soil sampling effort resulted in the
detection of PCB concentrations above 1 mg/kg in portions of the Adjacent Street and
in some Residential Yards. Dioxin/furan TEQs exceeded the MTCA CUL of 11 ng/kg
at many locations and ranged from 0.495 to 84.0 ng/kg. One TEQ of 395 ng/kg was
considered to be an outlier (see Section 2.3.3). As a result of these investigations, EPA
directed that the Adjacent Streets portion of the T-117 EAA be expanded to include the
area bounded by Dallas Avenue S to the north and east, 14th Avenue S to west, and S
Donovan Street to the south (EPA 2009c). As shown on Map 1-1, this area is now
referred to as the Adjacent Streets and Residential Yards Study Area. 
1.1.56 Expanded T-117 EAA and the revised EE/CA 
This EE/CA is being prepared in accordance with the EE/CA Work Plan (Windward
et al. 2008) and SOW Amendment 1 (EPA 2007c), the latter replacing in its entirety the
SOW appended to the NTCRA ASAOC issued on December 22, 2005. SOW
Amendment 1, issued on September 28, 2007, states that the revised EE/CA will
include the information presented in the previous EE/CA (Windward et al. 2005c) and
will also include new information that has been generated since the 2005 EE/CA. Such
information includes the following datasets, which are discussed in greater detail in
Sections 2.2 and 2.3. 

1 Dioxin/furan TEQs were calculated in accordance with Ecology's calculation guidance (WAC 173-340-
900, Table 708-1). 
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Data collected by the Port in support of its investigation of the T-117 Sediment
Study Area 
Data collected by the Port in support of its investigation and removal action
activities within the T-117 Upland Study Area 
Pertinent information from the river-wide LDW RI/feasibility study (FS) 
Data collected by the City in support of its investigation and independent 
cleanup action activities within the Adjacent Streets and Residential Yards
Study Area 
Data collected by Ecology and EPA in support of their dioxin and furan 
investigation within the Adjacent Streets and Residential Yards Study Area 
Data collected as part of the T-117 data gaps assessment, including
groundwater monitoring activities set forth in the SOW 
Data collected by Ecology and EPA in conjunction with past and ongoing
investigation and cleanup actions at Basin Oil 
Data collected by Ecology as part of its investigation of the Marina 
This EE/CA includes an identification and analysis of removal action technologies and
alternatives for the expanded T-117 EAA as well as previously analyzed sediment
removal alternatives, taking into consideration all new information from the abovenoted
sources. Following the completion of this EE/CA, EPA will issue an amended
action memorandum for the T-117 EAA NTCRA, which will replace the action
memorandum issued on July 22, 2005. 
1.2   EE/CA ORGANIZATION 
This EE/CA is organized in accordance with SOW Amendment 1 (EPA 2007c), which
is an appendix of the ASAOC (EPA 2005c). The contents and EE/CA approach are
detailed in the approved EE/CA Work Plan (Windward et al. 2008). The remaining
sections of this EE/CA are organized as follows: 
Section 2, Site Characterization  Presents a summary of historical operations,
previous investigation and removal actions, current site conditions, land use,
geology, and hydrogeology. This section also discusses the nature and extent of
contamination based on sediment, soil, and groundwater for the T-117 EAA
and the RAAs. 
Section 3, Streamlined Risk Assessment  Presents the conceptual site model
(CSM), which shows the current and potential sources, transport mechanisms
and exposure pathways to potential receptors. The contaminants of potential
concern (COPCs) presented in the EE/CA Work Plan (Windward et al. 2008) 
are further evaluated, and specific contaminants were selected as COCs
through a streamlined risk assessment. 
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Section 4, Identification of Removal Action Scope, Goals, and Objectives  
Presents the development of removal action levels (RvALs) for sediment and
soil necessary to address the removal action goals and objectives. These goals
include contaminant removal sufficient to allow for a broad range of final site
uses at T-117, including possible upland and aquatic habitat. This section also
presents the removal boundaries for each of the T-117 EAA areas. 
Section 5, Recontamination Assessment Provides an overview of the source
control strategy, identifies potential recontamination sources and pathways, 
and evaluates the potential for the pathways to recontaminate the post-NTCRA
site. This section also describes the results of the recontamination assessments
for the Basin Oil property and Marina, which were initially presented in the
EE/CA Work Plan (Windward et al. 2008), and has been updated based on
identified data needs and recent investigations by Ecology. 
Section 6, Identification, Evaluatioin, and Screening of Removal Action
Technologies  Identifies, discusses, and screens the potentially applicable
removal action technologies for soil and sediment removal, treatment, and
offsite disposal. Technologies retained after screening are intended for use as 
part of the assembled removal action alternatives presented in Section 7. 
Section 7, Description and Analysis of Removal Action Alternatives  
Presents the removal action alternatives and describes how they will be applied
in each removal area of the EAA. Each alternative is also discussed in terms of
its implementability, effectiveness, and cost to facilitate the comparative
analysis in Section 8. 
Section 8. Comparative Analysis of Removal Action Alternatives  Provides a
comparative discussion of the removal alternatives based on the CERCLA
criteria of effectiveness, implementability, and cost. 
Section 9. Recommended Removal Action Alternative and Implementation  
Describes and presents the rational for the recommended alternative for the
NTCRA. Presents the preliminary removal action sequencing concepts, short-
term and long-term monitoring objectives, and general a description of NTCRA
activities to be conducted during design and during and after construction. 
Section 9 includes a description of the long-term operation, maintenance, and
monitoring plan (OMMP) that will be developed and implemented to ensure
the long-term performance of the selected removal action alternative. The
section also includes a discussion of the data gaps that will be needed prior to
the removal action. 
Section 10, References  Includes references for published documents and
other sources cited in this EE/CA. 

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The following appendices support the text: 
Appendix A. SOW and Reasonably Anticipated Future Land Use Letter 
Appendix B. Groundwater 
Appendix C. Data Tables 
Appendix D. Data Management 
Appendix E. COC Screening 
Appendix F. RAA Data Summary Tables 
Appendix G. ARARsS and Other Requirements to be Considered 
Appendix H. Risk-Based Disposal Application 
Appendix I. Combined Early Life Stage Adjustments and Soil Exposure Factors
for Residential and Recreational PRG for cPAHsSoil Risk Calculation
Supporting Details 
Appendix J. Cost Details 
Appendix K. Detailed Technology Evaluation 
Appendix L. MIS Variance 
Appendix M. Dioxin Technical Workgroup Presentations 
The appendices are provided only on a compact disk, (CD) which is located on
the inside back cover. The CD also includes a copy of this report and the figure
and map folio. 








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2    Site Characterization 
This section presents a summary of the available environmental, physical, and
ecological information relevant to the T-117 EAA. The section also includes a
description of the historical activities, regulatory history, and current site features. The
current site uses and activities occurring in the vicinity are also described. There is also
discussion ofon the LDW and the geology inof this area. Finally, the previous
environmental investigation and clean-up actions in the T-117 EAA and RAAs are
summarized. 
2.1   SITE DESCRIPTION 
2.1.1  Location and characteristics 
The T-117 EAA is situated on the west bank of the LDW, between approximately River
Mile (RM) 3.5 and RM 3.7 (relative to the southern tip of Harbor Island) (Map 1-1). The
EAA is located approximately 6 miles south of the Seattle downtown area and is
across the LDW from Boeing Plant 2 and Jorgensen Forge, which together form
another EAA. The T-117 Upland Study Area is located within a narrow strip of
unincorporated King County that lies between the LDW to the east and the South Park
neighborhood of Seattle to the west. The Port's T-117 property, which includes the T--
117 Upland Study Area, is located at 8700 Dallas Avenue S and is immediately south
of the 16th Avenue S bridge (also known as the South Park Bridge) (Map 1-1). 
The T-117 EAA is characterized by gently sloping intertidal mudflat habitat, a steep
vegetated riprap bank, and a relatively flat adjacent upland area. The T-117 EAA
encompasses approximately 15.2 acres and consists of the three defined areas: the
Sediment Study Area within the LDW, the T-117 Upland Study Area (Port-owned T--
117 property), and the Adjacent Streets (City rights-of-way [ROWs]) and Residential
Yards Study Area. Each area of the T-117 EAA is described in further detail in the
subsections that follow. 
The T-117 EAA is also adjacent to the Marina and Basin Oil properties, which are
being evaluated as potential sources of recontamination to the T-117 EAA. These areas
are also shown on Map 1-1 and are discussed in detail in Section 2.3.4. 
2.1.1.1  Sediment Study Area 
The T-117 Sediment Study Area is the aquatic portion of the T-117 EAA. Located
within the LDW (Map 1-1), the study area is approximately 1.4 acres in size and
consists primarily of intertidal sediment with some subtidal sediment. The study area
extends from the top of the shoreline bank, at an elevation of approximately+13.8 ft
mean lower low water (MLLW), into the LDW (60 to 80 ft), at an elevation between 0
and -5 ft MLLW. This area is bordered by the LDW to the north and south, the LDW 
navigation channel to the east, and the T-117 Upland Study Area to the west. 
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2.1.1.2  T-117 Upland Study Area 
The T-117 Upland Study Area consists of the Port's T-117 upland property located
between the T-117 Sediment Study Area and the Adjacent Streets and Residential
Yards Study Area (Map 1-1). This property, which includes the former Malarkey
Asphalt Company (Malarkey) Plant property, is located at 8700 Dallas Avenue S. In
1963, the Port accepted the assets of the King County Commercial Waterway District 
No. 1 (KCCWD1) (Map 2-1), which included limited rights in a 500-ft-wide strip of
upland property along the T-117 shoreline. ROW acquired to create a portion of the
LDW. In 20001999, the Port acquired two inland parcels that included the former
Malarkey property between the shoreline KCCWD1 parcel and Dallas Avenue S.
These properties were consolidated to form the present-day footprint of T-117, which
encompasses approximately 3.3 acres. This area is relatively flat with an elevation that
ranges from approximately +13.8 ft MLLW at the top of the bank to approximately +21
ft MLLW along the property boundaries at Dallas Avenue S and the Marina. The T-117
Upland Study Area is bordered by the Marina to the north, Boeing South Park to the
south, Dallas Avenue S to the west, and the T-117 Sediment Study Area and the LDW
to the east. 
2.1.1.3   Adjacent Streets and Residential Yards Study Area 
The Adjacent Streets and Residential Yards Study Area consists of two subareas: the
Adjacent Streets and the Residential Yards. The Adjacent Streets portion is the street
and ROW areas bounded by Dallas Avenue S, S Donovan Street, and 14th Avenue S. 
These streets and ROWs are relatively flat with the exception of S Donovan Street. The
lanes of this street are separated by a steep bank and the southern-most lane is
elevated relative to other streets in the area. 
The Adjacent Streets are bordered by the T-117 Upland Study Area to the east and the
Marina to the north. The Adjacent Streets also surround, but do not include, the
former Basin Oil property and Residential Yards within the bounding streets
mentioned above. The Residential Yards consist of the residential properties within
the boundaries of Dallas Avenue S, S Donovan Street, and 14th Avenue S. These yards
are relatively flat with some local minor variations in topography. 
2.1.2  Historical activities 
2.1.2.1  T-117 operations 
The Duwamish Manufacturing Company began manufacturing asphalt roofing
materials at T-117 around 1937 and continued until 1978 at a location that generally
corresponds to the western half of the T-117 Upland Study Area (URS 1994). The
business and property were sold in 1978, when it became known as the Malarkey
Asphalt Company. Asphalt roofing materials manufacturing continued until 1993.
Since that time, several environmental site investigations werehad been conducted
until the asphalt plant was decommissioned in 1997. During the Duwamish
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Manufacturing Company's operation of the asphalt manufacturing facility from the
late 1960s through the mid 1970s, used oils, some of which contained PCBs, were used
as fuel for the asphalt manufacturing process (URS 1994). Some used oils came from
Seattle City Light. 
Features formerly associated with the asphalt plant (Map 2-1) but no longer present at
the site include underground and aboveground storage tanks (USTs and ASTs) and 
associated piping, reaction tanks, sumps, a diesel fuel dispenser, a hot oil heater and
associated shed, transfer pumps and pipes, warehouses at the east side of the plant
area, a drum storage shed, and a partially buried railroad tank car (URS 1994). 
A former ponding area was located just inland of the top of the shoreline bank
(Map 2-1) and was reportedly used during site operations for retaining non-contact
cooling water (Hart Crowser 1992; URS 1994). This area was later determined to
merely be a depression in the unpaved area of the site where stormwater collected and
vehicles drove through the property. The ponding area was the lowest point on the 
T-117 Upland Study Area and also collected all water that flowed across the site, 
including non-contact cooling water from the main manufacturing area. Periodic
overflow from the former ponding area to the LDW was noted during extended rainy
periods (EMCON 1996). The former ponding area was located within the former
KCCWD1 ROW (EMCON 1996) and was subsequently excavated as part of a
contaminated soil TCRA in 1999 and backfilled (Onsite 2000a) (see Section 2.2.2). 
From 1989 to as late as 1995, Basin Oil leased a 10,000-gal. horizontal tank from
Malarkey within the plant area for storing and processing used oil (EPA 1995). After
the asphalt plant was decommissioned in 1997, portions of the property were occupied
by Evergreen West Wholesale (a lumber wholesaler) for untreated lumber storage and
loading (Windward et al. 2003). From 2003 to 2004, through a lease with the Port, 
Basin Oil also used a portion of the interior of the south building on the T-117 property
for storage and oil filter processing (Windward et al. 2003). In 20001999, the Port
acquired the asphalt plant parcels and related buildings located between the shoreline
ROW parcel and Dallas Avenue S. This acquisition was part of an agreement in which
the Port would conduct the 1999 TCRA in exchange for the parcels. The Port
consolidated the asphalt plant parcels with the KCCWD1 parcel to form the presentday
T-117 Upland Study Area. After the Port acquired the property, Port Construction
Services used the outdoor area near the small office/carport for the storage of
miscellaneous materials. International Inspection, a provider of non-destructive
testing services, formerly leased the north building and the small office/carport.
Second Use Building Materials, Inc., a recycling business that obtains reusable
building materials from demolition projects for resale to the public, leased the south
building for inventory storage. The T-117 Upland Study Area has been vacant since
February 2007. 

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2.1.2.2  Adjacent Streets and Residential Yards Study Area 
Aerial photographs show that the current street configuration in the South Park area
was largely established as early as 1936. Available records indicate that S Cloverdale
Street, between 14th Avenue S and 16th Avenue S, was paved or resurfaced with
asphalt in 1947 (Allwine 2005). Other streets in the area (Dallas Avenue S, S Donovan
Street, 16th Avenue S, and 17th Avenue S) remained unpaved until the mid-1970s or 
later, which extends into the period when used oils were handled by the Duwamish
Manufacturing Company and Basin Oil (described below). Prior to an independent 
cleanup action conducted by Seattle Public Utilities (SPU) in 2004-2005 (Section 2.2.4), 
the streets surrounding Basin Oil had no formal stormwater collection system within
the Adjacent Streets portion of the EAA. 
Businesses historically located within the neighborhood adjacent to T-117 included
Basin Oil, the Marina, Seattle Chocolate Company, Allied Bolt Company, and 
Fasteners, Inc; these businesses are briefly described below. Basin Oil and the Marina
are further evaluated as RAAs, and additional site information and the results of
environmental investigations for these properties are presented in Section 2.4. 
Until 2007, the Basin Oil site was occupied by the Basin Oil Company, which operated
as a collector, transporter, and marketer of used oil. Used oil was delivered to the
facility by tank trucks and stored in tanks prior to treatment and recycling. The
property was also the former site of operations for other affiliated companies
including Northwest Antifreeze Service, Frontwater Service, and Vintage Oil Inc., all
of which were handlers of used oil or antifreeze products. Basin Tank and
Environmental Services, Inc., also operated on the site, but that company closed in
January 2002. According to Ecology records (Ecology 2004b), Basin Oil began
operating at the site in 1987. Prior to development as an industrial facility, the site
included residential parcels and a single-family residential structure. The site is
currently inactive, and cleanup actions by the owner have been conducted since the
plant closure in 2007 (EPA 2007a). 
There is little information regarding historical activities at the Marina (SAIC 2007b). A
portion of the land that currently comprises the Marina was a mobile home park. Boat
transport and engineering operations have also been conducted in the boat yard. A&B
Barrel, a barrel refurbishing and cleaning operation, was located at the site in the 1950s
(Windward et al. 2003). Former occupants of the central portion of the site reportedly
included North Star Trading Company (1980 to 1981), Evergreen Boat Transport (1985
to 1999), R.P. Boatbuilding (dates unknown), and Dekker Engineering (1995 to 1999). 
Seattle Chocolate Company, Allied Bolt Company, and Fasteners, Inc., occupied the
same property (located at 8619 and 8620 17th Avenue S) at various times; Caf Umbria
currently occupies the property. The City conducted a site history assessment of this
property in general accordance with EPA standard practice (40 Code of Federal
Regulations [CFR] 312). County records indicate the building was constructed in 1971
and first occupied in 1979. City records document a connection made to the City sewer
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in 1979 (at which time Allied Bolt Company was a tenant). The Allied Bolt Company
and Fasteners, Inc., were classified as small-quantity generators, although and no
violations were noted in association with their operations. Chemicals potentially
associated with operations at the Allied Bolt Company and Fasteners, Inc., may have
included volatile organic compounds (VOCs) and metals. A records search (King
County 2008; Ecology 2008a; City of Seattle 2008; Ecology 2008b) did not indicate that
any COPCs were associated with the Seattle Chocolate Company. 
2.1.3  Current site features 
2.1.3.1  Upland structures and infrastructure 
Since the asphalt plant was decommissioned in 1997, the only aboveground structures
that remain on the T-117 Upland Study Area are the north and south buildings, the
small office/carport inside the north gate, and the truck scale at the west side of the
property. The remainder of the T-117 Upland Study Area is covered with asphalt or
concrete pavement with the exception of a vegetated drainage ditch along the
southern boundary. Asphalt plant structures that remain at T-117 beneath the ground
surface include the three closed-in-place USTs; the decommissioned large-diameter
industrial water supply well; concrete foundations associated with the former
warehouse structures, reaction tanks, cooling water sump, and tank pads, and
underground utility corridor; and a shallow, concrete-lined ditch that has
subsequently been cleaned out and backfilled with controlled density fill (Windward
and Onsite 2004). Some small-diameter remnant buried piping associated with the
former plant may also be present, although most of this piping was removed during
plant demolition and the subsequent cleanout of the concrete-lined utility corridor.
The property is fenced, and gates are locked to control public access. The buildings on
T-117 are supplied with potable water from the City public water supply system. The
north building and the office/carport building discharge grey water and sewage to the
septic system onsite. These features are shown on Map 2-1. 
An overhead power line (Seattle City Light's Dallas Avenue Crossing) was
temporarily removed in 2004. This overhead power line passed through the Adjacent
Streets along an existing easement across the T-117 Upland Study Area and across the
T-117 Sediment Study Area. The current 12-ft-wide easement across the upland
property is shown on Map 2-1, and the historical lines are visible on Map 1-1; these
lines traversed the T-117 Upland Study Area, in the vicinity of the Dallas Avenue S
and 17th Avenue S intersection, and extended east across T-117 and the LDW to a
location near the southwest corner of the Boeing Plant 2 property. The overhead
power line is scheduled for reconstruction following completion of the NTCRA. 
The Adjacent Streets are paved, with gravel surfacing in some shoulder areas (along
Dallas Avenue S, and 16th Avenue S). Sidewalks, with grass buffer strips and
occasional trees, are present along sections of Dallas Avenue S, 16th Avenue S, and
17th Avenue S (Map 2-1). Overhead power lines and underground utilities (e.g., gas,
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water, telephone, combined sewer system [CSS]) exist throughout the area. 
Stormwater in the area east of 16th Avenue S drains to the CSS. A temporary
stormwater collection system was installed and pavement improvements were
completed within portions of the Adjacent Streets as part of the City's independent 
cleanup actions (see Section 2.2.4). 
2.1.3.2  Offshore debris and structures 
Waste materials that may be associated with historical upland operations are present
in the riprap of the shoreline berm, on the vegetated berm crest, and in the drainage
ditch at the south side of T-117 Upland Study Area. These waste materials include
55-gal. drums, semi-soft and hardened asphalt and asphalt roofing materials.
Weathered chunks of asphalt are also present on the intertidal mudflat. Photographs
and maps of the locations of these waste materials are included in the 2004 data report
(Windward et al. 2004). 
A deteriorating bulkhead located offshore of the north half of the T-117 EAA can be
observed today at the base of the riprap and can also be seen in a 1946 aerial
photograph (Windward et al. 2003) as a row of pilings in the intertidal area. Also, a
row of treated pilings and a log boom used to divert floating debris away from the
Marina is located in the intertidal area near the boundary with the Marina. 
2.1.3.3  Drainage and outfalls 
Map 2-2 shows the outfalls, sewer and storm drain lines, and catch basins associated
with the drainage in the T-117 EAA and vicinity. Two storm drain outfalls located
along the T-117 shoreline bank are owned by the Port and discharge runoff from
stormwater conveyances located on the T-117 Upland Study Area. These two outfalls
discharge directly to the LDW and T-117 EAA Sediment Study Area. Threewo storm
drain outfalls are located to the north of T-117, located along the shoreline bank of the
Marina and , discharge to the LDW. from the Marina. The southernmost of the Ttwo of
the Marina outfalls areis owned by the Marina and discharge stormwater from the
Marina property.; Tthe ownership of the northernmost Marina outfall is uncertain;
howeverowned by the County and, the outfall drains the South Park Bridge
(Windward 2009). Two storm drain outfalls to the south of T-117 are located on the
Boeing South Park property and are owned by Boeing.; the northernmost of these two
outfalls is in the vicinity of T-117). Stormwater in the Adjacent Streets and Residential 
Yards Study Area discharges to the City's CSS as described below. No combined
sewer overflow (CSO) outfalls are located in the vicinity of the T-117 EAA ( Map 2-2);
the nearest CSO (operated by King the County) is located at 8th Avenue S. King 
County records show that this CSO has not overflowed in the past 10 years (Huber
2009). 


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T-117 Upland Study Area 
The two storm drain outfalls along the shoreline of the T-117 EAA drain catch basins
are located on the T-117 Upland Study Area and were field verified by the Port in 2006 
(Phoinix 2007). Stormwater discharging through these outfalls primarily originates
from the asphalt-paved T-117 Upland Study Area and is collected in the T-117 catch
basins before discharge to the LDW. Stormwater runoff from the northern part of T-
117 Upland Study Area flows to a catch basin (CB-1) that discharges to the LDW
through a 6 in diameter outfall located within the shoreline riprap. Runoff from the
central and southern portions of the Upland Study Area drain to several catch basins
(CB-2, CB-3, and CB-4) that eventually lead to a catch basin located to the northeast of
the south building (CB-5) that discharges to the LDW. Roof drainage from the
warehouse building on the south end of the T-117 Upland Study Area is conveyed
from the gutters to the south side of the building and eventually discharges to the
drainage ditch/swale located along the southern property boundary. 
Since completion of the 2006 TCRA, all of the catch basins on T-117 have been
surrounded by hay bales and equipped with a filter sock. The catch basins include
sumps for retaining settled solids and are equipped with inverted outlets to retain
floating oil. These catch basins are inspected regularly as part of the 2006 TCRA
inspection and maintenance program. 
In early September 2009, sediments that had accumulated inside and outside of catch
basins on the T-117 Upland Study Area (CB-3 and CB-5) were sampled for dioxins and
furans, arsenic, copper, silver, total petroleum hydrocarbons (TPH) in the diesel and
gasoline ranges, PCBs, and polycyclic aromatic hydrocarbons (PAHs). 
In September 2009, all catch basins on the T-117 Upland Study Area were inspected
and attempts were made to sample solids that had accumulated on both the outside 
(i.e., retained outside the catch basin by hay bales) and inside of the catch basins. Only
CB-3 had accumulated sufficient solids both on the inside and outside for sampling; 
CB-5 had accumulated sufficient solids only on the outside. These samples were
analyzed for dioxins and furans, arsenic, copper, silver, total petroleum hydrocarbons
(TPH), PCBs, and polycyclic aromatic hydrocarbons (PAHs); and the results are
presented on Table 2-1. 
Table 2-1.  Summary of 2009 T-117 Upland Study Area catch basin sampling 
results 
Concentration 
CB-3          CB-5 
ChemicalContaminant    Ooutside    Iinside    Ooutside 
Metals (mg/kg) 
Arsenic                    7        10.0 U      10.0 U 
Copper                 121       146       131 

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Concentration 
CB-3          CB-5 
ChemicalContaminant    Ooutside    Iinside    Ooutside 
Silver                       5.2         4.2          2 
Dioxin and Furans (ng/kg) 
Dioxin/furan TEQ            49.11       na       152.9 
TPH (mg/kg) 
TPH  diesel range           3,050      2,900      1,830 
TPH  gasoline range          14        na        5.6 
PAH (mg/kg) 
cPAH TEQ             0.49      0.24      0.24 
PCBs (mg/kg) 
Total PCBs                1.6        16        1.1 
cPAH  carcinogenic polycyclic aromatic hydrocarbon 
na  not analyzed (insufficient sample volume) 
PAH  polycyclic aromatic hydrocarbon 
PCB  polychlorinated biphenyl 
TEQ  toxic equivalent 
TPH  total petroleum hydrocarbons 
U  not detected at given concentration 
Based on the higher- than- expected concentrations of PCBs and dioxins and furans
detected during Based on the September 2009 catch basin sampling event,results, site
inspections were conducted in early November 2009 in order to better document the
site stormwater drainage and potential sediment contaminant sources. Based on these
inspections, Aa stormwater solids control plan (Chen and Hainsworth 2009) was
developed as a result of these in inspections. The plan included and
recommendationsed that site maintenance activities be performed to reduce potential
sources of contaminants to stormwater and to reduce and /control the runoff of
stormwater solids. Site maintenance was conducted in late December 2009 and
included the following: 
Cracks in the asphalt cap throughout the site were sealed with asphalt sealer. 
Gaps above and below the ecology block retaining wall were sealed. 
Site vegetation was cut back. 
The asphalt surrounding all catch basins was washed down. 
The interiors of all catch basins were cleaned out. 
New hay bales and sediment filter socks were installed at all catch basins. 

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The site maintenance activities were documented in the sixth semi-annual TCRA
O&M report (AECOM 2009d), which was submitted to EPA on December 28, 2009,
along with a catch basin sampling memorandum that described the September catch
basin sampling events (Huntington and Hainsworth 2009). 
A vegetated drainage ditch/swale on the southern boundary between Boeing South
Park and T-117 Upland Study Area also collects roof drainage from the warehousea 
building on the south end of the T-117 Upland Study Area. This ditch discharges to 
the shoreline mudflat area in the LDW. The runoff from the hillside along the Boeing
property appears to flow east along the toe of slope and then enter the trench drain on
the westsouth side of the building that eventually drains to CB-5 (Map 2-2). 
Adjacent Streets and Residential Yards Study Area 
Stormwater runoff from the Adjacent Streets and Residential Yards Study Area is
currently collected in two separate systems that can be roughly divided into areas
west and east of 17th Avenue S (see Map 2-2). To the west, runoff is currently
discharged to the CSS. As part of its independent cleanup action in the Adjacent
Streets in 2004 (see Section 2.2.4), the City installed a temporary stormwater collection
and treatment system to control runoff from the newly paved streets and associated
1.8-acre catchment area adjacent to the T-117 Upland Study Area. The triangle of
roadway that includes 17th Avenue S, Dallas Avenue S, and S Donovan Street
currently drains to this temporary system, which is used to collect and s, store 
stormwater.s Retained stormwater is periodically released in , and batch discharges
stormwater to the CSS at S Donovan Street and 17th Avenue S (Map 2-2). Because the
CSS is over capacity in this area, stormwater is only discharged to the CSS during
periods of dry weather to prevent sewer backups. 
During construction of the 2004 independent cleanup actions, a temporary stormwater
treatment system was also installed to treat runoff during construction. Discharges to
the CSS were permitted under a discharge authorization with King County Industrial
Waste. Five 18,000-gal. storage tanks were installed to hold water for testing and to
regulate the rate of stormwater discharge to the CSS. The permit (No. 4072-04) list
conditions for both active stages and the non-active stage. Active stages are periods
when active remediation and construction are occurring, and the non-active stage is
the period of operation between interim and final removal actions. In addition to
general stormwater permit conditions, special conditions of the permit for the
non-active stage include the following: 
Collected stormwater must be pumped to appropriately sized settling tanks. 
Discharge must be monitored as follows: 
PCBs - monthly 
Discharge rate  daily 
Discharge rate daily maximum  monthly 
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Maximum discharge is 100,000 gallons per day 
The PCB discharge limit per Aroclor is 0.513 g/L (parts per billion). 
SPU must contact King the County at least 15 days before the NTCRA (removal
action) project begins. 
Initial testing of stormwater solids in 2004 and 2005 resulted in occasional detections
of PCBs up to 2.3 g/L. The treatment system was removed in April 2005 because the
testing that has been conducted since January 2005 showed that PCBs were no longer
detected (at a DL of 0.1 g/L) in stormwater runoff from streets adjacent to T-117.
Stormwater continues to be discharged to the CSS via this system during dry
conditions through a discharge authorization with the County. The County requires
the stormwater to be tested each month when discharges occur. There has been one
detection (0.12 mg/kg in January 2008) since treatment was discontinued
(Appendix C). 
Under an arrangement with the Port, the City has a provision to discharge water from
this system to the southern drainage system on the T-117 Upland Study Area as an 
emergency overflow during the rainy season (due to the over capacity condition of the
CSS described above). Discharges to the Port system generally occur under the
following conditions: 
Very Iintense storm events that exceed the capacity of the storage tanks 
Periods of prolonged rainfall, which cause the tanks to fill up when stormwater
cannot be discharged to the CSS 
Cold weather conditions when the storage tanks and associated piping must be
drained to prevent the pipes from freezing and breaking. When cold weather is
predicted, the valves to both the CSS and the Port drainage system are fully
opened to rapidly drain the system 
Since 2005, 11 emergency discharge events have occurred.2 Given the infrequent
nature of the overflows to the LDW, SPU has not tried to develop direct correlations 
between rainfall events and overflows from the tanks. The tanks hold about 90,000 ft3
of runoff. The tanks fill up after approximately 2.25 to -2.5 in. of rain accumulates,
either in a single event or multiple back- to- back storms. During the emergency
discharges, runoff from the temporary system is discharged to a catch basin located at
the northwest corner of the south building on the T-117 Upland Study Area. Runoff is
conveyed in a pipe that runs along the north side of the building and discharges to the
pavement at the northeast corner of the building. From there, runoff sheet flows
approximately 60 ft across the pavement to CB-5 on the T-117 Upland Study Area. 
2 The 11 discharges occurred on December 24 through- 27, 2005; January 1 through - 3, 2006;, January 6
through - 16, 2006; January 29 through -February 1, 2006; November 6 through - 30, 2006; December
12, 2006 - through January 5, 2007; January 7, 2007; December 3 through - 7, 2007; December 20, 20/07
through - January 2, 2008; January 15 through - 17, 2008; October 17 through - 19, 2009. 
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The City intends to replace the temporary stormwater system with a permanent
stormwater collection and treatment system in accordance with Seattle Municipal
Code (SMC) 22.800 and Directors' Rule 2009-005 (SPU), 17-2009 (Department of
Planning and Development [DPD]) (City of Seattle 2009b) as part of the removal action 
in the Adjacent Streets. Options for Aa new, permanent collection and treatment
system to be installed in the Adjacent Streets following the removal action is included
in the removal action alternatives describedare identified in Section 7. 
South Park Marina Properties 
Stormwater runoff from the south and east end of the Marina discharges directly to
the LDW via a private drainage system (SAIC 2007b). The Marina operates a closedloop
boat pressure wash system in the southeast portion of the property near the T-117 
Upland Study Area. The wash system is located in the vicinity of the southern-most
catch basin on the Marina property that discharges through a general stormwater
National Pollutant Discharge Elimination System (NPDES)-permitted shoreline outfall 
fitted with an oil/water separator and a sand filter (StormwateRx) treatment system.
The Marina has been sampling and analyzing the discharge from this outfall for oil
and grease, total recoverable copper, and total suspended solids as required under its
NPDES permit. 
Stormwater from the north end of the Marina property is believed to discharges 
directly to the LDW (Crow 2010). , although the private drainage system on the
property has not been fully mapped (SAIC 2007b). The Marina's storm drain system is
shown on Map 2-2.Because the onsite catch basins are near the LDW (as shown on
Map 2-2) and downgradient from the CSS on Dallas Avenue S, stormwater from these
catch basins is likely discharging to the LDW rather than being pumped to the CSS.
However, further site investigation (e.g., dye testing) would be needed to confirm
whether these onsite catch basins discharge to the LDW. 
Stormwater runoff from the Marina property located at the southeast corner of 16th 
Avenue S and Dallas Avenue S, which is used for additional dry boat storage, most
likely enters the City catch basins located on 16th Avenue S, which convey stormwater
to the City's CSS. Some drainage from this location may also flow onto Dallas Avenue
S and into the LDW via the T-117 Upland Study Area catch basins. 
Boeing South Park 
To the south of the T-117 EAA at Boeing South Park, two privately owned outfalls 
discharge to the LDW. The northernmost outfall used to discharge non-contact cooling
water from Boeing South Park under an NPDES permit. This practice was
discontinued in 1993, and the cooling water was re-routed to the sanitary system
(Ecology 1993b). Currently, both outfalls appear to discharge only stormwater;
however, stormwater drainage patterns associated with Boeing South Park have not
been identified. 
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2.1.4  Current land use, zoning, ownership, and activities 
This section describes the current land use, zoning, ownership, and activities for the
T-117 EAA. 
2.1.4.1  Land-use, zoning, and ownership 
The T-117 EAA and vicinity are zoned3 as mixed-use for residential, commercial, and
industrial activities (City of Seattle 2007a), as shown on Map 2-3. Current land use in
the area is primarily manufacturing, commercial, and residential. Properties located
on the east side of Dallas Avenue S in unincorporated King County include: 
The Marina, which is primarily used for boat storage and maintenance, as well
as the moorage of live-aboard and recreational vessels. The upland portion of
the Marina is currently owned and operated by South Park Marina Ltd.
Partners. The eastwest portion of the Marina lies within the Duwamish
Commercial Waterway District boundary. 
The former asphalt plant parcel, which is currently owned by the Port and was
formerly used for manufacturing and industrial activities, including asphalt 
materials manufacturing. The site has been vacant since 2007. 
A portion of the Boeing South Park facility, which is currently owned by The
Boeing Company and is primarily used as a training center. 
Properties to the west of Dallas Avenue S, include: 
The former Basin Oil plant (a used oil and antifreeze processing facility that
ceased operations in 2004) at 8661 Dallas Avenue S, which is currently owned
by Basin Oil Company. This property was residential prior to being used for
industrial purposes. 
A property at 8617 17th Avenue S formerly used by Basin Oil for excess drum
storage until this parcel was purchased by the Marina for boat storage in
August 2007. This property was residential until November 1998 when it was
sold to Basin Oil and was subsequently used for industrial purposes. 
The former residential parcel located at 8603 Dallas Avenue S used by the
Marina for boat storage. 
Commercial and residential parcels bounded by Dallas Avenue S, 16th Avenue
S, and S Donovan Street, including three commercial parcels (and a boat storage
area), two residential parcels, and one apartment complex. West of 16th, there
are 22 residential and six commercial parcels on the east side of 14th Avenue S. 
A commercial/warehouse facility at 8620 16th Avenue S. The property has been
occupied by Caff Umbria Inc. (a wholesale coffee roaster) since 2008. Former
occupants were the Seattle Chocolate Company (a chocolate confectionery
3 Zoning designation based on a 2002 City of Seattle GIS layer, as shown on Map 2-2. 
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company that ceased operations in 2007), Allied Bolt Company (metal
fabrication), and Fasteners, Inc. (metal fabrication). 
The Basin Oil parcels and the Boeing South Park parcels within the City limits are
zoned as manufacturing/industrial; the parcels between 16th Avenue S and 17th 
Avenue S are zoned as industrial buffer. Parcels west of 16th Avenue S and north of S
Donovan Street are zoned as residential/commercial and include approximately
20 houses and one 12-unit apartment complex (Map 2-3). 
2.1.4.2  Commercial and residential activities 
As previously described, there are several residences as well as various commercial
and manufacturing facilities within the vicinity of T-117 EAA. Because the T-117
Upland Study Area and T-117 Sediment Study Area have restricted access, public
activities within these areas are limited. Access to the Sediment Study Area is
restricted by a secure fence surrounding the T-117 Upland Study Area, but is
accessible from the LDW by boat and kayak. The Muckleshoot Tribe has a commercial
salmon fishery in the LDW, uses portions of the T-117 Sediment Study Area for tribal
fishing, and thus may come in contact with the sediment. Within the Adjacent Streets
and Residential Yards Study Area, residential activities could include, but are not
limited to, recreation activities such as jogging or biking, or typical residential
activities such as walking, yard work, or driving. Workers may also access the T-117
EAA to service utilities, which may require digging in the Adjacent Streets as well as
on the T-117 Upland Study Area. Exposure scenarios associated with these site uses
are evaluated in Section 3.2. 
2.1.4.3  Recreational activities 
The LDW is not a major recreational resource compared to other water bodies in and
around the City (King County 1999b). The Duwamish River Cleanup Coalition, a
consortium of environmental and citizen groups that participate in cleanup efforts, has
coordinated activities to improve habitat and recreational activities. The group has
been conducting kayak tours on the LDW and asserts, but anecdotal evidence from
community members suggests that recreational use of the LDW has been increasing,
including guided kayak tours of the LDW and shoreline access at new parks and
restoration sites (EPA 2010). Few data that quantify the frequency with which people
use the river for recreational purposes have been identified. The County's human
health risk assessment (HHRA) (King County 1999b) discussed the human use of both
the LDW and Elliott Bay, but presented quantitative data only for fishing. The County
study assumed that few, if any, people engage in activities such as swimming, scuba
diving, and windsurfing within the LDW. There are several public access points along 
the LDW and recreational boating and kayaking in the LDW have been observed as
part of a survey for the LDW RI (Windward 2005b). The Marina and a public boat
launch north of the Marina are the closest recreational boating access points to the
T-117 EAA. There is no known use of T-117 as a boat put-in or haul-out location. Such
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use is unlikely because the T-117 shoreline is steep and overgrown and the T-117
Upland Study Area is secured by a fence. However, the T-117 shoreline and intertidal
mudflat is accessible from the LDW by boat. 
In the County survey of fishing and seafood consumption practices (King County
1999b), none of the LDW sites identified as locations where recreational fishing
occurred were near the T-117 EAA. However, recreational fishing may occur from the
Marina or from boats in the vicinity of the T-117 EAA. There are no recent data on
seafood consumption rates specific to the LDW, but current consumption rates may be
suppressed. There are several possible explanations for such suppression, including
the current advisory against the consumption of resident fish and shellfish, media
coverage of the published risks from the consumption of LDW seafood, and the close
proximity of more desirable fishing locations outside the LDW. The T-117 EAA is
within tribal Usual and Accustomed fishing areas, and the tribes desire the restoration
of shellfish and fisheries resources. 
2.1.5  Physical environment 
This section describes the physical features associated with both the aquatic and
upland portions of the T-117 EAA. Sections 2.1.5.1 and 2.1.5.2 discuss the aquatic
portion of the site; Section 2.1.5.3 focuses on the upland environment. 
2.1.5.1  Currents, circulation, and estuarine features 
River currents in the Sediment Study Area have not been specifically measured.
However, the results of a site-wide hydrodynamic model developed as part of the
LDW RI (Windward 2007c) can be generally applied to T-117 insofar as the model
provides information regarding the currents of the LDW as a whole. The model may
be less useful for capturing hydrodynamics in near-shore and shallow areas within the
T-117 Sediment Study Area. 
Water currents within the LDW are driven by tidal actions and river flow; the relative
influence of each is highly dependent on seasonal river discharge volumes. Fresh 
water flowing downstream overlies the tidally influenced salt water that enters the
system. The LDW is tidally influenced to the head of the estuary at RM 12.0 (Kerwin
and Nelson 2000), with the degree of tidal influence varying depending on stream
flow and tidal stage. 
Tidal action significantly influences currents and water elevation in the LDW. The
average tidal range is -0.91 to 12.81 ft MLLW.4 Typical of tidally influenced estuaries,
the LDW has a relatively sharp interface, or wedge, between the freshwater outflow at
the surface and saltwater inflow at depth. Tidal effects and the volume of river flow
also control the movement of the saltwater wedge. The toe of the saltwater wedge is

4 Information based on National Oceanic and Atmospheric Administration (NOAA) Center for
Operational Oceanographic Products and Services National Tidal Datum from 1993 to 2003. 
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generally located between Slip 4 (approximately 0.8 RM north of T-117) and Turning
Basin 3 (approximately 1 RM south of T-117) (Santos and Stoner 1972). Salinity
measurements by Santos and Stoner (1972) at RM 3.2, just downstream from T-117,
indicated that at this location, the estuary had freshwater at all points in the vertical
profile only when there was a combination of very low tide and high rates of river
flow. Dye studies indicated that downward vertical mixing over the length of the
saltwater wedge was almost nonexistent (Schock et al. 1998). 
The Green River is the main source of water for the LDW. Average downstream flow
for the Duwamish River measured at the Tukwila gauging station was 1,533 cubic feet
per second (cfs) during 2003-2004, ranging from 327 cfs in August to 3,290 cfs in June 
(Clemens 2007). Flow at the Auburn gauging station ranged from 152 to 11,600 cfs (the
record high) between 1962 and 2004 (Clemens 2007). Between 2000 and 2006, the
annual average flow rate measured at the Auburn gauging station was 1,190 cfs,
ranging between 850.6 cfs and 1,413 cfs (USGS 2007). Flow rates are greatest in the
winter because of seasonal precipitation and lowest throughout the late summer dry
season. 
Stream flow to the LDW is also influenced by water diversions, particularly by the
City of Tacoma's Headworks Dam, located on the Green River, which diverts at least
113 cfs daily for municipal use. The Howard Hanson Dam (located upstream of the
City of Tacoma's Headworks Dam) also influences flows in the river. Information on 
the estimated influence of the Howard Hanson Dam on flow rates (Kerwin and Nelson
2000) indicates flow rates in the Duwamish River have been reduced by 33 to 60%,
depending on the season. The historical diversion of the White, Black, and Cedar
Rivers from the Green/Duwamish River system resulted in a reduction of
contributing flow by approximately 70% to the system, and an a accompanying 
reduction in total discharge for the Duwamish River. 
LDW Stream flow is also influenced by inflows from surface water sources such as
storm drains, CSOs, tributary creeks, and nonpoint inputs, although these sources are
expected to be less than 1% of the total discharge, even during peak flow events
(Windward 2007c). Two main tributary creeks drain into the LDW: Puget Creek at
approximately RM 0.7 (downstream of the T-117 EAA) and Hamm Creek at
approximately RM 4.2 (upstream of the T-117 EAA). 
2.1.5.2  Sediment transport 
LDW-wide investigations have been conducted that provide some insight into
hydrodynamic and sediment transport conditions at T-117 within the river. Sediment
transport within the LDW, including the T-117 EAA, is influenced by many variables,
including hydrodynamic forces attributable to currents and circulation driven by tidal
actions and river flow, the saltwater wedge, sediment loading from upstream and
upland sources, channel morphology, and resuspension processes (i.e., propeller
scour, bioturbation, bed shear stress, and dredging). As part of the LDW RI, sediment
transport data were collected throughout the LDW (Windward and QEA 2005) to
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enable a better understanding of the LDW sediment transport process and the
development of a LDW-wide sediment transport model (STM) (QEA 2008). The results
of these investigations and analyses can also be used to evaluate sediment transport
conditions in specific areas of the LDW, such as the T-117 EAA, but the accuracy of the
model at such small scales is highly uncertain. Consequently, predictions from the
STM for the T-117 Sediment Study Area did not influence the development of removal
action alternatives. The LDW-wide STM indicated that the T-117 Sediment Study Area
was net depositional over annual time scales. Along most of the T-117 Sediment Study
Area, the predicted net sedimentation rate for a 30-yr period ranged from 0 to 0.5
cm/yr, except along the northern portion of the T-117 EAA at the Marina interface,
where the net sedimentation rate was estimated to be > 3 cm/yr. 
The LDW-wide STM included simulations of high-flow events (i.e., events with return
periods of 2, 10, and 100 years) that occur over time scales of several days and
simulations that focused on sediment deposition patterns over longer time scales (i.e.,
30 years). A separate model was used to evaluate ship-induced mixing of surface
sediment (QEA 2008). 
The simulation of high-flow events indicated that in the southern and central portion
of the Sediment Study Area, no more than 2 cm of net erosion is estimated to occur 
during the 2- and 10-yr high flow events (Map 2-4), while up to 6 cm of net erosion is
estimated to occur during the 100-yr event (Map 2-4). In contrast, no net erosion is
predicted for the northern portion of the site, even during the 100-yr high-flow event
(Map 2-4). 
The LDW-wide STM evaluated deposition patterns over a 30-yr time scale. Although
short-term events such as those described above may cause periodic erosion, results of
the longer-term analysis indicated that the T-117 EAA Sediment Study Area was net
depositional over annual time scales. Along most of the T-117 EAA, the predicted net
sedimentation rate for a 30-yr period ranged from 0 to 0.5 cm/yr, except along the
northern portion of the EAA at the Marina interface, where the net sedimentation rate
was estimated at > 3 cm/yr (Map 2-5). Although the results from this LDW-wide
modeling effort provide insight into broader trends in the vicinity of the T-117 EAA,
the spatial heterogeneity of the model predictions within and adjacent to the T-117
EAA suggests that the area is in a transitional location with regard to both erosion and
sedimentation rates. The modeling results also indicate that some net erosion, on the
order of 0 to 6 cm, may occur along most of the T-117 EAA shoreline during high-flow
events, but net deposition may occur in the vicinity of the Marina. 
The investigations of ship traffic presented in the STM report indicated that ship
activity is not a major cause of sediment transport in the LDW (except in ship berthing
areas) or in the T-117 EAA (QEA 2008). 
Several organizations have measured current velocities within the LDW as part of
environmental investigations. The most extensive measurements within the LDW
have been conducted by the County. Current velocity meters were placed at two
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locations in the LDW (RM 1.1 and RM 3.5) for a 3-month period and recorded currents
at 15-minute intervals along a vertical profile (King County 1999a). During this study,
measured current velocities within the LDW rarely exceeded 40 cm/s (1.3 ft/s).
Another study of current velocities involved the deployment of two current velocity
meters for two 4-week periods at RM 1.1, which is a straight portion of the LDW
located just south of Kellogg Island (King County 2005). One meter was placed near
the center of the navigation channel; the other was placed on a shallower channel side
slope. Reported mean net current speeds for meters placed in the center of the channel
ranged from 2.5 cm/s (0.082 ft/s) (at 25% channel depth) to 18 cm/s (0.59 ft/s) (at 10%
channel depth). Mean net current speeds for meters placed at the channel side slope
locations ranged from 1.3 cm/s (0.043 ft/s) (at 25% depth) to 8.9 cm/s (0.29 ft/s) (at
10% depth). Currents were predominately oriented along the channel, and velocities
were generally slower along the side slopes. 
2.1.5.3  Geology 
Geology of the Duwamish Basin 
The Greater Duwamish Valley was formed by the carving action of glaciers that last
advanced into this area from British Columbia approximately 15,000 years ago. When
the ice sheets began to retreat approximately 5,700 years ago, the waters of Puget
Sound extended up the Duwamish Valley as far south as Auburn, about 32 km (19 mi)
upstream of the present mouth of the LDW at Elliott Bay. Around that same time, the
Osceola Mudflow descended from Mount Rainier, depositing a massive layer of
sediment into the then marine waters near present-day Auburn and Kent. The
mudflow diverted the historical course of the White River, at that time a tributary of
the Puyallup River, to the Green River (Booth and Herman 1998). 
The alluvial fill within the Duwamish Valley deepened over time from the deposition
of upstream fluvial sediments of the White, Green, and Black Rivers, advancing the
mouth of the Duwamish River farther to the north. The fill included beds of fine silts
and sands deposited as riverine and floodplain deposits, with coarser sands and
gravels deposited near the water's edge. These sediments eventually buried the
post-glacial form of the valley so that only a few outcroppings of bedrock remain
exposed at the ground surface. As the river flooded and migrated back and forth
across the floodplain, these sediments were re-deposited by the river and continually
intermixed with additional riverine and floodplain deposits (Booth and Herman 1998). 
In the late 1800s and early 1900s, extensive modifications were made to the river,
including the filling of tide flats and floodplains to straighten the river channel,
resulting in the abandonment of almost 6 km (3.7 mi) of the original meandering river
bed (Map 2-64). Several current side slips in the LDW are remnants of these old river
meanders. The channel was dredged for navigational purposes, and the excavated
material was frequently used to fill the old channel areas and the lowlands to bring
them above flood levels. The portion of the LDW at the T-117 EAA was a new
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alignment, dredged and excavated as part of the "straightening" of the river. A former
filled meander (oxbow) intercepts the shoreline in the vicinity of the north portion of
T-117. Because the dredge fill materials were similar to the native deposits, they are
difficult to distinguish from the native silts and sands. Subsequent filling of the
lowlands for continued development resulted in a surficial layer of fill over most of
the lower Duwamish Valley. Although the sediment types encountered in the LDW
are variable (either from changing regional or local hydrodynamics or anthropogenic
disturbances), basic sedimentary patterns of interbedded silts and sands are present in
the LDW (Booth and Herman 1998). 
The three principal geologic assemblages within the Greater Duwamish Valley that
establish the regional hydrogeologic system, from oldest to youngest, are: 
Bedrock 
Glacial and non-glacial sedimentary units (glacially overridden and dense units
that make up the plateaus to the east and west of the Duwamish Valley) 
Undifferentiated quaternary alluvial deposits (principal aquifer and
groundwater pathway for the Duwamish basin) 
Bedrock 
Bedrock in the Greater Duwamish Valley provides the lower boundary of the aquifer
system and limits groundwater flow in the basin. At the north end of the Duwamish
Valley, the elevation of the bedrock unit ranges from roughly 60 m (200 ft) to over
500 m (1,640 ft) below ground surface (bgs). Exposed bedrock in the eastern and
southern areas of the Duwamish Valley is predominantly marine and continental
sedimentary rocks intermixed with isolated areas of igneous rock deposited during the
Tertiary period. Sedimentary rock units within the Greater Duwamish Valley are not 
an important source of groundwater because the predominantly cemented,
fine-grained nature of the material precludes rapid groundwater movement.
However, igneous rock layers are extensive in the area and can store and move water
much more readily (Booth and Herman 1998). 
Glacial and Non-Glacial Sedimentary Deposits 
The glacial and non-glacial sedimentary units within the Duwamish basin are complex
sequences of interbedded and unconsolidated deposits. In areas where bedrock occurs
at significant depth below the river valley, these glacial sedimentary deposits serve as
the lower boundary of the alluvial deposits in the Greater Duwamish Valley. The
upland plateau areas to the east and west of the valley are formed predominantly of
these glacially deposited sedimentary units (Booth and Herman 1998). 
Little information on the glacially overridden sedimentary units within the LDW
study area is available. These overridden deposits are mainly fine-grained materials;
their maximum depth is unknown (Booth and Herman 1998). Although these deposits
provide a geologic boundary to the overlying alluvial deposits, they also provide a
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potential hydraulic pathway for the flow of upland groundwater to the Duwamish
Valley alluvial sediments. 
Thick sequences or silt beds (transitional beds) could potentially limit the upland
inflow of groundwater where these deposits occur. The presence of saline water in the
deeper alluvial sediments outside of current tidal influence areas suggests that there is
little influx of fresh water into the original marine delta deposits. The lack of fresh
groundwater in these deep alluvial sediments may indicate that the inflow of upland
groundwater in this layer is limited (Booth and Herman 1998). 
Duwamish Valley Alluvial Deposits 
The near-surface alluvial deposits in the Duwamish River valley extend to a depth of
roughly 60 m (200 ft) bgs within a trough bounded between the bedrock unit and the
very dense upland glacial and non-glacial sedimentary deposits. The geologic history
of this valley suggests that the alluvial deposit sequences include estuarine deposits,
typically fine sands and silts (often including shell fragments), which progress upward
into more complex, interbedded river-dominated sequences of sand, silt, and gravel.
These layers of alluvial deposits delineated the areas of advancing river delta
sedimentation that increase in thickness from south to north (Booth and Herman
1998). 
Geology of the T-117 EAA and Vicinity 
A summary of geotechnical information for the west shore of the LDW indicates that
upland portions of the T-117 EAA consist of shallow fill. The alluvium underlying the
fill extends to a depth of approximately 95 ft (29 m) bgs and consists of discontinuous
silt units with interbedded sands, silty sands, and some gravel. Thin peat deposits
have also been encountered. A fine-grained lower unit that contains shell fragments
has been observed in borings beneath the lower silt, and dense sand and gravel were
reportedly observed at depths below 95 ft (29 m) bgs (Wilbur Consulting 2003). A
Geologic cross sections of the T-11 EAA areis provided as Figures 2-1 through 2-5. 






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Slipsheets (11 x 17) 
Figure 2-1. Geologic cross section of the T 117 EAA 
Figure 2-1. Cross section locations 
















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Slipsheet (11 x 17) 
Figure 2-2. Geologic cross section A-A of the T-117 EAA 

















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Slipsheet (11 x 17) 
Figure 2-3. Geologic cross section B-B of the T-117 EAA 

















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Slipsheet (11 x 17) 
Figure 2-4. Geologic cross section C-C of the T-117 EAA 

















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Slipsheet (11 x 17) 
Figure 2-5. Geologic cross section D-D of the T-117 EAA 

















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Geology of the T-117 Upland Study Area and Adjacent Streets 
According to the results of previous site characterization activities at the T-117 Upland
Study Area (Parametrix 1991; RETEC 2007b; SECOR 1997; Windward and DOF 2006),
subsurface soil at the T-117 EAA consists of fine to medium sand, sand/silt mixtures,
and silt. Shallow soils typically consist of fill material that ranges from 3 to 10 ft in
thickness, with the fill thickness increasing toward the LDW. This fill consists of sand
with varying amounts of silt mixed with anthropogenic materials (e.g., bricks, rubble,
and wood). Shallow boreholes typically terminate in a silt unit present beneath the fill.
All stratigraphic information from below the fill/silt contact has been provided by a
geotechnical borehole advanced along the west bank of the LDW (Hart Crowser,
2003). This borehole indicated that the silt unit is 10 ft thick and is underlain by a sand
unit that is about 20 ft thick. Silt and sand interbeds are present beneath the sand unit. 
A bedrock outcropping, which is unique within the Duwamish valley, is present
immediately south of the T-117 EAA (Booth and Herman, 1998). This bedrock was has
been encountered during geotechnical explorations on the Boeing South Park property
at elevations above 40 ft MLLW ( Dames and Moore, 1980a and b), which is above the
ground surface elevation of the T-117 Upland Studay Area the installation of MW-13
by Ecology. The influence of this formation can be seen in the upper elevation of the
till in the geologic cross sections (Figures 2-1 through 2-5). This formation may also 
influence local hydrogeology. 
T-117 Upland Study Area soil has been modified by the 1999 and 2006 TCRAs. The
removal area that was excavated for the 1999 TCRA (Onsite 2000a) was backfilled with
fill and quarry spalls (i.e., large angular rocks) to depths ranging from approximately
2 to 6 ft. This backfill was overlain with an asphalt pavement system (i.e., gravel
subgrade and bituminous pavement) that was approximately 1 ft thick. The removal
area that was excavated for the 2006 TCRA (RETEC 2007b) was backfilled with
crushed rock to depths ranging from approximately 2 to 7 ft and covered with asphalt
pavement. 
Site characterization work conducted by the City in the Adjacent Streets determined
that the soil gradation is generally fill material (asphalt and gravel with fines) in the
top 1 to 2 ft underlain by silts, sandy silts, and a characteristic native sand deposit
observed throughout most of the site (Integral 2006b). The depth to the native sand
unit varied approximately as follows: 
4 to 6 ft at Dallas Avenue S, between 14th Avenue S and 17th Avenue S 
2 to 5 ft at Dallas Avenue S, between 17th Avenue S and S Donovan Street 
9 to 10 ft at S Donovan Street, between 17th Avenue S and Dallas Avenue S 


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2.1.5.4  Hydrogeology 
The shallow unconfined aquifer in the Duwamish River valley is generally located
within the native alluvium unit. At T-117, shallow groundwater extends upward into
the overlying sand and silt fill, and water table fluctuations are influenced by river
level fluctuations in the LDW. Groundwater is recharged from the upland areas to the
west (Wilbur Consulting 2003), and net groundwater flow is toward the LDW as
shown on Map 2-75. 
Recent groundwater level data collected in 2008 and 2009 (ENSR|AECOM 2008;
AECOM 2009a) indicate that the groundwater table within the T-117 EAA occurs
between approximately 7.4 and 13.0 ft MLLW (Map 2-75). Tidal influence has been
observed in all monitoring wells on the T-117 Upland Study Area (MW-2 through 
MW-8) and was confirmed by tidal study piezometric measurements made in 1998,
2003, 2006, and 2008 (SECOR 1998; Windward et al. 2005b; Windward unpublished;
ENSR|AECOM 2008). During these tidal studies, the water levels in the LDW varied
by up to 13 ft, from extreme high to extreme low tide, and water levels in the T-117
shoreline wells typically varied by 3.2 to 8 ft. The magnitude of the water level
variation decreased inland with no tidal influence observed in the wells located on
Dallas Avenue S (MW-01, MW-09, and MW-10) (ENSR|AECOM 2008). Based on this
information, tidal influence becomes negligible somewhere between about 80 ft (MW-
03) and 230 ft (Dallas Avenue S) from shore. An earlier investigator reported that the
tidally influenced area adjacent to the waterway is generally within 300 to 500 ft of the
shoreline (Booth and Herman 1998). 
At T-117, the groundwater gradient reverses during high tide, causing water from the
LDW to flow into the aquifer and mix with groundwater. Once the tide has ebbed,
groundwater flowing from the aquifer into the LDW is a mixture of groundwater and
surface water from the LDW. The degree to which surface water enters and exits the
aquifer during the tidal cycle has ramifications for groundwater characterization. Tidal
influence was measured in all shoreline wells and in well MW-03, which is located
approximately 100 ft from the LDW (Map 2-75). In addition, the use of a pumping well
at this location could create a drawdown at significant distance, though much less
than the 1,000 ft noted by Herman and Wineman (1997). Under these conditions, the
infiltration of surface water from the adjacent LDW would occur across the entire
vicinity of the T-117 Upland Study Area. Appendix B discusses this issue in more
detail and provides an estimate of tidal mixing based on empirical data and modeling
studies. 
Groundwater and surface water interactions also affect the salinity of the groundwater
at the T-117 EAA. Specific conductance, a proxy for salinity, is elevated in shoreline
wells. This is likely due to the infiltration of brackish surface water from the LDW.
Specific conductance is also elevated in several other wells that are not adjacent to the
LDW. The highest specific conductance measurements were taken at MW-13, which is
located near a bedrock outcropping at the Boeing property to the south. It is likely that
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the elevated specific conductance is due to upwelling of more saline groundwater
from the lower aquifer along preferential flow paths adjacent to the bedrock in the
vicinity of MW-13 (Booth and Herman 1998). The lower aquifer in this area is more
saline because of historical interactions with Puget Sound (Herman and Wineman
1997) (see Appendix B for a full discussion of specific conductance in groundwater at
the T-117 EAA). 
Horizontal groundwater gradients were determined based on the net groundwater
flow (Map 2-5). Two horizontal gradients were determined for the site, one between
MW-10 and MW-12 and a second between MW-03 and the shoreline well MW-05R. 
The horizontal gradient in the vicinity of MW-10 and MW-12 is 0.076 ft/ft, and the
horizontal gradient in the vicinity of MW-03 and MW-05R is 0.009 ft/ft. 
Hydraulic conductivities for typical silty sand units, such as the T-117 EAA fill soil,
range from 10-1 to 10-5 cm/s. Site- specific data for groundwater in the upper portion
of the native alluvium was used to estimate Silt units, such as the upper portion of the
native alluvium that is immediately below the fill unit, typically have hydraulic
conductivities ranging from 10-3-1 to 10-7-3 cm/s (Freeze and Cherry 1979). 
Seeps have been observed at the base of the shoreline riprap (at the mudline) near the
central portion of T-117 Sediment Study Area and south of the Marina boat ramp
during low tides. Two seeps appear to be well established, as demonstrated by the
channels that have been cut into the tide flats between the seep locations and the main
river channel. Several minor seeps have also been observed along the T-117 EAA
shoreline, but the flow is intermittent and not as pronounced. One of the well
established groundwater seeps (Seep 2 (SW-2), shown on Map 2-1) appears to emerge
adjacent to a wooden pile, which suggests that the pile may have intercepted a locally
confined lower sand unit. The possible sources and control of these seeps will be 
addressed during the remedial design phase of the NTCRA. 
2.1.6  Sensitive ecosystems and habitat 
Sensitive ecosystems and habitat in the T-117 EAA are limited to the aquatic sediment 
portion of the site. The upland portion of the EAA is developed and lacks sufficient 
substantial habitat to support wildlife, as described in a terrestrial ecological
evaluation (TEE) conducted for the Adjacent Streets (Integral 2006b). 
Estuarine intertidal and near-shore subtidal ecosystems in the LDW provide important
habitat for juvenile salmonid growth, physiological transition, and predator avoidance
during their outmigration. The estuarine environment also provides refuge for various
marine fish during larval stages and supports an array of preferred prey for all
salmonid life stages. The intertidal zone in the LDW is located approximately between
-4 ft and +13 ft MLLW, and the near-shore subtidal zone is just slightly deeper than
the intertidal zone. 
Within the intertidal areas, mudflats serve many ecosystem functions, including
providing food and habitat for benthic invertebrates, fish, shorebirds, and aquatic
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mammals. A diverse assemblage of invertebrate species, including larvae, clams,
worms, and crustaceans, can be found in these habitats, which typically consist of
unconsolidated silts and clays and sand flats of unconsolidated sandy sediments
(Simenstad et al. 1991). Mudflats containing gravel may support high densities of
bivalve populations. 
The features of the T-117 EAA intertidal mudflat make the area suitable habitat for the
organisms described above as well as provide potentially important habitat for
organisms within the juvenile salmonid food web. The intertidal mudflat of the T-117
EAA extends approximately 15 to 65 ft (4.6 to 20 m) from the immediate shoreline,
around +5 ft MLLW, to a depth of approximately -4 ft MLLW. The T-117 intertidal
mudflat includes more than 43,000 ft2 (4,000 m2) of gently sloping, fine-grained
sediment. An LDW clam survey (Windward 2004) conducted in 2003 identified
harvestable clams within the T-117 intertidal area. 
2.2   PREVIOUS REMOVAL ACTIONS 
This section provides an overview of historical removal action activities and
environmental investigations pertinent to the T-117 EAA. 
Prior to the Port's acquisition of the asphalt plant T-117 Upland Study Area parcel in
20001999, the Malarkey asphalt plant was closed, and a number of storage tanks were
removed or abandoned (i.e., closed in place) as required by EPA in a 1996 AOC for
Removal Action at Malarkey (EPA 1996a). In 1996 and 1997, Malarkey performed tank
and equipment decommissioning and decontamination and removed soil from ditch
areas and the utility corridor (i.e., hot spot removals). Product also was also removed 
from a large-diameter well prior to Port ownership (SECOR 1998). 
All of the tanks were decommissioned and removed from the property prior to the
Port's acquisition in 20001999. The three USTs, which contained diesel and waste oil, 
were filled with concrete slurry and closed in place; a partially buried railroad car,
which was used to hold waste oil, was excavated and removed. Sixteen ASTs were
also removed from the site. Soil samples were taken from the tanks and tested for TPH 
(Hart Crowser 1992). The former locations of these tanks are shown on Map 2-86. 
In 1999, immediately prior to the Port's acquisition of the site, a TCRA for upland soil
was conducted within the T-117 Upland Study Area pursuant to an EPA AOC
(No. 10-2000-0222) (EPA 2000) to remove PCB-contaminated soil from the former
ponding area (see Section 2.2.1 for additional details). Since the 1999 TCRA and the
Port's 2000 acquisition of the former asphalt plant, several actions that focus on the
removal of asphalt plant residues and PCB-contaminated soil from within the T-117
Upland Study Area and Adjacent Streets have been performed by the Port. In 2003,
several old drums and other large debris were removed from the offshore intertidal
area. In 2004, a below-grade utility corridor was cleaned out. In 2006, under the terms
of a separate ASAOC, the Port carried out an additional TCRA to remove additional
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impacted soil with the highest concentrations of the newly discovered PCBs within the
T-117 Upland Study Area. 
In 2004 and 2005, the City implemented a series of independent cleanup actions to
address PCBs discovered in soil in the Adjacent Streets and Residential Yards and
three neighboring residential properties near the T-117 EAA (City of Seattle 2005). The
City removed soil that had PCB concentrations exceeding 1 mg/kg from the
residential yards and unpaved street shoulders and placed a temporary asphalt cap
over residual contamination within the street ROW areas. The action level of 1 mg/kg
was based on the MTCA Method A CUL for PCBs. The current removal actionNTCRA 
boundary for the Adjacent Streets includes the areas whereaddresses remaining
contamination may still be presentin this area. 
The above removal actions conducted in the T-117 EAA are described in greater detail
in the following subsections. The locations of previous removal actions are shown on
Map 2-86. Removal actions conducted in the T-117 EAA are also presented on the
timeline (Figure 1-1). 
2.2.1  1999 TCRAtime-critical removal action 
PCBs were initially detected in surface and subsurface soil in the upland shoreline
parcel (former ponding area) during several investigations in the 1990s. A TCRA 
(Map 2-86) was conducted by the Port in 1999 (Onsite 2000a) to remove PCB 
contaminated soil from an area within the shoreline parcel that contained elevated
concentrations of PCBs based on previous sampling efforts (SECOR 1998, 1997). The
TCRA was performed in accordance with the EPA AOC (No. 10-2000-0222) (EPA 2000) 
and associated SOW. Tasks included: 
Mobilization and site preparation (including installation of drainage controls
and the establishment of controlled work areas) 
Removal, storage, testing, and treatment of water from the ponding area prior
to soil removal 
Containment, testing, and removal (for offsite treatment) of approximately 
50,000 gal. of water during excavation 
Removal from the work area and disposal of several drums that contained 
asphalt 
Excavation and disposal of 2,061 tons of contaminated soil with PCB
concentrations that ranged up to 500 mg/kg 
Removal of shallow (i.e., top 0.5 ft) soil from exposed areas around the former
asphalt plant structures 
Backfilling 
Installation of an asphalt pavement cap 

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Improvement of storm drains (e.g., new catch basins in excavated area) 
Abandonment of the large-diameter industrial water supply well 
Replacement of three monitoring wells removed during the soil excavation 
All material removed from the property was disposed of at approved facilities. The
project's target action level for PCBs in soil was 25 mg/kg, and remaining soil at the
T-117 Upland Study Area was capped with asphalt pavement. The project's target
action level was negotiated with EPA and was premised on the "spill cleanup policy"
value (25 mg/kg) for soil in restricted-access sites set forth under the Toxic Substances
Control Act (TSCA). However, concentrations of PCBs above the action level were left
in removal grids A-1 and B-2 (Map 2-86) because of the potential undermining of old
building foundations. A 375-gal. (1,420-L) non-leaking diesel tank was also discovered
during the project and removed (Onsite 2000a). Two soil samples from the tank
excavation had elevated concentrations of diesel-range TPH (TPH-D) (462 and
2,780 mg/kg). Other samples did not contain detectable concentrations of TPH. 
2.2.2  2004 utility corridor cleanout 
The Port removed contaminated and structurally unsuitable fill materials, debris, and
waste from approximately 150 ft of a 2-ft-wide, 2.5-ft-deep, below-grade utility
corridor in the T-117 Upland Study Area (Map 2-6). This project was conducted
independently by the Port, without oversight under either the MTCA or CERCLA. The 
work was conducted to prevent further settling of the pavement surface along the
concrete-lined corridor and to stem extrusions of asphalt material that were caused by
heavy vehicles (high surface loading) during warm weather and appeared at several
locations along the alignment. Soft asphalt was observed extruding up through the
pavement in the truck parking area and there was concern that this material could be
tracked and spread by vehicles. This project was conducted independently by the Port
without oversight under either the Model Toxics Control Act (MTCA) or CERCLA. 
The Port removed the residual asphalt, contaminated soil, debris, and abandoned
asphalt plant-era pipes and backfilled the corridor with controlled density fill, without
oversight under either the MTCA or CERCLA. The overlying surface was repaved
with asphalt to restore the pavement surface. Soil removed from the south portion of
the concrete-lined corridor was found to contain elevated concentrations of TPH-D
and lube oil-range TPH (TPH-O), as well as large amounts of roofing asphalt.
Concentrations of PCBs in excavated soil did not exceed 10 mg/kg, and the soil was
not designated as a dangerous waste as a result of PAH or metals concentrations.
Approximately 26 tons of TPH-contaminated soil were excavated and disposed of
offsite at an approved landfill. Asphalt, pipe and metal debris, and oil were also
removed (Windward and Onsite 2004). All material removed from the property was
disposed of, treated, or recycled at approved facilities. 

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2.2.3  2006 time-critical removal actionTCRA 
The Port conducted a second TCRA (Map 2-6) to remove hazardous substances from
the T-117 Upland Study Area from September to November 2006. EPA determined
that a TCRA was required because of the high concentrations of PCBs in soil on the T--
117 Upland Study Area. The objectives of the TCRA were to prevent or reduce the 
potential for human exposure to contaminants and to prevent or reduce the potential
for contaminants to migrate into the LDW. 
The TCRA was performed in accordance with the Superfund ASAOC (No. 10--2006--
0072) SOW (EPA 2006b). The TCRA included the excavation of PCB-contaminated soil,
offsite disposal of PCB-contaminated soil at approved landfills, offsite disposal of
construction debris (e.g., asphalt), backfilling of excavations with clean soil,
environmental controls, monitoring to ensure there were no releases of PCB--
contaminated soil to the adjacent neighborhood and to the LDW, and site restoration
(e.g., new asphalt cap, street sweeping). TCRA activities were overseen by EPA and
closely coordinated with EPA and the neighborhood, with regular meetings being
held throughout the duration of the project. 
Three areas with elevated PCB concentrations (up to 9,200 mg/kg) were excavated:
one area along the riverbank and two areas west of the riverbank (Map 2-6).
Excavation along the riverbank consisted of the removal of the upper 2 ft of surficial
soil, including the existing asphalt and pavement. Excavation depths in the remaining
two areas varied from 2.5 to 7 ft bgs based on the depth needed to achieve the PCB
removal action level of 25 mg/kg (RETEC 2007b). All material removed from the
property was disposed of, treated, or recycled at approved facilities. The following
quantities were removed: 
3,030 tons of Toxic Substances Control Act (TSCA) soil (concentrations
> 50 50 mg/kg total PCB) 
78 tons of Resource Conservation and Recovery Act (RCRA) Subtitle D 
(concentrations < 50 mg/kg total PCB) soil 
533 tons of RCRA Subtitle D asphalt and concrete debris 
91,472 gal. of onsite runoff/decontamination water 
2.7 tons of metal debris 
1.2 tons of cleared and grubbed vegetative debris 
Clean backfill was placed in all of the excavation areas after the analytical results for
each excavation area had been reviewed. A non-woven geotextile was installed on top
of the excavation subgrade as an identifying marker layer. Asphalt pavement (i.e., a
temporary cap) was installed after the backfill had been placed and compacted
(RETEC 2007b). 

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FINAL                January 19June 3, 2010 
Page 47

In 2008, bank repair work was performed as part of maintenance activities associated
with the TCRA. This work included stabilizing approximately 25 linear ft of the upper
shoreline bank by reinforcing the area with a riprap revetment. In addition, to
minimize erosion, clean gravel was removed from the top of the bank to reduce the
load on adjacent areas of the bank. The localized bank failure was first noted during a
scheduled maintenance visit on March 7, 2008. A temporary repair of the bank was
implemented on March 13, 2008, which included covering the eroded area with plastic
and securing the plastic with sandbags. Final repair and maintenance activities began
on June 16 and were completed on June 20, 2008. The repair work involved site
preparation, vegetation removal, geotextile placement, silt fence repair, the removal of
existing plastic, riprap and gravel cobble mix placement, and the removal of existing
gravel. The shoreline bank repair and maintenance work was performed in accordance
with the May 29, 2009, scope of work described in the request for authorization
approved on June 9, 2008, by EPA (ENSR 2008b; EPA 2008b). A complete summary of
work performed is included in the Bankline Repair and Maintenance Activities Completion
Report, Terminal 117, Port of Seattle (ENSR 2008a). 
2.2.4  Independent cleanup actions in the Adjacent Streets and Residential
Yards Study Area 
The City completed a series of independent cleanup actions between December 2004
and October 2005 (City of Seattle 2005) to reduce potential human exposure to
PCB-impacted soil in the streets, ROWs, and yards in the vicinity of T-117 EAA
(Map 2-68). These actions were conducted independently by the City without
oversight under either MTCA or CERCLA. The independent cleanup actions are
described in a site characterization data report (Integral 2006b) and briefly
summarized below. 
Soil with PCB concentrations that exceeded 1 mg/kg was removed from
residential yards at 8601 and 8609 17th Avenue S, the boat storage yard at
8603 Dallas Avenue S, and from along the west side of 16th Avenue S (Hart
Crowser 2005). The action level of 1 mg/kg was based on MTCA's Method A
cleanup level (CUL) for PCBs. The depth of soil removal was based on
confirmation sampling .(King County and SPU 2005). 
A 100-ft section of the road shoulder on the north side of the 8500 block of
Dallas Avenue S was paved to cover soil that contained PCB concentrations
above 1 mg/kgimprove drainage. 
Shallow excavations (i.e., between 6 and 12 in.) and the placement of clean
gravel were completed in the unpaved road shoulders along selected portions
of Dallas Avenue S, between 14th Avenue S and 17th Avenue S; on
16th Avenue S, between Dallas Avenue S and S Cloverdale Street; and in a boat
storage area located within the public ROW on Dallas Avenue S, between
14th Avenue S and 16th Avenue S. 
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FINAL                January 19June 3, 2010 
Page 48

The City street ROWs surrounding the Basin Oil property bounded by Dallas
Avenue S, 17th Avenue S, and S Donovan Street were graded and paved with
asphalt. 
The existing catch basin located near the south driveway entrance to the T-117 
Upland Study Area was cleaned, and a catch basin near 8609 17th Avenue S
was removed. Basin Oil removed two catch basins and an oil/water separator 
on their property within the same time frame.Contaminated sediment was
removed from three existing catch basins (located around the perimeter of the
Basin Oil property); a catch basin near 8609 17th Avenue S was also removed. 
The existing catch basin in the boat storage yard was also cleaned. 
The following streets were pressure washed, and the existing catch basins
serving those streets were cleaned: S Cloverdale Street, between 14th Avenue S 
and 16th Avenue S; S Donovan Street, between 16th Avenue S and 17th Avenue S;
and in front of the building located at 8620 16th Avenue S. 
A temporary stormwater collection and treatment system was installed to
capture runoff from the ROW independent cleanup action area. This work
included the installation of the drainage features described above in Section 
2.1.3.3, including five catch basins, two small pump stations, five 18,000-gal.
storage tanks, and a temporary treatment system (i.e., settling followed by sand
and granular activated-carbon filtration). All runoff from the area is now
collected in the five storage tanks and released at a controlled rate to the City's
CSS at 17th Avenue S and S Donovan Street. The temporary treatment system,
associated with the storage tanks, was installed during the independent
cleanup action to treat construction and post cleanup runoff and was removed
in April 2005, when repeated sampling confirmed that PCBs were not detected
in the incoming runoff. The City obtained discharge authorization from the
County's Industrial Waste Program for this discharge. As part of the
authorization, SPU tests the quality of water discharged to the CSS every month
in which discharge occurs. The temporary stormwater collection system
remains in place and will be maintained until removal action construction. 
2.3   PREVIOUS ENVIRONMENTAL INVESTIGATIONS AND SUMMARY OF
ENVIRONMENTAL DATA 
This section summarizes the chemistry data associated with the investigations
presented in Table 2-1 2 for each study area of the T-117 EAA and the two RAAs.
These investigations and other milestones are also presented on the timeline
(Figure 1-1). Map 2-9 7 presents an overview of the sampling locations in all three
study areas of the T-117 EAA. 
Data summarized in this section are presented along with screening levels (SLs)
discussed in Section 3, where they are used to identify COPCs. PCBs, PAHs, and TPH
are the most prevalent chemicals that exceed their respective the SLs in soil and
Lower Duwamish Waterway Superfund Site:                                   EE/CA 
DRAFT
T-117 Early Action Area 
FINAL                January 19June 3, 2010 
Page 49

sediment within the T--117 EAA. The large quantity of data for the T-117 EAA
indicates that the current environmental conditions at the site are likely the result of
historical site use and operations. 
All available data are presented in Appendix C. However, not all samples are
representative of current conditions as a result of previous removal actions (described
in Section 2.2) and subsequent sampling results (i.e., MIS) that has superseded
previous sampling results. Numbers of samples provided in this section are for only
the actual field samples and do not include the quality assurance/quality control
(QA/QC) samples (i.e., field duplicates and triplicates and laboratory duplicates). 
Maps and analytical results presented in the following sections present mean
concentrations that include the results of QA samples. In addition, multiple samples 
may have been collected from a single location if samples were collected from multiple 
depth intervals at that location. A complete description of all the data management
rules used in this step is provided in Appendix D. 












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DRAFT
T-117 Early Action Area 
FINAL                January 19June 3, 2010 
Page 50

Table 2-21. Summary of previous investigations at T-117 Early Action Area 
No. of Samples
from the T-117
EAA and
Vicinity Used
a
Activity         Date                           Summary                            Analyses       in the EE/CA     Source 
Summary of T-117 Historical Investigations  Data Ttoo Oold or Nnot Aapplicable for Uuse in EE/CA 
Water and sediment samples were collected from the LDW, roadway
Metro inspection              ponding area, catch basin 5 outfall, and an apparent groundwater seep at
sampling of                the shoreline. PCBs, PAHs, and metals were detected in one or more of
PCBs, PAHs, and               URS
roadway ponding   1984       the water and sediment samples. No PCBs were detected in the seep                      na 
metals                         (1994) 
area and                 sample. The ponding area was reportedly receivedused for non-contact
shoreline seep               cooling water during the period that the asphalt plant operated.discounted 
by subsequent investigators. 
Ecology sediment           Sediment samples were collected from an onsite drainage ditch. Results
1985 and                                                                        URS
sampling and              showed elevated concentrations of lead (1,666 mg/kg), arsenic (2,027    metals              na 
1986                                                                              (1994) 
inspections                  mg/kg), and zinc (5,416 mg/kg). 
Samples were collected from a waste oil tank and another tank that
contained usable light oils. No PCBs were detected. However, total       PCB and
EPA TSCA                                                                       URS
1989       halogenated hydrocarbons (as total chlorine) were reportedly detected at   halogenated          na 
inspection                                                                                                     (1994) 
levels up to 1,160 mg/kg in the sampled product. No materials were noted  hydrocarbons 
at the facility to qualify for PCB regulation. 
One surface sediment sample was collected at the toe of the bank. Onsite
and offsite soil, sediment, groundwater, and surface water were sampled.
Malarkey site               PCBs and PAHs were detected in soil at the former ponding/waste areas.                                URS
1994                                                    PCBs and PAHs        na 
inspection                   Three monitoring wells and a groundwater seep were also sampled. PCBs                                 (1994) 
were detected in all wells, and PAHs were detected in MW-03. PCBs were
not detected in the seep sample. 
An asbestos-containing material survey was conducted. Twelve suspect                               EMCON
Asbestos survey    March 1996                                                   asbestos             na 
materials were found to contain detectable amounts of asbestos.                                      (1996) 
Sediment Study Area  Sediment 
Duwamish
metals, PCB
Waterway                                                                              Exponent
1997       Site-wide LDW surface and subsurface sediment samples            Aroclors, and          4 
Phase 1 site                                                                                              (1998) 
SVOCs 
characterization

Table 2-12.  Summary of previous investigations at Terminal-117 Early Action Area (cont.) 
No. of Samples
from the T-117
EAA and
Vicinity Used
a
Activity         Date                           Summary                            Analyses       in the EE/CA     Source 
PCB Aroclors,
Duwamish
selected PCB
Waterway
congeners, and                 NOAA
sediment       1997       Site-wide LDW surface and subsurface sediment samples                             3 
total                               (1998) 
characterization
polychlorinated
study 
terphenyls 
metals, pesticides,
PCB Aroclors and
EPA site
selected PCB                  Weston
inspection: Lower   1998       Site-wide LDW surface and subsurface sediment samples                                5 
congeners, dioxins                 (1999) 
Duwamish River 
and furans, TBT,
SVOCs, and VOCs 
Site-wide LDW chemical analyses of benthic invertebrate and clam tissue  metals, SVOCs,                 Windward
LDW RI Benthic    2004                                                                         2 
samples and co-located sediment samples                      and PCB Aroclors,                (2005a) 









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DRAFT
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FINAL                January 19June 3, 2010 
Page 52

Table 2-12.  Summary of previous investigations at Terminal-117 Early Action Area (cont.) 
No. of Samples
from the T-117
EAA and
Vicinity Used
a
Activity         Date                           Summary                            Analyses       in the EE/CA     Source 
An initial sediment investigation was conducted to determine the nature
metals, PCB                  Windward
December   and extent of contamination in the T-117 EAA. All surface and subsurface
Aroclors, SVOCs,       137        et al.
2003       sediment were analyzed for PCBs and select locations were also
VOCs, TBT                  (2005b) 
analyzed for SMS chemicals and TBT. 
Additional subsurface and surface sediment samples were collected from
Windward
the northern portion of T-117 to further refine the removal boundary. Large
March 2004                                                PCB Aroclors          12        et al.
asphalt deposits and other major debris located in the shoreline bank
(2005b) 
were identified, described, and mapped. 
Surface sediment samples collected outside the offshore northern portion
of the preliminary sediment boundary in the 2005 EE/CA were analyzed    metals, PCB                   Windward
June 2004    for PCBs, and archived samples collected in December 2003 that were    Aroclors, SVOCs,       8         et al.
either outside of the boundary or below the vertical extent of PCB        and VOCs                       (2005b) 
T-117 EAA
contamination were analyzed for all other SMS chemicals. 
investigation 
Surface and subsurface samples were collected in the northern portion of
the site that extends into the proposed Marina dredge area. This sampling  metals, pesticides,
September                                                                   Windward
event was conducted to satisfy both the EPA T-117 EAA boundary       PCB Aroclors,         12 
2004                                                                              (2005a) 
definition and the PSDDA sediment characterization requirements for the   SVOCs, and VOCs 
Marina. 
Surface sediment samples collected near the proposed sediment
boundary for the 2008 EE/CA were analyzed for dioxins and furans and
PCB Aroclors,                 Windward
PCBs to determine if there were any dioxin/furan TEQ exceedances
August                                                 dioxins and furans,               and
outside of the boundary and to refine the extent of the sediment removal                       18 
2008                                                    mercury and                  Integral
boundary presented in this EE/CA. Two surface sediment samples were
dieldrin                             (2009) 
also collected for mercury and dieldrin to evaluate potential soil to
sediment contamination from the Marina. 
T-117 Upland Study Area  - Soil 
Work included review of Ecology and Malarkey Asphalt files, installation of
three monitoring wells (MW-01, MW-02, and MW-03), soil sampling and
Ecology site                                                                   metals, total PCBs,
analysis of borehole samples, groundwater sampling, sampling of product                             Parametrix
hazard        May 1991                                                pesticides,           8 
in USTs and ASTs. Metals, PCBs, pesticides, and VOCs were found in                                (1991) 
assessment                                                            SVOCs, VOCs 
soil. Results of TCLP analyses on soil were below dangerous waste
criteria. 

Lower Duwamish Waterway Superfund Site:                                   EE/CA 
DRAFT
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FINAL                January 19June 3, 2010 
Page 53

Table 2-12.  Summary of previous investigations at Terminal-117 Early Action Area (cont.) 
No. of Samples
from the T-117
EAA and
Vicinity Used
a
Activity         Date                           Summary                            Analyses       in the EE/CA     Source 
UST              Four USTs containing diesel and waste oil were decommissioned,
Hart
decommissioning           including a partially buried railroad tank car. Three USTs were closed in
1992                                                    TPH                6        Crowser
and site                   place by filling with concrete slurry. The railroad tank car was removed.
(1992) 
assessment               Soil samples were taken from the tanks and tested for TPH. 
One surface sediment sample was collected at the toe of the bank. Onsite
and offsite soil, sediment, groundwater, and surface water were sampled.
Malarkey Asphalt
PCBs and PAHs were detected in soil at the former ponding/waste areas.  total PCBs and                   URS
Company site    1994                                                                    na 
Three monitoring wells and a groundwater seep were also sampled. PCBs  PAHs                         (1994) 
inspection 
were detected in all wells, and PAHs were detected in MW-03. PCBs were
not detected in the seep sample. 
Soil and water     September   Surface soil samples were collected from locations near the ponding area,                              EMCON
total PCBs             7 
sampling        1995       former railroad tank car, and storm drain ditches.                                             (1996) 
Focused site               Surface soil samples were collected from locations near the ponding area  total PCBs, PAHs,                SECOR
July 1997                                                                         55 
characterization               and former railroad tank car to delineate the extent of contamination.       and TPH                         (1998) 
Windward
Utility corridor soil   October      Three borehole locations were sampled along a utility alignment that
PCB Aroclors           3       and Onsite
sampling        1999       extended from the former tank area to the south building. 
(2004) 
Actions included the removal and treatment of impounded stormwater, the
PCB soil removal   October     excavation and disposal of over 2,000 tons of PCB-contaminated soil with
and containment   1999 to     concentrations ranging up to 500 mg/kg, backfilling, installation of a                                  Onsite
total PCBs             14 
roadway area     February    pavement cap, and storm drain improvements. Also included was the                                (2000a) 
(1999 TCRA)     2000       abandonment of the large-diameter well and replacement of three
monitoring wells. PCB removal action target level in soil was 25 mg/kg. 
Underground             A 375-gal. (1,420-L) non-leaking diesel tank was removed. Two soil
January                                                                           Onsite
diesel storage               samples from excavation indicated elevated TPH diesel levels (462 and    TPH                 2 
2000                                                                              (2000b) 
tank removal                2,780 mg/kg). 



Lower Duwamish Waterway Superfund Site:                                   EE/CA 
DRAFT
T-117 Early Action Area 
FINAL                January 19June 3, 2010 
Page 54

Table 2-12.  Summary of previous investigations at Terminal-117 Early Action Area (cont.) 
No. of Samples
from the T-117
EAA and
Vicinity Used
a
Activity         Date                           Summary                            Analyses       in the EE/CA     Source 
Soil samples were collected from the top of the shoreline, the southern
metals, PCB                  Windward
December   drainage ditch, and the adjacent Dallas Avenue S roadway area. Solid
Aroclors, and          40         et al.
2003       samples were collected from catch basins. PCBs were detected in most
SVOCs                   (2005b) 
soil samples. 
To better define the extent of contamination, shallow soil borings were
T-117 EAA              collected from the northern upland bank. All these samples were analyzed
investigations                 for PCBs and compared to SMS to assess the risk from potential erosion.
Soil sampling was also conducted to estimate concentrations of PCBs in                               Windward
March 2004   the roadway along the entrance area of the T-117 property and determine  PCB Aroclors          16        et al.
if these materials were the likely source of elevated PCBs in and around                                 (2005b) 
catch basin 5. Roadway soil samples and catch basin samples were
analyzed for PCBs. Large asphalt deposits and other major debris located
in the south ditch were identified, described, and mapped. 
Four shallow soil grab samples were obtained from the concrete-enclosed
soil-filled planter areas at the north side of the south building at T-117.
T-117 South
November   PCB concentrations in the four soil samples ranged from 0.03 to 0.22                           Onsite
building planter                                                                     PCB Aroclors            4 
2004       mg/kg. Soil in the west planter was subsequently covered over with a                               (2004) 
soil sampling 
layer of clean gravel. Soil in the east planter was covered with asphalt
pavement. 
This work was performed as part of an iterative process to provide
additional information on the nature and extent of PCBs in soil.
Windward
T-117 Upland soil            Subsurface soil samples were collected from three upland regions of TJune
2005                                                 PCB Aroclors          95         et al.
sampling                  117: the unpaved upland area along the northern shoreline; beneath the
(2005d) 
pavement along the shoreline edge of the site; and the ditch along the
southern boundary of the site. 
Supplemental upland soil sampling was conducted from 26 soil borings (0
to 9 ft).Three soil samples (SB-26, SB-51, and SB-28) along the northern
shoreline contained PCB concentrations similar to those of the previous
T-117 Upland soil            upland sampling effort in the same area. Two soil samples located in the                              Windward
August
sampling -                  paved driveway area inboard of the bank extending north of the 1999 PCB  PCB Aroclors           89         et al.
2005 
supplemental               removal area had two of the highest PCB concentrations (1,200 and                                 (2005e) 
730 mg/kg for soil samples SB-30 and SB-50, respectively). These data
identified a new area of elevated PCB contamination on the T-117 EAA
not previously observed in the June 2005 soil sample results. 

Lower Duwamish Waterway Superfund Site:                                   EE/CA 
DRAFT
T-117 Early Action Area 
FINAL                January 19June 3, 2010 
Page 55

Table 2-12.  Summary of previous investigations at Terminal-117 Early Action Area (cont.) 
No. of Samples
from the T-117
EAA and
Vicinity Used
a
Activity         Date                           Summary                            Analyses       in the EE/CA     Source 
PCB Aroclors,
Soil borings were collected throughout the upland property. PCBs were                                Windward
T-117 Upland     January                                                 metals SVOCs,
detected in several samples. The results of this investigation led to the                         230        and DOF
Investigation       2006                                                              pesticides and
2006 TCRA for PCB contaminated soil.                                                    (2006) 
TPH 
Confirmation samples were collected in the TCRA excavation areas upon
T-117 TCRA     October to
completion of the soil removal activities. Baseline samples were also      PCB Aroclors and                 RETEC
activities (2006     November                                                                               79 
collected in the roadway along Dallas Avenue S before and after the      TPH                          (2007b) 
TCRA)        2006 
TCRA. 
Subsurface Soil samples were collected to determine the presence and                               Windward
PCB Aroclors,
T-117 EAA dioxin  August     concentrations of dioxins and furans in the T-117 Upland Study Area.                                 and
PAHs, TPH, and       29 
investigation       2008        Select subsurface samples were also analyzed for TPH and PCBs to                                     Integral
dioxins and furans 
further refine the vertical extent of the removal boundary.                                              (2009) 
Adjacent Streets and Residential Yards Study Area 
Soil samples were collected of right-of-wayROW street dust and from                                  Integral
Street dust and              storm drain catch basins by Seattle Public UtilitiesSPU and King County                                (2006b) 
2004                                                       PCB Aroclors and
soil ROW               Health Department and analyzed for PBCBs. Catch basin sample CB41                   31       Integral
2005                                                    dioxin and furans 
sampling                  and street dust sample SD52 were analyzed for dioxins that led to                                 (2008b)(20
discovery of dioxin/furans in this area..                                                             08) 
Subsurface soil samples were collected from boreholes and test pits
Subsurface soil    2004                                                                                     Integral
within the ROW by Seattle Public UtilitiesSPU and King County Health    PCB Aroclors          118 
ROW sampling    2005                                                                         (2006) 
Department. 
2004       Samples were collected from yards adjacent to the ROW by Seattle Public                              Integral
Yard soil sampling                                                                PCB Aroclors           97 
2005       UtilitiesSPU and King County Health Department.                                           (2006) 
In June 2005, SPU collected confirmatory soil samples at the base of the
56         Hart
excavation following the removal of PCB-contaminated soil from the
Yard soil sampling   2005                                                           PCB Aroclors       (not included in   Crowser
residential lots adjacent to the impacted ROW. All confirmation samples
Appendix C)     (2005) 
were below 1 mg/kg. 
Twenty-five direct push borings were advanced up to a depth of 20 ft bgs
Subsurface      February                                                 PCB Aroclors,
to delineate the extent of PCB contamination and to screen for other                                   Integral
sampling in      and March                                                    TPH, PAHs,           83 
COPCs within the Adjacent Streets. Results of the investigation were                                  (2006b) 
Adjacent Streets    2006                                                          BTEX, and metals 
used to delineate the preliminary boundary for the Adjacent Streets. 

Lower Duwamish Waterway Superfund Site:                                   EE/CA 
DRAFT
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FINAL                January 19June 3, 2010 
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Table 2-12.  Summary of previous investigations at Terminal-117 Early Action Area (cont.) 
No. of Samples
from the T-117
EAA and
Vicinity Used
a
Activity         Date                           Summary                            Analyses       in the EE/CA     Source 
Surface and subsurface soil samples were collected to determine the                                 Windward
T-117 EAA dioxin  August                                                    PCB Aroclors and
presence and concentrations of PCBs and dioxins and furans in the                         85         et al.
investigation       2008                                                              dioxin and furans 
Adjacent Streets and Residential Yards Study Area.                                              (2009) 
Soil samples were collected from the adjacent streets and right-of-
PCB boundary            waysROWs as part of the PCB boundary refinement investigation. The
April and                                                                                      Integral
refinement                  samples consisted of direct push borings in the streets and right-of-       PCB Aroclors           76 
July 2009                                                                                   (2009) 
Adjacent Streets              waysROWs, discrete parking strip samples, and multi-increment samples
(MIS) from right-of-waysROWs. 
PCB boundary
April and    MIS soil samples were collected from residential yards as part of the PCB                                Integral
refinement                                                                    PCB Aroclors           75 
July 2009    boundary refinement investigation.                                                         (2009) 
Residential Yards 
Ecology analyzed MIS sample splits for dioxins and furans from the MIS
Dioxin analysis                                                                                                  Ecology
July 2009    samples from Adjacent Streets during the PCB bBoundary rRefinement    dDioxin and furans        9 
Adjacent Streets                                                                                              (2009) 
iInvestigation as described above. 
Ecology analyzed MIS sample splits for dioxins and furans from the MIS
Dioxin analysis                                                                    dDioxins and                     Ecology
July 2009    samples from Residential Yards during the PCB bBoundary rRefinement                      24 
Residential Yards                                                                furans                          (2009) 
iInvestigation as described above. 
Groundwater Monitoring (2003 to -2008) 
Groundwater was sampled from three wells in the vicinity of T-117. TPH-D
Groundwater
([0.70 mg/L)], TPH-O ([1.4 mg/L)], and six PAH compounds (at         PCB Aroclors,                   Onsite
sampling at T-117  May 2003                                                                       5 
concentrations ranging from 0.013 to 1.6 g/L) were detected in MW-03.   PAHs, and TPH                   (2003) 
wells 
PCBs were not detected in any of the wells. 
T-117 EAA                                                        PCB Aroclors,               Windward
December   Water samples were collected from intertidal seeps. Copper, zinc, and
investigation                                                                      SVOCs, VOCs,          5          et al.
2003       BEHP were detected in seep samples. 
seeps                                                                     metals                        (2005b) 
T-117 EAA                                                                               Windward
January    Water samples were collected from groundwater monitoring wells. No    PCB Aroclors,
investigation                                                                                             5          et al.
2004       chemicals were detected in the monitoring well samples.            PAHs, VOCs 
monitoring wells                                                                                                (2005b) 


Lower Duwamish Waterway Superfund Site:                                   EE/CA 
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FINAL                January 19June 3, 2010 
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Table 2-12.  Summary of previous investigations at Terminal-117 Early Action Area (cont.) 
No. of Samples
from the T-117
EAA and
Vicinity Used
a
Activity         Date                           Summary                            Analyses       in the EE/CA     Source 
Two new groundwater monitoring wells were installed to extend the
existing network northward. All shoreline monitoring wells and upgradient                               Windward
T-117 Upland                                                           PCB Aroclors,
June 2005    monitoring well (MW) 3 were analyzed for PCBs also monitored for the                      6         et al.
groundwater                                                              PAHs, and TPH 
presence of free product. One well was also analyzed for PAHs and TPH.                              (2005d) 
PCBs were detected in one well. 
Windward
T-117 Upland     January    One well was sampled for PCBs to verify the detection noted in the
PCB Aroclors           1        and DOF
Investigation       2006        previous event 
(2006) 
PCB Aroclors,                  ENSR |
T-117 Upland     August
Groundwater in was collected prior to 2006 TCRA activities             metals, PCBs, and       7         AECOM
groundwater      2006 
TPH                      (2008) 
T-117 EAA              5 new monitoring wells were installed in the T-117 EAA. Two wells were
PCB Aroclors,                  ENSR |
Groundwater             installed along Dallas Avenue S downgradient of Basin Ooil and the other
March 2008                                                SVOCs, VOCs,        11       AECOM
Monitoring                  three wells were installed along the T-117 shore line as replacement wells
metals                         (2008) 
2008 1st Event               for the ones removed during the 2006 TCRA. 
T-117 EAA                                                        TSS, TPH, metals,
ENSR |
Groundwater                                                         BTEX, PCB
June 2008    Groundwater samples were collected.                                         10        AECOM
Monitoring                                                                      Aroclors, SVOCs,
(2008) 
2008 2nd Event                                                            VOCs, and PAHs 
T-117 EAA                                                        TSS, TPH, metals,
ENSR |
Groundwater     September  Groundwater samples were collected. Installed one new upgradient      BTEX, PCB
10        AECOM
Monitoring        2008       monitoring well in the T-117 EAA (MW-11).                       Aroclors, SVOCs,
(2008) 
2008 3rd Event                                                              VOCs, and PAHs 
TSS, TPH, metals,
T-117 EAA
BTEX, PCB                ENSR |
Groundwater     December
Groundwater samples were collected.                         Aroclors, SVOCs,       11        AECOM
Monitoring        2008 
VOCs, PAHs, and               (2008) 
2008 4th Event 
dioxins and furans 
T-117 EAA                                                        TSS, TPH, metals,
Groundwater                                                         BTEX, PCB                  AECOM
March 2009   Groundwater samples were collected.                                         13 
Monitoring                                                                    Aroclors, SVOCs,                 (2009a) 
2009 1st Event                                                                VOCs, and PAHs 

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Table 2-12.  Summary of previous investigations at Terminal-117 Early Action Area (cont.) 
No. of Samples
from the T-117
EAA and
Vicinity Used
a
Activity         Date                           Summary                            Analyses       in the EE/CA     Source 
Groundwater samples were collected. Modified the groundwater
T-117 EAA                                                        TSS, TPH, metals,
monitoring program at the T-117-Upland Study Area. The Department of
Groundwater                                                         PCB Aroclors,                AECOM
May 2009    Ecology installed two new monitoring wells upgradient of Basin Oil (MW-                    7 
Monitoring                                                                      SVOCs, and                     (2009b) 
12 and MW-13). These wells will be adopted into the T-117 EAA
2009 2nd Event                                                            cPAHs 
monitoring well net work in subsequent groundwater sampling events. 
T-117 EAA                                                        TSS, TPH, metals,
Groundwater     August                                                PCB Aroclors,                AECOM
Groundwater samples were collected.                                            10 
Monitoring        2009                                                            SVOCs, VOCs,                   (2009c) 
2009 3rd Event                                                              and cPAHs 
a
Numbers of samples in this table are for only the actual field samples and do not include the QA/QC samples (e.g., field duplicates). In addition, multiple samples
may have been collected from a single location if samples were collected from multiple depth intervals at that location. 
AST  aboveground storage tank              MTCA  Model Toxics Control Act                  SPU  Seattle Public Utilities 
BBP  benzyl butyl phthalate                  MIS  multi-increment sampling                     SQS  sediment quality standards 
BEHP  bis(2-ethylhexyl) phthalate              NOAA  National Oceanic and Atmospheric Administration    SVOC  semivolatile organic compound 
bgs  below ground surface                  PAH  polycyclic aromatic hydrocarbon                T-117  Terminal 117 
BTEX  benzene, toluene, ethylbenzene, and xylene  PCB  polychlorinated biphenyl                     TBT  tributyltin 
COPC  contaminant of potential concern         PCP  pentachlorophenol                        TCLP  toxicity characteristic leaching procedure 
CSL  cleanup screening level                 PSDDA  Puget Sound Dredged Disposal Analysis        TCRA  time-critical removal action 
DOF  Dalton, Olmsted & Fuglevand            ROW  right-of-way                           TPH  total petroleum hydrocarbons 
EAA  early action area                     Marina  South Park Marina                        TSCA  Toxic Substances Control Act 
Ecology  Washington State Department of Ecology   NOAA  National Oceanic and Atmospheric Administration   TSS  total suspended solids 
LDW  Lower Duwamish Waterway            QA/QC  quality assurance/quality control            UST  underground storage tank 
Marina  South Park Marina                  SMS  Washington State Sediment Management Standards   VOC  volatile organic compound 




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2.3.1  T-117 Sediment Study Area 
Extensive sediment sampling in the T-117 EAA was conducted from 1998 to 2008.
Most of the investigations focused on PCBs; however, additional chemicals analyzed
included PAHs, other semivolatile organic compounds (SVOCs), pesticides, dioxin 
and furans, VOCs, and metals, including tributyltin (TBT). Appendix C includes a 
complete list of available data for each chemical analyzed in the T-117 Sediment Study
Area. 
2.3.1.1  PCBs 
One hundred and eighty-two surface and subsurface sediment samples were analyzed
for PCBs. PCB concentrations for surface grab samples are presented on Map 2-108,
and concentrations for subsurface samples are presented on Map 2-119. PCB
concentrations on both maps are compared to Washington State Sediment
Management Standards (SMS) criteria. The detected PCB concentrations in surface
sediment ranged from 1.9 to 2,200 g/kg organic carbon (OC), and the detected PCB 
concentrations in subsurface sediment ranged from 1.4 to 2,600 g/kg OC. Both the
surface and subsurface sediment sampling data indicate a spatial trend of PCB
concentrations decreasing from the bank out towards the navigation channel. The
highest PCB concentrations were collected from within 100 horizontal ft of the
shoreline bank and were typically confined to the upper 1 to 2 ft of sediment in the
nearshore cores. PCB concentrations were also generally higher in the northern
portion of the T-117 EAA (as opposed to the southern portion), at similar depths. This
trend suggests the presence of a historical and ongoing upland source for these 
chemicals, which were subsequently conveyed to the river via stormwater runoff and
direct erosion from the T-117 Upland Study Area and shoreline bank. Map 2-8 also
identifies historical sampling locations that have since been re-occupied by more
recent sampling locations. The more recent samples are considered to be more
representative of current site conditions. 
2.3.1.2  PAHs 
Thirty-four surface and subsurface sediment samples were analyzed for PAHs. PAH
data show that several individual PAHs and total carcinogenic PAH (cPAH) TEQ had 
maximum concentrations that exceeded their respective SLs. Less than 10% of the
samples analyzed had PAH concentrations that exceeded the SL. These samples were
collected from the toe of the shoreline bank and were co-located with samples that had
PCB exceedances. 
The detailed results (Appendix C) show that PAHs were detected in 3 of 34 samples at
concentrations that exceeded the SL. Two of these samples were from surface
sediment sampling locations (25-G and 37-G), and one was from a subsurface 
sampling location (25-SC). These locations are shown on Map 2-1210. The surface
sediment sample from 25-G exceeded the sediment quality standards (SQS) for three
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individual PAHs, and the sample from 37-G had 13 individual PAH SQS exceedances.
Total high-molecular-weight PAHs (HPAHs) also exceeded the SQS in 37-G, and total
low-molecular-weight PAHs (LPAHs) in this sample exceeded both the SQS and
cleanup screening level (CSL). The one subsurface sampling location, 25-SC, had one
individual PAH (acenaphthene) concentration that exceeded the SL in the 2-to-4-ft
depth interval. 
2.3.1.3  Other SVOCs and VOCs 
Thirty-three surface and subsurface sediment samples were analyzed for other SVOCs.
SVOCs that exceeded SMS were relatively few as compared with the PCB exceedances
and were in discrete locations, as shown on Map 2-120. The following SVOCs
exceeded their SL: bis(2-ethylhexyl) phthalate (BEHP) and butyl benzyl phthalate 
(BBP) (at DR206); hexachlorobenzene (at R19); phenol; (at C10-1, C10-2, and DR 207);
and benzyl alcohol (at 08-G). VOCs were not detected in any sediment sample
analyzed. 
2.3.1.4  Metals 
Thirty-one two sediment samples were analyzed for metals. Arsenic was the only
metal that exceeded its SL. Detected concentrations of aArsenic ranged from 7 to 22
mg/kg. Map 2-120 shows the locations of all samples analyzed for the full suite of
SMS chemicals, which included metals. 
2.3.1.5   Dioxins and Furans 
Eight surface sediment samples were analyzed for dioxins and furans. These samples
were collected to provide an initial indication of whether the dioxins and furans were
present in the sediment and if dioxin/furan TEQs were greater than theits SL (4.5 
ng/kg) at locations where PCB concentrations were below theits SL for PCBs; 
therefore,. no dioxin and furan analyses were performed for samples collected from
sediment areas that had elevated PCB concentrations and were thus targeted for
removal. The dioxin/furan TEQs ranged from 2.11 to 9.36 ng/kg and are shown on
Map 2-113. 
2.3.2  T-117 Upland Study Area 
Soil conditions at the T-117 Upland Area have been determined through the
evaluation of an extensive collection of soil samples from borings advanced from 1990
to 2008. Chemicals analyzed included PCBs, TPH, PAHs, other SVOCs (including
phthalates, and phenols), pesticides, and metals. As a result of the 1999 and 2006
TCRAs, 5,200 tons of contaminated soil were removed from the Upland T-117 Area. 
All available soil data (including data for samples collected from soil that is remaining
or has been excavated) for the T-117 Upland Study Area are provided in Appendix C. 

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2.3.2.1   PCBs 
A total of 682 samples from 282 locations have been analyzed from the T-117 Upland
Area for PCBs. During the two TCRAs, the soil associated with 83 sampling locations
was excavated, leaving 539 samples that are representative of current site conditions. 
PCB concentrations are presented by both subarea (A through F) and by depth range
(0 to -7 ft, 7 to -12 ft, and >15 ft) to facilitate data presentation because of the large
number of sampling locations in the T-117 Upland Study Area. Subareas were
delineated during the 2006 T-117 Upland Investigation (Windward and DOF 2006) 
and are shown on Map 2-124. PCB concentrations associated with both remaining and 
excavated soil in the T-117 Upland Study Area are presented on Maps 2-153a 
through 2-153c by depth. Maps 2-146 through 2-20 18 present the PCB sample 
concentrations associated with the remaining and excavated T-117 Upland Study Area
soil by subarea (A through F). The excavated data representing excavated soil are 
presented to illustrate chemical distribution and to facilitate the assessment of data
gaps. 
PCBs (predominantly Aroclor 1260) are generally found within the uppermost 2 ft of
surface soil, and concentrations tend to decrease with depth (Maps 2-153a through 
2-153c). Exceptions to this trend have been found at the following locations: 
Beneath the 1999 TCRA removal area (Subarea C, Map 2-168) and the 2006
TCRA removal area (Subarea B, Map 2-157), where the highest PCB
concentrations were located at 2 to 8 ft bgs and then decreased with depth 
Near Catch Basin 5 (Subarea E, Map 2-1820), where elevated PCB
concentrations ranged from 0 to 6.5 ft in depth 
The highest remaining PCB concentrations (i.e., greater than 1,000 mg/kg) were
detected in the upper 2 ft at location T-117-D-11 and between 2 and 5 ft bgs at location
T-117-E-1. Below 7 ft, PCBs were detected above 50 mg/kg only at locations PS-7
(110 mg/kg) and T-117-6 (94 mg/kg). 
The 2006 TCRA included the excavation of three areas in Subarea B (Map 2-157) that
contained the highest concentrations of PCBs in the T-117 Upland Area, including the
highest PCB concentration (9,200 mg/kg) at location T-117-B-8. 
2.3.2.2   TPH 
A total of 377 samples have been analyzed for TPH from 162 locations. Of this total,
37 sampling locations were associated with the soil that was excavated during the 1999
and 2006 TCRAs. The site-wide total TPH chemical concentrations associated with
samples that were collected from the remaining and excavated soil in the T-117
Upland Area are presented on Maps 2-1921a through 2-1921c. Maps 2-220 through
2-264 present total TPH chemical concentrations associated with samples that were
collected from the remaining and excavated soil in the T-117 Upland Area by subareas
(A through F). 
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The highest concentrations of TPH (i.e., greater than 10,000 mg/kg) were detected in
the former roadway ponding area (Subarea C, Map 2-242) and in the vicinity of Catch
Basin 5 (Subarea E, Map 2-246), where elevated TPH concentrations were detected as
deep as 6.5 ft. Most of the shallow soil (0 to 2 ft bgs) that had elevated concentrations
of TPH was removed as part of the 1999 and 2006 TCRAs (Maps 2-213 and 2-2432). 
2.3.2.3   PAHs 
A total of 303 samples from 81 locations have been analyzed, and soil associated with
35 of these sampling locations was excavated during the 1999 and 2006 TCRAs.
Individual cPAH compounds were compared with SLs as total cPAH TEQ.5 Twentyone
percent of soil samples exceeded the SL for total cPAH TEQ. A summary of the T-
117 Upland Study Area soil cPAH concentrations associated with soil that has since
been excavated are presented on Maps 2-275 and 2-286. cPAHs tended to be co-located
with elevated concentrations of PCBs and TPH. The highest cPAH TEQ concentrations
were detected at T-117-D-6 (22.67 mg/kg), T-117-B-4 (23.82 mg/kg), E-1 (27.89 mg/kg)
and T-117-C-4 (176.3 mg/kg). Three of these samples were collected from between 2
and 5 ft bgs. 
2.3.2.4   Other SVOCs and VOCs 
A total of 303 samples have been analyzed from 81 locations, and soil associated with
35 sampling locations was excavated during the 1999 and 2006 TCRA. These chemicals
had maximum concentrations below comparative SLs. SVOC concentrations 
(including PAHs) for samples collected within the T-117 Upland Area are presented in
Appendix C. 
2.3.2.5   Metals 
A total of 141 samples from 42 locations have been analyzed for metals. Metals have
been detected in the T-117 Upland Area, but only arsenic exceeded the SL. The highest
arsenic concentrations were detected at locations T-117-C-8 (55 mg/kg), T-117-D-6 (40 
mg/kg), and T-117-D-10 (160 mg/kg), as shown on Map 2-297. All of the samples
were collected from within the upper 4 ft. Concentrations of PCBs and TPH were also
elevated at these sampling locations. 
2.3.2.6   Dioxins and Furans 
A total of 21 samples from eight locations were analyzed for dioxins and furans. All
samples contained detected concentrations of one or more dioxin or furan congeners.
These concentrations, expressed as dioxin/furan TEQs, ranged from 0.272 to
296 ng/kg and are shown on Map 2-2830. 

5 cPAH TEQ benzo[a]pyrene equivalents were calculated in accordance with Ecology's calculation 
guidance (WAC 173-340-900 Table 708-2). 
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2.3.3  Adjacent Streets and Residential Yards Study Area 
Between 2004 and 2009, several investigations were conducted within the Adjacent
Streets to support the City's site characterization and independent cleanup actions 
(Integral 2006b) and in the Adjacent Streets and Residential Yards Study Area to
support boundary refinement activities completed since the Adjacent Streets were
included in the T-117 EAA in 2007 (Integral 2009; Windward and Integral 2009). 
Samples collected prior to 2008 were generally single samples collected from surface
soil, test pits, borings, street dust, and catch basins. The detection of PCBs and dioxins
and furans in Residential Yards samples collected in 2008 led EPA to direct the City to
conduct additional sampling using MIS in 2009. An MIS sample is a composite of
small amounts of soil (soil increments) collected at many locations (30 to 44 individual
soil aliquots or increments for this study) from a decision unit (DU); the laboratory
analysis is performed on a sub-sample from the composite sample. A DU is a defined
area for which a characterization or a decision is to be made; for example, a DU can
represent an exposure unit and/or a remediation unit. 
A MIS sample provides a single analytical result for each DU; that result represents an
estimate of the average concentration within the DU, but provides no information on
the variability (numerical or spatial) of concentrations across the DU. DUs were 
delineated collaboratively with EPA based on the objective of providing an average
chemical concentration for soil in the DU (Integral 2009). MIS samples were collected
from the surface depth interval (0.0 to 0.2 ft [0.0 to 2.0 in.]) and the subsurface depth
interval (0.2 to 0.5 ft [2.0 to 6.0 in.]). Where grass was present, the surface interval
began below the grass roots. The MIS increments were aggregated to form a single
composite to provide an average chemical concentration for soil in a given DU
(Integral 2009). 
MIS sampling was conducted in two phases during 2009. Residential Yard DUs were
delineated in consideration of the potential differences in how residents used their
yards (potential exposures), possible differences in the soil disturbance histories of
portions of yards (e.g., front versus back yards), the potential for contamination in
streets to enter yards (e.g., trackout, runoff, and resuspended dusts), and the
accessibility of surface soils. Residential Yard DUs for the first phase of sampling
represented entire yards. In some cases, Residential Yard DUs for the second phase of
sampling represented only the portions of Residential Yards adjacent to streets. 
EPA determined that results from previous investigations that were based on point
samples located within the 2009 DU areas were to be superseded by results of the 2009
MIS sampling in those areas. 
Appendix C includes a complete list of available data for each chemical analyzed in
the Adjacent Streets and Residential Yards Study Area. Appendix C also identifies
samples that were removed during the City's independent cleanup actions or data that

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were superseded by subsequent MIS composite sampling data; these data are 
presented to illustrate the current spatial distribution of contaminants. 
The SLs for soils discussed in the following sections are based on the MTCA Method B
standard formula values for direct human contact, with the exception of lead, TPH, 
and PCBs. For lead and TPH, the soil SLs are based on the MTCA Method A
unrestricted land use CULs. Method A provides the only applicable SLs for these
chemicals. PCB SLs are based on the TSCA applicable or relevant and appropriate
requirements (ARARs) (see Section 4.3.2.1). 
2.3.3.1   Adjacent Streets 
This section summarizes the data obtained from soil investigations conducted within
the Adjacent Streets between 2004 and 2009. 
Several investigations were conducted within the Adjacent Streets to support the
City's site characterization and independent cleanup actions between 2004 and 2006
(Integral 2006b) and in the Adjacent Streets and neighboring residential properties to
support boundary refinement activities completed since the Adjacent Streets were
included in the NTCRA in 2007 (Integral 2009; Windward and Integral 2009). 
Appendix C includes a complete list of available data for each chemical analyzed in
the Adjacent Streets. Appendix C also identifies samples that were removed during 
the City's independent cleanup actions or data that were superseded by subsequent
MIS composite samples; these data are presented to illustrate the current spatial
distribution of contaminants. 
PCBs 
A total of 382 367 soil, street dust (i.e., fine soil accumulated on street surfaces and
shoulders), and catch basin solids and MIS samples were collected and analyzed for
PCBs within the Adjacent Streets. Maps 2-29 and 2-30 show the locations where soil
was sampled from 2004 through 2006 and 2008 through 2009, respectively. (Map 2-
31); tThe source materialcontaminated soil associated with 17 of these the 367 samples
(i.e., 4 soil, 7 street dust, and 6 catch basin samples) was removed in conjunction with
the City's independent interim cleanup actions of 2004 and 2005. Map 2-31 shows the
locations of soil samples that were in areas where soil was subsequently removed as
part of the City's 2004 and 2005 cleanup actions, or were superseded by subsequent
sampling conducted by the City in 2008 and 2009. 
The sampling locations within the Adjacent Streets that had PCB concentrations
greater than the SL (1 mg/kg; MTCA Method B/TSCA) were located on Dallas
Avenue S, between 16th and 17th Avenues S, the north portion of 17th Avenue S, and in
other isolated areas on Dallas Avenue S and S Donovan Street. The detected PCB
concentrations in point samples ranged from 0.0025 mg/kg to 480 mg/kg at TP40
(located at 8601 17th Avenue S near the intersection with Dallas Avenue S). 

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PCBs were also detected at concentrations greater than 1 mg/kg were detected in
street dust (e.g., upper 0.1 in. of soil) along S Cloverdale Street, along S Donovan Street
near 17th Avenue S, and in street dust samples collected along Dallas Avenue S in
conjunction with the 2006 TCRA at the T-117 Upland Study Area. PCB concentrations
greater than 1 mg/kg, but less than 10 mg/kg, were generally detected only in the
upper 12 in.1.0 ft of soil, although there were isolated exceedances in samples collected
at depths of up to 2.0 ft. at locations P68, P83, P85, TP12, TP20, TP21, and TP41; and (at
depths of up to 48 4.0 ft at locations MW10, P65, and P66. The specific depth intervals
are presented on Map 2-28. 
PCB concentrations greater than 10 mg/kg were limited to surface samples (0-to-6-in.
depth interval) in the immediate vicinity of the T-117 Upland Study Area, with the
following exceptions: 
Ten exceedances in samples with depths ranging between 0.0 and 1.0 ft at 12 in. 
bgs (at locations P95, P100, TP6, TP8, TP9, TP12, TP13, TP19, TP26, and TP41 
Five exceedances in samples with depths ranging between 0.0 and 2 ft bgs at 24
in. bgs (at locations P86, P100, TP9, TP19, and P81 
MIS samples were collected from 12 decision units (DUs) in the Adjacent Streets. DUs 
were areas from which the MIS sample increments were aggregated to form a single
composite MIS sample. DUs were delineated collaboratively with EPA based on the
objective of providing an average chemical concentration for soil in the DU. MIS
samples were collected from the surface (0.0-to-0.2-ft depth interval) and subsurface
(0.2-to-0.5-ft depth interval). Where grass was present, the surface interval began
below the grass roots. Total PCBs were detected in all samples at concentrations that
ranged from 0.055 mg/kg at DU30 (0.2 to 0.5 ft bgs) to 8.1 mg/kg at DU19 (0.2 to 0.5 ft
bgs) (Map 2-32)30). The second highest total PCB concentration was also detected at
DU19 in the 0.0-to-0.2-ft interval (5.7 mg/kg). A total of 18four Adjacent Streets DUs
had total PCB concentrations (expressed as means for locations with sample replicates) 
that exceededing 1 mg/kg total PCBs. There were no total PCB concentrations higher
than exceedances of 1 mg/kg in DUs at the southern (south side of upper S Donovan
Street) extent of the 2009 PCB investigation. Areas designated for cleanup are
identified in Section 4. 
TPH 
A total of 53 63 soil, street dust, and catch basin samples were collected for the analysis
of TPH within the Adjacent Streets (Map 2-3432). The contaminated soil associated
with seven of these samples (i.e., one soil sample from TP48, two soil samples from 
TP49, street dust samples from SD20 and SD18, and catch basin samples from SD8 and
CB1-DAL) was removed in conjunction with the City's independent 2004 and 2005
cleanup actions. The source material (catch basin solids) associated with four of these
samples (SD3, SD8, SD20, and RCB101) was removed in conjunction with the City's
independent cleanup actions. TPH-D exceeded the SL (2,000 mg/kg; [MTCA
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Method A soils for unrestricted land use]) at two locations  a catch basin located at
the corner of Dallas Avenue S and S Donovan Street (SD3) and a five-point surface
composite soil sample from the ROW area at the east end of S Donovan Street (SD4)
that was previously used by Basin Oil to store equipment. TPH-O exceeded 2,000
mg/kg in eight samples, including two catch basins (SD3 and SD8), five street dust 
samples (SD2, SD4, SD7, SD19, and SD21), and one push probe location (P81). 
TPH analyses of street dust and catch basin samples showed that of the four samples
collected to the west of 14th Avenue S (SD27, SD28, SD29, and SD30), none exceeded
the comparative criteriaSL for TPH-D (2,000 mg/kg). TPH-O exceeded the
comparative criteriaSL of 2,000 mg/kg at one of the four sampling locations, a catch
basin located at the southwest corner of S Donovan Street and 12th Avenue S (SD30).
The data for tThese six four sampling locations are located outside of the Adjacent
Streets boundary and therefore are not shown on Map 2-34 32 but are presented in
Appendix C. 
PAHs 
A total of 12 soil and street dust samples from within the Adjacent Streets Area were
analyzed for PAHs; two samples (SD8 and RCB101CB1-DAL) were collected from soil
that was subsequently removed in conjunction with the City's independent cleanup
actions. Total cPAH TEQs associated with both the remaining and excavated Adjacent
Streets soil are presented on Map 2-35.33. At five locations (MW-12 [two intervals],
P60, P81, and SW1-Tank), total cPAH TEQs exceeded the SL (0.14 mg/kg; [MTCA
Method B]). The highest cPAH TEQ was detected at MW-12 (320 mg/kg in the, 0.0- to- 
60.5-ft in. depth bgsinterval). cPAHs were detected at P60, located on Dallas Avenue S
(west of 16th Avenue S), where total Total cPAHs were detected in the 4-to-6-ft depth
interval at P60, located on Dallas Avenue S (west of 16th Avenue S) in the 4-to-6-ft
depth interval, and appeared to be associated with in a thin soil horizon between
5 and 5.5 ft bgs. At P81, located near the east end of S Donovan Street, total cPAHs
were detected in the 21-to-42-ft depth interval. The individual cPAHs chrysene,
dibenz(a,h)anthracene, and indeno(1,2,3-cd)pyrene, were also detected at
concentrations greater than the SL at these sample locations and intervals (see
Appendix C). 
Other SVOCs and VOCs 
Seven samples were collected from five locations within the Adjacent Streets (MW11,
MW-12, MW-13, P72, and P78) for benzene, toluene, ethylbenzene, and xylene (BTEX)
analyses. Benzene was detected at a MW-12 in two different intervals (0.0082 mg/kg
at 0 to 6 in. bgs and 0.0019 mg/kg at 2.5 ft bgs). Toluene was detected at three
locations (MW12, P72, and P78), with the highest concentration (11 mg/kg) at P78 on
Dallas Avenue S, between 17th Avenue S and S Donovan Street (east of Basin Oil). 
Phthalate esters, including BEHP, were detected in two street dust and catch basin 
samples. Concentrations of BEHP ranged from 0.79 mg/kg to 6.2 mg/kg (SW1-Tank). 
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In addition, there were detections of other miscellaneous SVOCs (4_methylphenol, and
phenol) and VOCs (2-butanone, carbazole, and carbon disulfide) in street dust and
catch basin samples (see Appendix C). 
Metals 
A total of 19 soil and catch basin/street dust samples from within the Adjacent Streets
were analyzed for metals. The soil from one two of these locations (SD8 and CB1--
DAL) was removed in conjunction with the City's independent cleanup actions.
Arsenic was the only metal that exceeded its SL (0.67 mg/kg; [MTCA Method 
B/TSCA]), which occurred at two all locations (MW-12 and P81; Map 2-36). Arsenic
was detected at varying depth intervals in 8 of the 19 soil and catch basin/street dust
samples analyzed (see Map 2-34 and Appendix C). Arsenic was not detected in the
remaining 11 samples; however, the arsenic reporting limits for these samples were all
greater than the SL. Arsenic concentrations associated with both the remaining and
excavated Adjacent Streets soil are presented on Map 2--3634. 
Dioxins and Furans 
Archived samples collected in 2004-2005 from catch basins, manholes, and street dust
as part of the City's source-tracing program for the LDW (Herrera 2004) were later
selected for the analysis of dioxins and furans. The samples included one street dust
sample (SD52) collected at the intersection of Dallas Avenue S and 16th Avenue S
(within the Adjacent Streets portion of the T-117 EAA) and a sediment sample (CB-41)
collected from a settling tank associated with an oil-water separator located on the
Basin Oil property (see Section 2.4.1). Analytical results from this sampling program
were compiled in 2008 and reviewed by the City in 2008 (Integral 2008b). The
dioxin/furan TEQ for the street dust sample (SD52) and settling tank sample (CB-41)
both exceeded the SL (11 ng/kg; [MTCA Method B/TSCA]), atwas 90.5 ng/kg and
15.2 ng/kg, respectively., exceeding the SL (11 ng/kg). The street dust at this sampling
location and the immediate vicinity was removed in 2005 based on PCBs as part of the
City's independent cleanup action (Section 2.2.4). 
In 2008, the City, in coordination withas directed by EPA, conducted a follow-up
sampling program to assess whether there were any other locations with elevated
dioxin concentrations in the vicinity of the 90.5 ng/kg result. Sixteen Fifteen samples
were collected from the Adjacent Streets in 2008 (Map 2-3735) and analyzed for
dioxins and furans and PCBs. Nine locations had dioxin/furan TEQs that were greater
than the SL. The highest dioxin/furan TEQ was detected in borehole P94 (84 ng/kg in
the 0.1--to--1.0-ft interval) on Dallas Avenue S immediately east of the intersection
with 16th Avenue S (south of the Marina). The next highest dioxin/furan TEQ was
detected on S Donovan Street adjacent to Basin Oil and the T-117 Upland Study Area
(30 ng/kg in the 0.4-to-1.0-ft depth interval at P100), Dallas Avenue S immediately
west of 17th Avenue S (32.4 ng/kg in the 0.1-to-1.0-ft depth interval at P95), and Dallas

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Avenue S at the intersection with 16th Avenue S (21.4 ng/kg in the 0.4-to-1.0-ft depth
interval at P90). 
Nine Eight MIS split samples collected in 2009 were analyzed for dioxins and furans
by Ecology. MIS samples were collected from the surface (0.0-to-0.2-ft [0.0-to-2.0-in.] 
depth interval 0.0-to-0.2-ft depth interval) and subsurface (0.2-to-0.5-ft [2.0-to-6.0-in.] 
depth interval 0.2-to-0.5-ft depth interval) at DU16 and DU17, located on the west and
east sides of 16th Avenue S, respectively (Map 2-3735). Dioxin/furan TEQs ranged
from 9.58 ng/kg in the at DU16-0.0-to-0.2-ft (0.0-to-2.0-in.) depth interval of DU16 to
43.8 ng/kg in the 0.0-to-0.2-ft (0.0-to-2.0-in.) depth interval at DU17-0.0-0.2. Surface
and subsurface samples were collected at DU18 and DU19, located along the west and
east portions of the bank, respectively, along lower S Donovan Street (Map 2-3735). 
Dioxin/furan TEQs ranged from 30.4 ng/kg to 51 ng/kg at DU18 (0.0-- to-- 0.5-ft and
0.2- to- 0.5 5-ft bgsdepth intervals, respectively). Dioxin/furan TEQs in all samples
exceeded 11 ng/kg,the SL with the exception of one sample at DU16 (9.58 ng/kg at the
DU16-0.0-0.20.0-to-0.2-ft depth interval). Map 2-33 386 shows the dioxin/furan TEQ
soil sample locations that were in areas where soil was removed as part of the City's
2004 and 2005 clean-up actions or were superseded by subsequent sampling in 
2009.presents the dioxin/furan TEQs in soil that were removed from or superseded by
MIS results. 
2.3.3.2   Residential Yards 
This section summarizes the data obtained from soil investigations conducted within
the Residential Yards between 2004 and 2009. 
Several investigations were conducted within the Residential Yards to support the
City's site characterization and independent cleanup actions between 2004 and 2006
(Integral 2006b) and to support boundary refinement activities completed since the
Adjacent Streets were included in the T-117 EAA in 2007 (Integral 2009; Windward
and Integral 2009). 
The detection of PCBs in Residential Yards samples collected in 2008 led to a request
by In the case of residential yards, DUsto encompass individual residential properties
or portions thereof based on a conceptual model of land use for residential properties
(i.e., differences in uses for front yards and backyards) and proximity to potential PCB
track-out in streets. The MIS increments were aggregated to form a single composite to
provide an average chemical concentration for soil in that DU (Integral 2009). 
Some of the 2009 sampling completed in the Adjacent Streets was also completed 
using MIS. EPA has determined that results from previous investigations that were 
based on point samples located within the 2009 DU areas were to be superseded by
results of the 2009 MIS sampling in that location. 
Appendix C includes a complete list of available data for each chemical analyzed in
the Residential Yards. Appendix C also identifies samples that were removed during
the City's independent cleanup actions or data that were superseded by subsequent
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MIS composite sampling data; these data are presented to illustrate the current spatial
distribution of contaminants. 
PCBs 
A total of 175 point and MIS 206 soil samples collected from within the Residential
Yards have been analyzed for PCBs. The source soils from for which 4544 of these 175 
samples were collected have since beenwas removed in conjunction with the City's
independent 2004 and 2005 cleanup actions., and PCB concentrations data for 47 of the
175 samples were superseded by the 2009 MIS sampling (as presented on Map 2-31). 
PCB concentrations associated with Residential Yards soil are presented on Map 2--
38367. 
Sampling performed during the City's cleanup near the intersection of Dallas
Avenue S and 17th Avenue S (across from the entrance to the T-117 Upland Study
Area) indicated that total PCB concentrations greater than the SL extended to depths
that were similar to those in the Adjacent Streets. All PCB-contaminated soil detected
within the residential lots was excavated and disposed of at an offsite landfill (Hart
Crowser 2005). 
Thirty-four Residential Yards point samples were collected in 2008 to assess the
concentrations of PCBs in residential soils near the ROWs. Twenty--eight four of these 
point sampling results were superseded by 2009 MIS results collected from the same 
yards. In locations where 2008 sampling results were not superseded by 2009 MIS
results did not supersede the 2008 results for Residential Yards (YC samples) or
discrete yard parking strip samples (YS samples) (sampling locations YC17 and YC18,
which were east of 16th Avenue S), total PCB concentrations ranged from 0.12 to 0.26
mg/kg (Windward and Integral 2009). 
MIS sampling conducted in 2009 was designed to identify average total PCB
concentrations in soil within individual DUs. The DUs were delineated collaboratively
with EPA to encompass individual residential properties or portions thereof based on
a conceptual site modelCSM of land use for residential properties (i.e., differences in
uses for front yards and backyards) and proximity to potential PCB track-out in
Adjacent Streets (Integral 2009). Fifty Residential Yards MIS samples were collected in
2009.Total PCB concentrations ranged from 0.043 mg/kg to 2.1 mg/kg at DU32 (0.0 -to
to-0.2 -ft depth intervalbgs). MIS DUs results with PCB concentrations that exceeded
1 mg/kg included DU01, DU14, DU32, and DU35. Map 2-38 367 provides presents the
PCB resultsconcentrations (with replicates averaged) the PCB results for the
Residential Yards DUs. Note that for the purposes of removal boundary delineation,
total PCB concentrations for each DU were adjusted for variance at the direction of
EPA (Appendix KL) as discussed in Section 4.4.3. Map 2-33 31 presents the total PCB
concentrations in soil that were removed from or superseded by MIS results. 

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Dioxins and Furans 
Dioxin/furan TEQs in soil samples collected from the Residential Yards are shown on
Map 2-39 3738 and presented in Appendix C. Nineteen composite samples (0.0-to-0.5-
ft depth interval) and four three discrete point samples were analyzed in 2008 to
evaluate the extent of contamination in Residential Yards (Windward and Integral
2009) and had concentrations up to 395 ng/kg (the 395 ng/kg result was considered to
be an outlier because of carbon fragments in the sample matrix; the next highest
concentration was 50.1 ng/kg). Fourteen Thirteen of these samples, including the
sample with the concentration of 395 ng/kg, were subsequently superseded by 2009
MIS samples. Map 2-36 shows the dioxin/furan TEQ soil samplinge locations that
were in areas where soil was removed as part of the City's 2004 and 2005 cleanup
actions or were superseded by subsequent sampling conducted by the City in 2008
and 2009.Samples collected in Residential Yards that had soil removed or samples that
were superseded by subsequent sampling are shown on Map 2-33. 
Dioxin/furan TEQs of in non-superseded Rresidential Yyard composite samples
(shown on Map 2-378) ranged from 4.69 ng/kg at YC16abc to 16.0 ng/kg at YC12abc.
Samples from YC12abc, YC13abc, YC14abc, and YC19abc were the only Rresidential
Yyard composite non-superseded samples that exceeded the SL (11 ng/kg; [MTCA
Method B]). 
Twenty-four MIS sample splits were provided to Ecology for dioxin and furan
analysis. The highest dioxin/furan TEQs were detected in DU01 at the west end of
Dallas Avenue S (50.1 ng/kg from the 0.0- to- 0.2- ft in [0.0-to-2.0-in.] depth interval 
and 38.2 ng/kg from the 0.2 2-to to-0.5 5-ft [2.0-to-6.0-in] in depth interval);) ( (Map 2--
3938). All MIS samples but one sample (in the 0.0-to-0.2-ft depth interval from DU03-
0.0-0.2) exceeded the SL (Ecology 2009a). 
2.3.4  Groundwater 
Groundwater data have been collected from both monitoring wells and intertidal
seeps throughout the T-117 EAA and vicinity since 1991. Historical (pre-2003)
groundwater conditions are detailed in the data gaps report (Windward et al. 2003).
Groundwater samples analyzed during sampling events conducted between 2003 and
2009 are considered most representative of current conditions and are summarized in
Section 2.3.4.1this Section. Section 2.3.4.1 discusses groundwater results for the T-117
Upland Study Area, and Section 2.3.4.2 discusses the groundwater results for Adjacent
Streets and Residential Yards Study Area. Section 2.3.4.3 discusses the seep water 
results. 
The T-117 EAA monitoring well network currently consists of 13 wells. Seven wells 
(MW-02, MW-03, MW-04R, MW-05R, MW-06, MW-07, and MW-08R) are located on
the T-117 Upland Study Area, four wells (MW-01, MW-09, MW-10, and MW-11) are
located just upgradient of the T-117 Upland Study Area on Dallas Avenue S, and two
wells (MW-12 and MW-13) are upgradient of Basin Oil on 17 th Avenue S and
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S Donovan Street. Locations of groundwater monitoring wells are shown on Maps 2-7 
and 2-8. Several seeps discharge from the shoreline bank. Many of these seeps are
seasonal, and the locations and flow rates of these seeps can vary. One seep is
relatively large with a consistent location and flow rate; the locations of sampled seeps 
are shown on Map 2-7. 
Appendix C includes all groundwater sampling data from 1991 through 2009 and
presented in Appendix C. Appendix B presents the assessment and development of
groundwater screening and site-specific removal action levels based on the
groundwater monitoring results, groundwater quality criteria to be achieved at the
point of discharge, and a detailed evaluation of the potential for contamination from
former asphalt plant operations to have impacted groundwater beneath the Adjacent
Streets and Residential Yards Study Area. 
2.3.4.1   T-117 Upland Study Area Groundwater Data 
Groundwater monitoring was occasionally conducted in the T-117 Upland Study Area
between 2003 to 2005. Below is a summary of the data results from the seven
consecutive quarters of groundwater monitoring conducted since first quarter 2008.
The following discussion is limited to the first quarter 2008 through the third quarter
2009 groundwater monitoring events because the fourth quarter 2009 groundwater
monitoring event had not been completed at the time that the EE/CA COC analysis
was conducted. Appendix C includes summary tables that contain all available data, 
including data from the fourth quarter 2009 event. 
PCBs 
Total PCBs were detected in 23 of 70 samples. Twenty-one of twenty-threeAll total
PCB detections were above the SLs (0.000064 g/L) for total PCBs. The maximum 
highest total PCB concentration was 2.0 g/L (at MW-03). PCBs were detected in six of
seven T-117 Upland Study Area wells during one or more sampling events. Aroclor
1260 was detected in all detected samples, and Aroclor 1254 was detected in two
samples (MW--05R and MW-08R). 
TPH 
Total TPH was detected in 17 of 57 samples and exceeded the SL (0.5 mg/L) in 16 
samples. The maximum detected total TPH concentration was 22 mg/L (at MW-03).
Total TPH exceeded the SL for in one or more samples in from two T-117 Upland
Study Area wells (MW-02 and MW-03).of five T-117 Upland Study Area wells. 
cPAH 
cPAHs were detected in 4 of 54 samples from three of seven T-117 Upland Study Area
wells (MW-03, MW-02, and MW-05R). One sample exceeded the SL (0.018 g/L) for
cPAH TEQ. The maximum cPAH TEQ was 0.20 g/L (at MW-05R). 

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Total cPAH TEQ were detected in 4 of 54 samples. One sample exceeded the SL for
total cPAH TEQ. The maximum total cPAH TEQ was 0.20 g/L (MW-05R). Total
cPAH TEQ was detected in three of seven T-117 Upland Study Area wells. 
Other SVOCs and VOCs 
The only SVOC detected above SLs in groundwater collected from T-117 Upland
Study Area wells was BEHP. BEHP was detected in 15 of 52 samples and exceeded the
SL (2.2 g/L) in 4 samples from three wells (MW-04R, MW-05R, and MW-06). The
maximum BEHP concentration was 16 J g/L (at MW-04R). 
Phenol has been detected but no concentrations have been above the SL (1,700,000 
g/L). Phenanthrene has also been detected; however, no applicable SL based on the
protection of a surface water receptor is available. BEHP was detected in 15 of 52
samples and exceeded the SL in 4 samples. The maximum BEHP concentration was 16
J g/L (MW-04R). BEHP exceeded the SL for one or more samples in three of six T-117
Upland Study Area wells. No other SVOCs or VOCs exceeded SLs for any samples. 
Metals 
Seven metals (arsenic, copper, cadmium, chromium, lead, silver, and zinc) have been
detected in groundwater. Only Arsenic, copper, and silver have been detected in
groundwater above the SLs. Arsenic was detected in all T-117 Upland Study Area
wells and exceeded the SL (0.00014 mg/L) in 16 of 48 samples from all seven wells.
Copper was detected in 12 of 43 samples and exceeded the SL (of 0.0031 mg/L) in six
detected samples from four T-117 Upland Study Area wells (MW-03, MW-04, MW-06,
and MW-08R). Silver was detected in 7 of 43 samples and exceeded the SL (of 0.0019
mg/L) in all detected samples from four T-117 Upland Study Area wells (MW-04,
MW-05R, MW-06, and MW-08R). The silver reporting limits for all non-detect samples
also exceeded the SL. 
Dioxins and Furans 
Groundwater samples collected during the fourth quarter 2008 sampling event were
analyzed for dioxins and furans. Groundwater samples were collected from three 
wells (MW-05R, MW-08R, and MW-10). All groundwater sample dioxin and furan
concentrations were below detection limits, with the exception of one congener from
MW-08R (1,2,3,4,6,7,8,9-octachlorodibenzo-p-dioxin), which resulted in a dioxin/furan
TEQ of 3.0-9 g/L), exceeding the dioxin/furan TEQ SL of 5.0-9 g/L. 
No samples exceeded the groundwater SLs for dioxins and furans. 
Light Non-Aqueous-Phase Liquid (LNAPL) 
During the 2004, 2005, and 2008 groundwater monitoring events, tidal studies were
conducted with an oil-water interface probe to determine the presence or absence of
light non-aqueous-phase liquid (LNAPL) in the groundwater monitoring wells. In 
2004 and 2008, no LNAPL was detected in any of the wells (Windward et al. 2005d;
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ENSR|AECOM 2008). In 2005, trace amounts of LNAPL (essentially a sheen [i.e.,
< 0.01-ft thick]), were detected in two wells (MW-02 and MW-07) (Windward et al.
2005d). During the 2009 second quarterly groundwater sampling event, a trace to
heavy trace sheen (with no measurable product thickness) was observed on the
groundwater at MW-03 (AECOM 2009b). 
2.3.4.2   Adjacent Streets and Residential Yards gGroundwater dData 
Groundwater sampling has not been conducted beneath the Adjacent Streets and
Residential Yards Study Area based on the findings of the 2005 site characterization
work plan (Integral 2005) and other investigations. The work plan noted that the depth
of contaminants in soil was shallow (maximum depth of 8 ft) relative to the depth of
groundwater (approximately 12 ft below Dallas Avenue S), the solubility and
consequent immobility of PCBs in soils was low, and that PCBs were detected only
infrequently and at low concentrations in groundwater from T-117 Upland Study Area
wells where PCB-impacted soil was in contact with groundwater. 
Although groundwater investigations have not been conducted in the Adjacent Streets
Study Area, several monitoring wells have been installed in and around the Adjacent
Streets, including the wells MW-01 MW-09, MW-10, MW-11, MW-12, and MW-13 and
three wells installed at the Marina. The results of groundwater monitoring associated
with these wells and soil conditions in the Adjacent Streets Study Area are evaluated
in Appendix B. This evaluation shows that while some chemicals have been
sporadically detected in groundwater below or immediately downgradient of Basin
Oil, the presence of a groundwater contamination beneath the Adjacent Streets Study
Area resulting from former asphalt plant operations is unlikely. Groundwater samples
collected from five locations in and around Basin Oil and from three wells at the
Marina indicated that PCBs were limited to a single detection (at MW-01), which was
not confirmed with subsequent monitoring The solubility of PCBs, dioxins and furans,
PAHs, TPH-D, and TPH-O is low, and the data indicate that where these chemicals
were detected in surface and subsurface soils, they have not leached to groundwater
in the 30-plus years that they have been present. The potential for contaminant
leaching in the future will be further reduced by removal of soils with residual
contamination as part of the permanent remedy for the site. 
2.3.4.3   Seeps 
Three seeps (Map 2-7) were identified and sampled in 2003 (Windward et al. 2005d).
The seep water samples were analyzed for PCBs, SVOCs, PAHs, other SVOCs, and
total metals. As presented in Appendix C, the only consistently detected chemicals
were BEHP, copper, chromium, and zinc. PCBs were detected in one seep sample
(SW3); however, it is possible that the PCBs were associated with contaminated fine
particles present in the seep sample instead of the water. This seep was subsequently
re-sampled, and the sample was centrifuged prior to analysis to remove any fine
particles, resulting in a non-detection for PCBs. It is unknown whether the PCBs were
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attached to fine particles traveling with the seep water or if contaminated particles
became entrained in the sample during collection. 
T-117 seep sample specific conductivity measurements were compared with T-117 the
groundwater and LDW surface water specific conductivity measurements to assess
whether the T-117 seeps were representative of bank- stored infiltrated LDW surface
water or T-117 groundwater. The fField parameters resultsmeasurements forT-117
seep and groundwater well samples are summarized in Tables 2-3 and 2-4. 
The average specific conductivity for the LDW in this reach of the river iwas 30,300
S/cm based on shallow measurements at the South Park Bridge in 2005 (Mickelson
and Williston 2006); these shallow measurements are more representative of water
that would infiltrate at T-117 and are less saline than deeper water, which would be
more influenced by salt water. The specific conductivity of the seep samples varied 
from 5,200 to 18,500 S/cm, with an average of 12,200 S/cm. Eight of the thirteen 
monitoring wells had average specific conductivities less than 1,000 S/cm. The
highest specific conductivities for monitoring wells were at MW-4R, MW-5R, MW-6,
and MW-8R; these four shoreline wells hadve average specific conductivities of 16,300,
6,600, 3,400, and 14,900 S/cm, respectively. The other well with elevated specific
conductivity was MW-13, located upgradient and near the bedrock outcropping 
describe in Section 2.1.5.2, with an average specific conductivity of 1,500 S/cm. 
Based on these data, it appears that the groundwater samples may have been diluted
by LDW surface water more than is typically anticipated. 
Table 2-3.  Summary of seep sampling field parameters at T-117 Early Action
Area 
Specific    Dissolved
Date    Temperature   Conductivity    Oxygen           ORP   Turbidity 
Seep   Sampled      (C)        (S/cm)      (mg/L)     pH     (mV)    (NTU) 
Seep 1   12/23/2003     7.46        5,213       9.22      7.14     467      nc 
Seep 2   12/23/2003     7.84        14,803       8.38      6.69     467      nc 
12/23/2003      9.28        18,527       7.81      7.09     358      nc 
Seep 3 
4/8/2004       9.6        14,781       9.72       9.11      79      1.12 
Seep minimum         7.46        5,213       7.81      6.69     79     1.12 
Seep maximum        9.6       18,527      9.72      9.11     467     1.12 
Seep mean           8.25       12,223      8.79      7.31     384     1.12 
Note: Stabilized field parameters are the values measured just prior to the collection of seep samples. 
C  centigrade 
nc  not collected 
NTU  nephelometric turbidity unit 
ORP  oxidation-reduction potential 


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Table 2-4.  Summary of monitoring well parameters at T-117 Early Action Area 
Temperature        Specific Conductivity      Dissolved Oxygen                           ORP              Turbidity 
(C)                  (S/cm)                 (mg/L)                  pH                    (mV)                  (NTU) 
Well ID    Min    Max    Mean    Min     Max    Mean   Min    Max    Mean    Min    Max    Mean    Min     Max    Mean    Min    Max    Mean 
MW-1    11.67   15.20   13.11    550     907     668    5.94   6.21    6.08    0.20    1.55    0.79    37.3    79.0    53.8    -4.4    1.8     0.0 
MW-2    10.46   19.42   14.55    533    1,136    691    6.45   7.61    6.79    0.24    1.34    0.54   -132.5    48.3    -74.0    0.0    8.3     2.3 
MW-3    10.41   16.86   13.72    418     502     471    6.27   6.47    6.35    0.14    1.43    0.85    -60.2    10.7    -30.9    0.0    8.9     4.0 
MW-4R   8.37   16.03   11.88   8,885   25,829   16,297   6.79   8.33    7.28    2.73    8.40    5.67   -165.2   272.4    87.0    0.0    9.5    2.9 
MW-5R   9.49   18.68   12.58   1,237   17,594   6,585   6.76   8.31    7.24    3.54    9.98    7.14   -64.1   192.5   103.3   0.0    2.7    0.9 
MW-6    10.89   15.41   13.49   1,145    4,590    3,368   6.53   6.96    6.78    3.35    6.32    4.94    21.8    204.9    126.1    5.2    7.8     6.6 
MW-7    11.99   16.76   13.95    122     268     190    5.80   6.24    6.00    2.45    6.82    4.93    24.4    164.4    124.0    0.0    7.0     2.7 
MW-8R   8.76   15.86   11.91   4,214   29,248   14,896   6.73   8.84    7.72    3.64    9.06    6.27   -34.4   233.3   102.6   0.2    1.3    0.7 
MW-9    12.34   13.21   12.78    307     556     432    5.95   6.11    6.03    4.75    5.67    5.21   180.1   232.4    206.3   0.65    1.04    0.85 
MW-10   10.17   12.96   11.64    214     422     328    5.48   5.95    5.71    0.65    1.84    1.38    66.7    181.3   144.7    1.5    14.0    5.1 
MW-11   10.44   17.61   13.64    340     825     624    5.90   7.06    6.40    0.18    0.74    0.44   -238.4   187.7    32.8    0.0    5.0     1.3 
MW-12   14.51   19.70   17.06    436     868     604    7.83   8.33    8.16    0.39    3.35    1.43   10.10   105.70   69.03   0.56   90.60   31.92 
MW-13   16.27   22.81   19.80   1,222    2,138    1,532   7.16   7.64    7.45    0.12    4.01    1.59   -91.40   73.30   -35.37   0.29   18.00    6.37 
Note: Stabilized field parameters are the values measured just prior to the collection of groundwater samples. 
C  centigrade 
ID  identification 
NTU  nephelometric turbidity unit 
ORP  oxidation-reduction potential 





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2.4   RECONTAMINATION ASSESSMENT AREAS 
This section describes the RAAs (Basin Oil and the Marina) and summarizes available
data relative to the SLs developed in Section 3 for all media for soil and sediment and
Appendix B for groundwater. The complete dataset for the RAAs is presented in
Appendix CF. The contaminants identified in at these RAAs at concentrations above
SLs will be incorporated into the analysis of potential recontamination of the T-117
Sediment Study Area from these two areas presented in Section 5.2. 
2.4.1  Basin Oil parcels 
2.4.1.1   Site dDescription and hHistory 
Basin Oil's primary operations occurred in the triangular-shaped property (8661
Dallas Avenue S) bounded by Dallas Avenue S to the east, Donovan Street S to the
south, and 17th Avenue S to the west (Map 1-1). Basin Oil operated at the site between
1987 and 2004 (Ecology 2005a). Prior to that time, the site served as the location of a
private residence. Three additional business entities are documented as having
operated on the property at one time or another during the Basin Oil tenure:
Frontwater, Inc.; Basin Tank and Environmental Services, Inc.; and Northwest
Antifreeze Service, Inc. Basin Oil also leased property on the T-117 Upland Study
Area, near the former asphalt plant facility located across the street to the east, where
they stored materials in drums and in a tank. Basin Oil also stored drums and trucks at
8617 17th Avenue S, a residential property, located across the street to the west. 
Basin Oil was a collector, transporter, and marketer of used oil. According to Basin
Oil's spill prevention, control, and countermeasure plan (Basin Oil 1995), materials
handled routinely at the facility included lubricating oil, Bunker C heating oil, diesel
fuel, crude oil, jet fuel, and gasoline. Used oils are generally known to contain PAHs.
Recycled and waste oils have been known to occasionally contain low concentrations
of PCBs and chlorinated solvents. Based on Ecology inspection reports (Ecology 2000;
Hohmann 1992), Frontwater and Basin Tank and Environmental Services handled
similar materials. Northwest Antifreeze Service handled new and used antifreeze.
Used antifreeze can contain metals such as lead and cadmium. 
According to a site assessment conducted in 1996 (Creative Environmental
Technologies 1996), the property was first developed and used for residential
purposes in the 1930s and was converted to an oil recycling facility in the late 1980s.
At the time of the 1996 site assessment, the northern portion of the property was
paved, and the southern portion was not. Standing water and tanks without
containment were both observed on the southern portion (Creative Environmental
Technologies 1996). 

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Basin Oil was visited by regulators on at least 12 occasions between December 1992
and December 2004 in the course of site inspections or in response to incident reports
or neighborhood complaints. Concerns and incidents included, but were not limited
to, the items listed below (Ecology 1992a, b, 1993a, 1994b, a, 2003; Hohmann 1992). 
Improper designation and labeling of wastes, including the potential handling
of hazardous wastes 
Errors, omissions, and discrepancies in waste manifests, including an allegation
of forgery 
Inappropriate waste storage containers 
Insufficient secondary containment 
A spill of 500 to 600 gal. of used fuel oil that occurred during Basin Oil
operations on the asphalt plant property in October 1993 
Inadequacies in the spill prevention, control, and countermeasure plan; the
stormwater pollution prevent plan; and in emergency planning procedures 
A more detailed discussion of selected compliance inspections and site visits is
available in the T-117 summary of existing information and data gaps analysis report
(Windward et al. 2003). 
Prior to 2005, surface runoff from Basin Oil and the Adjacent Streets flowed onto the
T-117 Upland Study Area and into the catch basins at the south side of the T-117 
Upland Study Area (SAIC 2007a). As described in Section 2.1.3.3, stormwater exiting
the site is now captured within the temporary stormwater collection system installed
during the City's independent cleanup action in the Adjacent Streets. 
Between 2004 and early 2008, the Basin Oil property facility underwent demolition
and stabilization, including the excavation of contaminated surface soil and
backfilling. Soil excavation occurred to depths of 2 to 2.5 ft across the site, with
excavations as deep as 4 ft in areas with visual or olfactory evidence of petroleum
(Ecology 2005a; Thomas 2008b). Site investigation samples were collected by Ecology
in 2009; these results are further discussed and summarized below. 
Excavation to a depth of about 6 in. was performed in the drum storage area on the
residential property at 8617 17th Avenue S (Thomas 2008a). That property has been
sold to the owner of the Marina and currently is being used for boat storage. An
application form for Ecology's Voluntary Cleanup Program (ENSR 2006) indicates that
Basin Oil is intended to be used for boat storage. 
2.4.1.2   Summary of existing environmental data 
Available data for Basin Oil includes historical (e.g., pre 2008 soil removal) soil,
groundwater, and liquids and sludges from tanks and drums at Basin Oil and post
post-2008 soil and groundwater data. The historical samples are not necessarily
representative of current site conditions inasmuch as some or all of the soil sampled
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may have been removed during the Basin Oil cleanup; however, they are discussed
below because they may have been potential previous source contamination to the
T-117 EAA. The most recent data are from analyses performed on investigational 
samples collected in 2008 and 2009 from Basin Oil following soil removal by the site
owner, and one sample (Drexler 2007) collected in 2007 from the 8617 17th Avenue S.
The recent samples are considered to be representative of current conditions and are
summarized below. Both historical and recent sampling locations are shown on
Map 2-3940 and results are presented in Appendix C and summarized in Appendix F. 
The historical and recent data are further evaluated in the recontamination assessment
presented in Section 5. 
Soil 
Historical Results 
The historical soil dataset for Basin Oil is limited and consists of 8 samples. One
surface soil sample and two subsurface samples were collected on the Basin Oil
property outside the fence line in the MW-01 boring in July 1991 (Parametrix 1991).
Two surface soil samples were collected and composited during the 1996 site
assessment (Creative Environmental Technologies 1996). Two samples were collected
from onsite drainage structures, a settling tank associated with an oil/water separator
and an area drain (CB41 and CB42, respectively), during a joint City/Ecology site visit
in July 2004 (Ecology 2005a). EPA collected a surface soil sample during a site visit in
May 2007 (Rodin 2007). Detected chemicals in soil collected from Basin Oil are
presented in Appendix F. 
Historical Basin Oil soil data were screened using the SLs developed for the T-117
EAA (Section 3). One of the 1996 composite surface samples and samples from two
subsurface intervals from the 1996 MW-01 boring exceeded the PCB SL (0.5 mg/kg).
TPH exceeded its SL in CB-41 and CB42. 
The dioxin/furan TEQ in CB-41 also exceeded the SL. Chromium was the only metal
detected in soil above the SL (which was detected in one sample from an MW-01
subsurface sample interval). A storm solids sample obtained from CB41 exceeded the
SL for lead. 
Current Results 
In May 2009, Ecology collected surface and subsurface soil from 10 locations on the
Basin Oil property (Map 2-3940) (Ecology 2009b). In May 2007, Basin Oil reported
concentrations for a soil sample collected at the 8617 17th Avenue S property (Ecology
2008). Basin Oil soil data were screened using the SLs developed for the T-117 EAA
(Section 3). Surface soil concentrations Concentrations of arsenic, TPH (lube oil and
gas), cPAHs, total PCBs, ethylbenzene, and xylenes in surface soils were greater than
their respective SLs. The total PCB concentration in one 12.5-ft-deep soil sample

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(BSB-3) was greater than the SL. The results of the recent soil sampling at the Basin Oil
property are presented in Appendix C and summarized in Appendix F. 
Groundwater 
Prior to 2009, only one groundwater monitoring well, MW-01, existed at Basin Oil,
located on the southeast property boundary (Map 2-79). MW-01 has been sampled
eight times between 1991 and 2008 (Windward et al. 2003; ENSR|AECOM 2008). 
Groundwater data from MW-01 collected during sampling events between 2003 and
2009 are considered to be the most representative of current conditions and were 
included as part of the groundwater summary presented for the T-117 EAA in
Section 2.3.4.1. 
Tanks and Drums 
EPA collected samples of liquid and/or sludge from two tanks and four drums during
a site visit in May 2007 (Rodin 2007). The tank and drum data do not directly represent
site environmental conditions but because they are indicative of past operations on the
site, they provide an indication of chemicals that could be present in the site soil and
groundwater. Aroclor 1260 was detected in sludge from one drum but not in sludge or
liquids from the other three drums or the two tanks. Petroleum was not analyzed in
the tank or drum samples. Chrysene, seven non-carcinogenic PAHs, three phthalates,
BTEX, one chlorinated solvent, and two non-chlorinated solvents were detected in
tank or drum samples. Arsenic, chromium, copper, lead, nickel, zinc and 16 other
metals were detected in tank and drum samples. The concentrations of chemical
analyses of the tank and drum samples are presented in Appendix C and summarized
in Appendix F. 
2.4.2  South Park Marina 
2.4.2.1   Site dDescription and hHistory 
The Marina is located at 8604 Dallas Avenue S and is adjacent to the T-117 Upland
Study Area to the north. Since the early 1970s, the site has been used as a small boat
marina and repair and maintenance facility. Activities at marinas elsewhere are
known to result in copper, lead, TBT, PAH, and phthalate impacts. Best management
practices (BMPs) are in place and Ecology has inspected the site. The Marina BMPs 
include the use of vacuum sanders, tarps to catch debris, routine sweeping of boat
maintenance areas, and a closed-loop wash system. Ecology concluded that the
potential for sediment recontamination associated with current operations is believed
to be low (SAIC 2007b). 
In the early to mid-1950s, A&B Barrel reconditioned and repainted drums on the
southeastern portion of the Marina using sodium hydroxide as a cleaning agent.
Liquid waste was discharged to an onsite pond that discharged to the LDW. The
northern half of the Marina was also formerly a mobile home park. Other former
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operations at the Marina site included the North Star Trading Company, Evergreen
Boat Transport, R.P. Boatbuilding, and Dekker Engineering. 
2.4.2.2   Summary of existing environmental data 
All available data collected from the Marina is are relatively recent and representative
of current conditions. The results of the Marina samples are further evaluated in
Section 5. All of the results from the Marina investigation are presented in Appendix 
C and summarized in F. 
Soil and Sediment 
In 2004 and 2006, the Port collected and analyzed seven soil samples for PCBs
(including a duplicate sample) near the boundary between the Marina and T-117
Upland Study Area. These sampling locations are shown on Map 2-4140, and the PCB
concentrations are presented in Appendix F. PCBs were detected at relatively low
concentrations in samples from all locations. At two locations (T-117 A11 and T-117
A12), Aroclor 1254 was detected in addition to Aroclor 1260 (Aroclor 1260 is the
predominant Aroclor at the T-117 EAA). TPH was also analyzed and detected in one
sample and the field duplicate sample from location T-117-A10, but at concentrations
well below the MTCA criteria (2,000 mg/kg). 
Ecology recently conducted a reconnaissance-level environmental investigation of the
area formerly occupied by A&B Barrel that included subsurface soil sampling
throughout the area formerly occupied by A&B Barrel and soil and sediment sampling
along two transects perpendicular to the shore (SAIC 2008). Thirteen subsurface soil
sampling locations were collected and analyzed for PCBs, pesticides, SVOCs, VOCs
and metals. Metals, PCBs, pesticides, PAHs, TPH and VOCs in soil samples collected
from the Marina were detected above their respective SLs (SAIC 2009). 
Three samples were collected along transects near the T-117 Upland Study Area and
Marina boundary and in front of the former A&B Barrel pond location (Map 2-394140).
Two soil samples were collected along each transect (one from the top of the bank and
one from just above the high water mark) and one sediment sample (collected from
the toe of the riprap bank). These samples were collected primarily to determine if
there were any impacts from the Marina bank soil to the sediment below. PCB
concentrations in two sediment samples (identified as Sediment Transect A and
Sediment Transect-B on Map 2-810) exceeded the SL for total PCBs (as Aroclor 1260),
indicating that PCBs from the Marina bank may have the potential to recontaminate
the sediment below. However, the total PCB concentrations in the soil samples from
Transects A and B (upgradient of the sediment samples) ranged from 0.073 to
0.17 mg/kg dry weight (dw) (0.61 to 8.5 mg/kg OC6). 
Groundwater 
Ecology's investigation of the area formerly occupied by A&B Barrel also included two
rounds of groundwater monitoring at three shoreline wells. Groundwater samples
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collected in October 2007 and March 2008 contained pesticides (detected in MW-3) and
arsenic (detected in all three site wells) above the Ecology screening criteria (SAIC
2009). One of the monitoring wells was located downgradient of a pond that
reportedly was used for liquid waste disposal in the 1950s. The other two wells were
installed in locations selected to characterize groundwater in other areas with a high
potential for impacts. Recent tidal data collected from T-117 EAA wells suggest that 
groundwater flow is parallel to the Marina/T-117 Upland Study Area property line.
Based on this groundwater flow pattern, migration from the Marina to the T-117
Upland Study Area is unlikely. Map 2-4140 provides the locations of the monitoring
wells and Map 2-57 presents the groundwater flow pattern. 














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3    Streamlined Risk Assessment 
This section presents the streamlined risk assessment. As described in the EE/CA 
guidance (EPA 1993), a streamlined risk assessment is an important component of an
NTCRA. This assessment is intermediate in scope between the limited risk assessment
conducted for emergency removal actions and the conventional baseline assessment
normally conducted for remedial actions. The streamlined risk assessment is presented
in this section, which includes: 
The identification of exposure pathways to potential receptors through the
development of a CSM (Figure 3-1) 
A comparison of SLs to site-specific data to determine media- and
subarea-specific COPCs for these pathways 
The identification of COCs for which site-specific removal action levels (i.e.,
RvALs) are have been derived etermined in (see Section 4.3) 
The purpose of this streamlined risk assessment is to support the development of the
NTCRA removal area boundary and design (i.e., alternative selection) and establish
the framework for post-NTCRA monitoring. The streamlined risk assessment
ultimately must demonstrate that the NTCRA is protective of ecological and human
receptors. This assessment is designed to be consistent with both MTCA and CERCLA
risk evaluation frameworks to ensure that all areas within the T-117 EAA that pose an
unacceptable risk will be addressed by the NTCRA. 
As specified in the EE/CA guidance (EPA 1993), the streamlined risk assessment
focuses on T-117 EAA media that are the focus of the NTCRA, including sediment in
the T-117 Sediment Study Area and soils in the T-117 Upland Study Area and
Adjacent Streets and Residential Yards Study Area. Groundwater considerations (i.e.,
groundwater potability, groundwater COCs, and RvALs) are discussed in
Appendix B, and an assessment of the potential for sediment recontamination from
groundwater has been incorporated into the development of groundwater RvALs
presented in Section 4.X3. 
3.1   CONCEPTUAL SITE MODEL AND PATHWAY IDENTIFICATION 
A CSM for the T-117 EAA was developed to present the relationships among 
confirmed and potential sources, release mechanisms, transport mechanisms,
exposure media, exposure routes, and potential receptors (Figure 3-1). A
comprehensive CSM is an essential part of the streamlined risk assessment because it
identifies pathways that must be considered in the design and successful
implementation of an early action. The CSM focuses primarily on current release and
transport mechanisms by which ecological and human receptors could be exposed. A

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summary of historical contaminant sources and associated site data was presented in
Section 2. 
As discussed in Section 1, the T-117 EAA includes the T-117 Sediment Study Area, the
T-117 Upland Study Area, and the Adjacent Streets and Residential Yards Study Area
(Map 1-1). The CSM includes all the study areas, although the importance of specific
transport mechanisms and exposure media varies significantly by study area, as
described below. 
3.1.1  Primary sources 
As shown in Figure 3-1, both historical and current primary sources have been
identified in the T-117 EAA. The principal historical source of contaminants was the
former asphalt manufacturing facility, which was located on property that is now part
of the T-117 Upland Study Area. The facility has been removed and is no longer a
source of contamination, although legacy contamination from the facility may still be
transported within and potentially outside of the T-117 EAA via secondary transport
mechanisms. 
Other nearby potential primary sources of contaminants (both historical and current)
include the Basin Oil property and the Marina, both of which have been identified in
this EE/CA as RAAs (Map 1-1). These properties are discussed in more detail in
Sections 2.4 and 5.2. Other regional sources that may have contributed to T-117 EAA
contamination, and may continue to do so, may also exist within the surrounding
urban area. 








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Figure 3-1. T-117 conceptual site model for current site conditions 
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3.1.2  Primary release and transport mechanisms 
Contaminant release mechanisms refer to the manner in which contaminants are
released from the primary source. Primary release mechanisms associated with the
former asphalt manufacturing facility included upland process-related releases, spills,
and the combustion of fuel oils, including recycled waste oils and PCB-contaminated
oil. The current and historical combustion of fuel and heating oils at other properties
in the vicinity of the T-117 EAA also represents a primary release mechanism. Urban
and industrial sources outside the T-117 EAA could also have resulted in releases to
sediment, soil, groundwater, stormwater, or air within the T-117 EAA. 
Contaminant transport mechanisms refer to the physical processes that move
contaminants from one area to another, including within the T-117 EAA and from
outside areas to the T-117 EAA. In the T-117 CSM (Figure 3-1), a primary transport
mechanism refers to a process that moves contaminants from the primary source to
one or more study areas within the EAA. 
The primary transport mechanism from combustion sources is atmospheric
deposition, either as dry deposition (during dry weather) or as wet deposition (during
rain events). This transport mechanism likely deposited contamination from the
former asphalt manufacturing facility and potentially other offsite sources to
sediments in the T-117 Sediment Study Area and soils in the T-117 Upland Study Area
and Adjacent Streets and Residential Yards Study Area. Other primary transport
mechanisms that likely moved contamination from the former asphalt manufacturing
facility to areas within the T-117 EAA include track-out, filling and dumping, dust
generation and transport, surface water flow (as stormwater), and groundwater
migration, infiltration, and adsorption/desorption (Figure 3-1). Each of these primary
transport mechanisms is briefly described below. 
Track-out refers to a process whereby contaminants in soil and ponded water adhere
to the tires of vehicles departing contaminated areas, such as the former asphalt
manufacturing facility property (which was unpaved), and are transported to adjacent
streets. Because the T-117 Upland Study Area is now paved, the historical mechanism
for the track-out transport of contaminated soil (i.e., track-out) is no longer active.
However, active sources such as spills or settled dust could still be contaminating the
paved surface and could continue to be tracked out. 
Filling and dumping6 likely were also primary transport mechanisms by which soil
was moved within the T-117 EAA. As discussed in Section 2.1.5.3, shallow soils in the
T-117 Upland Study Area and the Adjacent Streets and Residential Yards Study Area

6 For the purpose of the CSM, dumping is similar to filling in that potentially contaminated soil could
have been moved within the T-117 EAA and placed on the surface at another location within the
facility. 
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typically consist of fill material, primarily sand and silt, mixed with anthropogenic
materials (e.g., asphalt, bricks, rubble, and wood). No specific instances of dumping
have been documented in this EE/CA. Because the former asphalt manufacturing
facility has been removed, these primary transport mechanisms are no longer active. 
Dust generation could have also have resulted in the transport of contaminated
materials within the upland portions of the T-117 EAA. During dry weather, soil
particles from unpaved areas were blown throughout the T-117 EAA. Now that most
of the area occupied by the former asphalt manufacturing facility has been paved 
(except for a margin adjacent to the bank), this mechanism is less prevalent. 
The stormwater conveyance and discharge primary transport mechanism was relevant
historically and continues today. Stormwater runoff from the T-117 Upland Study
Area enters the LDW through a network of catch basins that discharge to two outfalls
located along the bank. Historically, this mechanism was likely a significant factor in
the transport of contaminants from the T-117 Upland Study Area to the T-117
Sediment Study Area. Since early 2000, improvements to the stormwater collection
systems at the T-117 Upland Study Area and Adjacent Streets and Residential Yards
Study Area by the Port and City have significantly controlled the stormwater pathway 
through infrastructure improvements. The major change was to prevent street runoff
in the area around Basin Oil from running across the T-117 Upland Study Area. 
Routine monitoring and inspections of the stormwater infrastructure are also being
conducted to verify the effectiveness of the stormwater controls. Runon to the T-117
Upland Study Area from nearby streets and all runoff from the Adjacent Streets and
Residential Yards Study Area is now controlled through the use of catch basins and
the redirection of stormwater, primarily to the County's CSS at a maintenance hole on
17th Avenue S and S Donovan Street. 
Groundwater primary transport mechanisms, including groundwater migration,
infiltration, and adsorption/desorption, were also active historically and continue
today. The current impact of these mechanisms has been reduced through the removal
and capping of soil in the area formerly occupied by the asphalt manufacturing
facility, previous removal actions at the T-117 Upland Study Area, and other source
control activities both within and outside of the T-117 EAA. 
As described above, some primary transport mechanisms related to stormwater and
groundwater remain active. The potential for these and other transport mechanisms to
recontaminate the T-117 Sediment Study Area is discussed in Section 5.2. 
The media affected by the primary transport mechanisms are designated as secondary
sources of contamination (Figure 3-1). Section 3.2 describes the manner in which
contaminants from these secondary sources may come in contact with people or
animals in specific study areas within the T-117 EAA. 

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3.2   STUDY AREA-SPECIFIC TRANSPORT MECHANISMS, RECEPTORS, AND
EXPOSURE PATHWAYS 
The following subsections describe the secondary transport mechanisms, receptors,
and exposure pathways applicable to each study area in the T-117 EAA. Secondary
transport mechanisms are similar to primary transport mechanisms with respect to the
physical process (e.g., stormwater discharge), but for the purpose of this discussion, a
distinction has been made between the mechanisms that were prevalent when the
primary source was active (i.e., primary transport mechanisms) and those that were
one step removed (i.e., secondary transport mechanisms). For example, primary
transport mechanisms transported contaminants from the former asphalt
manufacturing facility to various locations within the T-117 EAA. Now that the former
asphalt manufacturing facility is gone, the transport mechanisms are considered to be
secondary because media are no longer being contaminated by the original source.
This section discusses secondary transport mechanisms, although it should be
recognized that each of the primary transport mechanisms discussed in Section 3.1.2
likely influenced the distribution of contaminants in each study area. 
An exposure pathway focuses on the transport mechanism and exposure routes to a
potential receptor. An exposure pathway is considered complete if a chemical can
travel from a source to a receptor and is available to that receptor via one or more
exposure routes (EPA 1997a, b). The exposure route refers to the way in which the
receptor may be exposed (e.g., inhalation, ingestion). 
Note that exposures of ecological receptors were not evaluated for any of the upland
study areas (see Section 2.1.6). For the T-117 Upland Study Area, the current site
configuration has less than 0.25 acre of contiguous undeveloped land. As a result, the
current site configuration qualified the T-117 Upland Study Area for an exclusion from
the TEE (Washington Administrative Code [WAC] 173-340-7491). A simplified TEE
conducted for the Adjacent Streets and Residential Yards Study Area also concluded
that this study area qualified for the exclusion based on lack of substantial wildlife
exposure at the site (Integral 2006c). Consequently, terrestrial ecological receptors are
not shown in the CSM (Figure 3-1) or discussed in the rest of the section. Aquatic
ecological receptors are included. 
3.2.1  T-117 Sediment Study Area 
The T-117 Sediment Study Area has been contaminated by multiple sources, some of
which may be ongoing. The significant transport mechanisms for the T-117 Sediment
Study Area include: 
Erosion of upland surface soil, particularly on the bank 
Stormwater discharge 
Groundwater migration and seeps 

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Sediment transport within the LDW7 
Ecological and human receptors in the T-117 Sediment Study Area could be directly or
indirectly exposed to contaminants in soil, sediment, and river water as follows: 
Ecological  Animals using the LDW for habitat, including benthic
invertebrates, fish, birds, and mammals 
Direct exposure  Contact with or ingestion of porewater, river water, or
sediment 
Indirect exposure  Consumption of benthic invertebrates or fish 
Human  People using the LDW for recreation or food, including fishermen 
(tribal and recreational), kayakers, clammers, seafood consumers, and children
using the intertidal area for recreation 
Direct exposure  Incidental ingestion or dermal contact with sediment,
soil, seeps, or river water 
Indirect exposure  Consumption of seafood 
Other than incidental contact with seep water exiting the bank, there is no direct
contact with groundwater in the T-117 EAA (i.e., groundwater is not currently being
used for drinking water), nor is there any reasonable expectation of direct contact in
the future (see Appendix B for further details). 
3.2.2  T-117 Upland Study Area 
The T-117 Upland Study Area has been contaminated by multiple sources, some of
which may be ongoing. Contamination from the T-117 Upland Study Area may also
contaminate other study areas. 
Significant transport mechanisms for the T-117 Upland Study Area include: 
Erosion of bank soil to surface water and sediment  Portions of the upper
bank at the T-117 Upland Study Area have been covered with clean gravel or
stabilized with a geotextile fabric. Other portions of the upper bank are covered
with vegetation, which tends to control the erosion of underlying soil.
However, much of the original bank is still exposed to the river; where soil is
not stabilized, the potential for erosion of soil particles to the LDW exists. 


7 Extensive sediment transport modeling done for the LDW RI/FS indicated that the majority of the
sediment transported to the site originates from upriver locations. Sediment transport from
downstream locations to the T-117 Sediment Study Area is unlikely to occur in any appreciable
quantity (QEA 2008). Additional discussion of LDW sediment transport is provided in Section 5.2.4. 
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Stormwater outfall discharge  Stormwater from the T-117 Upland Study Area
enters the LDW through a network of catch basins that discharge to two outfalls
located along the river bank. 
Soil leaching to groundwater  PCBs and other hydrophobic chemicals in soil
are highly immobile because they are strongly sorbed to organic matter in soils
and thus have low partitioning from soil to water (EPA 1990). However, PCBs
and other hydrophobic chemicals may migrate in association with colloidal
particles or as dissolved components in more mobile substances, such as oil,
which have higher miscibility. PCBs and TPH have been detected in both soils
and groundwater in T-117 Upland Study Area and thus migration to
groundwater from soil may be occurring. 
Groundwater discharge to LDW surface water and sediment  Several active
groundwater seeps are present at the base of the shoreline bank and flow out
onto the intertidal mudflat. Because the shallow aquifer adjacent to the LDW is
tidally influenced, groundwater discharge is a mixture of river water from the 
preceding high tide and groundwater. Previous groundwater monitoring has
detected trace (i.e., just slightly above reporting limits) concentrations of
contaminants; thus, the migration from groundwater to LDW surface water and
sediment is a potential pathway. 
Dust generation and transport  Most soil at the T-117 Upland Study Area is 
covered with an asphalt cap. The asphalt cap reduces, if not eliminates,
migration pathways such as erosion and windblown dust generation from 
wind or vehicle traffic migration pathways. Also, any unpaved areas are either
capped with clean gravel or heavily vegetated, which helps stabilize the soil
and reduces erosion and the potential for fugitive dust generation. However, to
the extent that future construction activities disturb bank soils, dust generation 
and transport could be a transport mechanism. 
The T-117 Upland Study Area is currently closed to the public (secured by a chain link
fence and locked gate) and capped to reduce direct exposure to soil. Therefore, the
only current potential receptors in the T-117 Upland Study Area are workers who
perform occasional maintenance associated with the 2006 TCRA. These workers could
be exposed to contaminants in soil through the following exposure pathways: 
Direct contact or ingestion with soil  Direct contact (incidental ingestion and
dermal contact) could occur in areas where soil is uncapped, such as on the
bank, or where soil could become exposed during construction. Exposure
during construction will be mitigated through the use of personnel protective
equipment and engineering controls to prevent contact and access to soil 
during construction activities. 

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Inhalation and ingestion of windblown dust in outdoor air A small potential
for windblown dust exposure exists from the relatively small areas on the top of
the shoreline bank that are only covered with vegetation, or from areas
associated with site maintenance or construction activities. 
Currently, there is no direct contact with groundwater in the T-117 Upland Study
Area, nor is there any reasonable expectation of direct contact in the future. This
conclusion is supported by the potability evaluation presented in Appendix B. 
3.2.3  Adjacent Streets and Residential Yards Study Area  Adjacent Streets 
This section addresses the Adjacent Streets component of this study area; the
Residential Yards are discussed in Section 3.2.4. 
Currently, there are several secondary transport mechanisms for contaminants
entering and leaving the Adjacent Streets, as follows: 
Leaching from surface to subsurface soils  Infiltration of rainfall through the
soils can leach contaminants from surface soils to subsurface soils in street areas
where pavement is not intact or does not exist. 
Physical disturbance of soils  Surface soils along the streets could be exposed
via excavation by utility workers. 
Dust generation and transport  Surface soils, or subsurface soils that have
been brought to the surface through excavation, could be suspended by the
wind or vehicle traffic and deposited on nearby surface soils. Windblown
dDust can also be transported by stormwater. 
Stormwater discharge  Most stormwater runoff from streets in this study area
is currently carried to the CSS and/ or directly to the LDW from the temporary
stormwater storage tanks via occasional emergency overflow events (12 events
since 2005). Stormwater from a small portion of Dallas Avenue S flows onto the
T-117 Upland Study Area during emergency discharge events (see Section
2.1.3.3), where it is collected by the T-117 storm drainage system. Water in this
system is sampled on a regular basis. There has been one detection of total
PCBs (0.12 mg/kg) since treatment was discontinued in 2005 (January 2008)
(see Section 2.1.3.3) 
As discussed in Section 3.1.2, improvements to the stormwater collection systems at
the Adjacent Streets and Residential Yards Study Area by the City have significantly
reduced the volume the stormwater being discharged to the LDW from this area. Soil
contamination patterns discussed in Section 2.3 indicate that leaching likely has not
resulted in the contamination of groundwater in the Adjacent Streets; thus, this
transport mechanism is not considered to be significant for this portion of the study
area. The volatilization of VOCs to outdoor and indoor air is also not expected to be a

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significant pathway because the chemicals detected in soil and groundwater from the
Adjacent Streets are not volatile (see Section 2.3). 
People who could be exposed to chemicals in the Adjacent Streets include: 
Local residents 
Workers at commercial facilities within the study area 
Street or utility maintenance workers 
People could be exposed to contaminants in soil through the following pathways: 
Direct contact with soil  Direct contact (incidental ingestion and dermal
contact) could occur in areas where soil is uncapped, such as along street
shoulders. Local residents, workers at local industries, or workers performing
maintenance on streets could come into contact with surface soils. Residents
could also come into contact with these soils when doing maintenance or
lawn/yard improvement projects in ROWs. Soils that are capped or paved pose
no risk to residents or workers as long as the pavement remains intact. There is
a potential for future direct contact if people (e.g., utility workers) excavate 
areas with contaminated soil. 
Direct contact with stormwater  Stormwater in ROWs may pool in some
roadside areas, resulting in the potential exposure of local residents and
workers. 
Inhalation of windblown dust  -- Local residents and utility workers digging
trenches in the ROWs could inhale and potentially ingest windblown dust 
generated by wind or vehicle traffic. Workers at local businesses are assumed to
spend most of their time indoors, so they will not be exposed in any significant
way to windblown dust generated outside. However, dust generated outside of
buildings may ultimately be tracked inside, where it could be inhaled and
potentially ingested by workers. 
3.2.4  Adjacent Streets and Residential Yards Study Area  Residential Yards 
Currently, secondary transport mechanisms for contaminants entering and leaving the
Residential Yards include: 
Dispersal from streets  -- Once tracked onto the streets, contaminants may
have been dispersed into yards by foot traffic, residential parking, road splash,
and dust from the streets. 
Leaching to subsurface soils  Infiltration of rainfall through the soils could
potentially leach contaminants from surface soils to subsurface soils. 
Physical disturbance of soils  Subsurface soils could be brought to the surface
by residents gardening or undertaking lawn/yard improvement projects. 
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Dust generation and transport -- Surface soils along the streets could be picked
up by the wind or vehicle traffic and deposited onto surface soils in residential 
yards. 
Soil contamination patterns discussed in Section 2.3 indicate that leaching likely has
not resulted in the contamination of groundwater in the Residential Yards; thus, this
transport mechanism is not considered to be significant for this study area.
Volatilization of VOCs to outdoor and indoor air is not expected to be of concern
because the contaminants detected in the yards are not volatile (see Section 2.3). 
People who could be exposed to contaminants in residential yards include local
residents and utility workers, who could be exposed to contaminated soil through the
following pathways: 
Direct contact with soil -- Direct contact is a potential pathway in areas where
soil is uncapped, such as lawns, flowerbeds, and gardens, both as incidental
dermal contact or ingestion (including consumption of home-grown produce). 
Residents could come in contact with subsurface soil through projects that
involve digging, including digging through surfaces that may currently be
paved or otherwise capped. Residents with pets could also be exposed to soils
that may have adhered to the animals' coats. Soils that are capped or paved
(e.g., houses, paved driveways) pose no potential risk to residents as long as the
surfacing or pavement remains intact. 
Inhalation of windblown dust  Local residents or utility workers digging in
yards could inhale and potentially ingest windblown dust generated by wind
or vehicle traffic. In addition, residents inhale and potentially ingest dust within
households, some of which may have come from soils within the Residential
Yards Study Area. The soil ingestion rate used to derive soil CULs includes the 
ingestion of indoor dust derived from outdoor soil. 
People using the LDW may be local residents, which would lead to cumulative
exposures between the Residential Yards and the T-117 Sediment Study Area. 
3.3   CONTAMINANTS OF CONCERN SELECTION PROCESS AND RESULTS 
This section presents the final COC analysis for the T-117 EAA, which was derived
from the COPC analysis presented in the EE/CA Work Plan (Windward et al. 2008) 
and more recent data. In this analysis, COPCs were first identified based on a
comparison of sediment and upland soil data to SLs relevant to the contaminant
transport pathways and exposure routes discussed in Section 3.2. COCs for soil and
sediment were then selected from the COPC list based on several factors, including
detection frequency, age of data, and administrative decisions. The specific rationale
used for COC designation is described in more detail by study area below. 

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SLs are health-protective risk-based values developed for specific media; they are
based on specific exposure pathways to specific receptors. Because a single medium
may be relevant to multiple exposure pathways (or routes), as demonstrated in the
CSM (Figure 3-1), the screening process must explicitly identify the exposure
pathways that are evaluated, as summarized in Table 3-1. In some cases, exposure
pathways not explicitly addressed in SL development will be further evaluated in
Section 4 (as part of the development of RvALs) or in Appendix B (for groundwater).
Note that COCs were not identified for sediment for the seafood ingestion pathway
noted in Section 3.2.1. 
Table 3-1.  Exposure pathways addressed by screening levels 
Incorporation of Exposure Pathway for 
Medium        Exposure Pathway             Screening Level Development 
yes, by use of SQS for the protection of benthic
direct contact by aquatic organisms 
invertebrates 
yes, by use of EPA risk-based goals for residential soil
Sediment     direct contact by people 
(to be used as surrogate for sediment) 
no, to be addressed as part of RvAL development
seafood consumption by people 
(Section 4) 
direct contact by people (incidental
yes, by use of MTCA values for residential soil 
ingestion and dermal contact) 
no, to be addressed as part of the development of
protection of groundwater quality 
groundwater RvALs (Section 3.3.3 and Appendix B) 
no, to be addressed as part of the recontamination
protection of sediment quality 
assessment (Section 5) 
no, risk assessments conducted for other sites with
hydrophobic contaminants (e.g., PCBs along the
Soil                                        Housatonic River) suggest that risks associated with
consumption of home-grown produce
consuming plants grown in soil containing PCBs at the
by people 
concentrations present in Residential Yards are
-6
approximately 1 10 , the MTCA target risk level (see
Section 3.3.2) 
no, exposures through the dust inhalation and ingestion 
pathway are much less than exposures through the soil
incidental ingestion pathway (EPA Regions 3, 6, and 9
indoor dust inhalation and ingestion 
soil PRG for inhalation is 87,000 ng/kg for dioxins and
5,800 ng/kg for PCBs) so screening based on the soil
incidental ingestion pathway is protective. 
yes, by use of ambient water quality criteria to protect
Groundwater   protection of surface water quality 
surface water beneficial uses 
EPA  US Environmental Protection Agency 
MTCA  Model Toxics Control Act 
PCB  polychlorinated biphenyl 
PRG  preliminary remediation goal 
RvAL removal action level 
SQS  sediment quality standards 

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3.3.1  Sediment 
SLs for sediment were developed in consideration of both ecological and human
health. Sediment quality standards (SQS) (173-204 WAC) were selected for ecological
health. These standards are designed to protect benthic invertebrates in marine
sediment. These standards are likely protective of other ecological users of the T-117
Sediment Study Area because of the small size of this area relative to the home ranges
of fish, birds, and mammals within the LDW (Windward 2007a). 
For human health, neither EPA nor Ecology have published risk-based SLs for direct
contact with sediment. However, EPA has developed screening values for residential
soil exposure, which can be used as an acceptable and health-protective surrogate for
the purposes of screening for sediment exposure. The lower of the two values (i.e.,
SQS and EPA screening values for residential soil) for each chemical were used as SLs
for sediment in this assessment (Table 3-2). 
Table 3-2.  Sediment screening levels 
EPA Screening
SQS       SQS       Value 
a              b
Chemical         (original units)   (mg/kg dw)    (mg/kg dw)    SL Used fFor EE/CA 
Metals and Trace Elements 
Aluminum                  na          na         7,700        7,700 mg/kg 
Antimony                   na          na          3.1          3.1 mg/kg 
Arsenic                    57 mg/kg         57          0.39         0.37mg39mg/kg 
Barium                    na          na         1,500         1,500 mg/kg 
Cadmium              5.1 mg/kg       5.1         7.0         5.1 mg/kg 
Chromium              260 mg/kg       260         39          39 mg/kg 
Copper                 390 mg/kg       390         310         310 mg/kg 
Iron                           na            na           5,500           5,500 mg/kg 
Lead                   450 mg/kg       450          40          40 mg/kg 
Manganese                na         na         180         180 mg/kg 
Mercury                 0.41 mg/kg       0.41          2.3          0.41 mg/kg 
Molybdenum               na         na         39         39 mg/kg 
Silver                       6.1 mg/kg         6.1            39            6.1 mg/kg 
Thallium                      na           na           0.51          0.51 mg/kg 
Vanadium                 na          na          39          39 mg/kg 
Zinc                      410 mg/kg        410          2,300          410 mg/kg 
PAHs 
2-Methylnaphthalene         38 mg/kg OC      0.59          31          38 mg/kg OC 
Acenaphthene            16 mg/kg OC      0.25         340        16 mg/kg OC 

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EPA Screening
SQS       SQS       Value 
a              b
Chemical         (original units)   (mg/kg dw)    (mg/kg dw)    SL Used fFor EE/CA 
Acenaphthylene           66 mg/kg OC       1.0          na         66 mg/kg OC 
Anthracene              220 mg/kg OC      3.4         1,700        220 mg/kg OC 
110 mg/kg OC      1.7                          c 
Benzo(a)anthracene                                  0.15        110 mg/kg OC
99 mg/kg OC      1.5                          c 
Benzo(a)pyrene                                    0.02         99 mg/kg OC
Benzo(g,h,i)perylene         31 mg/kg OC       0.48          na          31 mg/kg OC 
Total benzofluoranthenes      230 mg/kg OC       3.6                              c 
0.15         230 mg/kg OC
cPAH TEQ                na                  0.015        0.015 mg/kg 
Chrysene               110 mg/kg OC      1.7          15         110 mg/kg OC 
c 
Dibenzo(a,h)anthracene       12 mg/kg OC      0.19         0.02         12 mg/kg OC
Dibenzofuran             15 mg/kg OC      0.23          na          15 mg/kg OC 
Fluoranthene             160 mg/kg OC      2.5          230         160 mg/kg OC 
Fluorene                 23 mg/kg OC      0.36          230         23 mg/kg OC 
Indeno(1,2,3-cd)pyrene       34 mg/kg OC       0.53                             c 
0.15         34 mg/kg OC
Naphthalene             99 mg/kg OC       1.5         3.90         99 mg/kg OC 
Phenanthrene            100 mg/kg OC      1.6          na         100 mg/kg OC 
Pyrene                1,000 mg/kg OC      16          170        1,000 mg/kg OC 
Total HPAH (calc'd)          960 mg/kg OC       15           na          960 mg/kg OC 
Total LPAH (calc'd)          370 mg/kg OC       5.7           na          370 mg/kg OC 
Phthalates 
BEHP               47 mg/kg OC     0.73        35        47 mg/kg OC 
BBP                4.9 mg/kg OC     0.076        260        4.9 mg/kg OC 
Diethyl phthalate             61 mg/kg OC       0.95          4,900          61 mg/kg OC 
Dimethyl phthalate           53 mg/kg OC       0.82          na          53 mg/kg OC 
Di-n-butyl phthalate          220 mg/kg OC       3.4           na          220 mg/kg OC 
Di-n-octyl phthalate           58 mg/kg OC       0.90           na           58 mg/kg OC 
Other SVOCs 
1,2,4-Trichlorobenzene       0.81 mg/kg OC      0.013          8.7         0.81 mg/kg OC 
1,2-Dichlorobenzene         2.3 mg/kg OC      0.036         200         2.3 mg/kg OC 
1,4-Dichlorobenzene         3.1 mg/kg OC      0.048         2.6         3.1 mg/kg OC 
2,4-Dimethylphenol           29 g/kg        0.029         120         0.029 mg/kg 
4-Methylphenol             670 g/kg        0.67          na          0.67 mg/kg 
Benzoic acid                650 g/kg        0.65         24,000         0.65 mg/kg 
Benzyl alcohol               57 g/kg        0.057         3,100          0.057 mg/kg 
Hexachlorobenzene        0.38 mg/kg OC     0.0059        0.30        0.38 mg/kg OC 

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EPA Screening
SQS       SQS       Value 
a              b
Chemical         (original units)   (mg/kg dw)    (mg/kg dw)    SL Used fFor EE/CA 
n-Nitrosodiphenylamine       11 mg/kg OC       0.17          99          11 mg/kg OC 
Pentachlorophenol           360 g/kg       0.36          3.0          0.36 mg/kg 
Phenol                  420 g/kg       0.42         1,800         0.42 mg/kg 
Pesticides 
Dieldrin                        na            na           0.03           0.03 mg/kg 
Total DDTs                  na          na          1.4           1.4 mg/kg 
Toxaphene                 na          na         0.44         0.44 mg/kg 
PCBs 
d
Total PCBs               12 mg/kg OC      0.19         0.22         12 mg/kg OC 
Dioxins and Furans 
Dioxin/furan TEQ               na           na        0.0000045         4.5 ng/kg 
a
SQS values originally presented in units of mg/kg OC were converted to mg/kg dry weight to facilitate
comparison with the EPA PRGs that are also in dry weight units. A TOC concentration of 1.55%, reflecting the
average TOC concentration in the T-117 Sediment Study Area, was assumed. 
b 
Values are from EPA's regional screening values for residential soil (EPA
2009f)(www.epa.gov/reg3hwmd/risk/human/rb-concentration_table/index.htm). Values based on a non-
carcinogenic endpoint were divided by 10 to be equivalent to a hazard quotientHQ of 0.1 per EPA Region 10
guidance (EPA 1996b). 
c
SL is based on ecological effects (i.e., SQS) even though human health SL is lower. This cPAH is evaluated as
part of the cPAH TEQ parameter. 
d
If the SQS value of 12 mg/kg OC is not used because the TOC value in a sediment sample is either higher or
lower than 0.5 to 3.5%, then a site-specific calculation, or "surrogate," can be applied, which results in a value
of 0.19 mg/kg dw. 
BBP  butyl benzyl phthalate                      MTCA  Model Toxics Control Act 
BEHP  bis(2-ethylhexyl) phthalate                  na  not applicable 
cPAH  carcinogenic polycyclic aromatic hydrocarbon     OC  organic carbon 
DDT  dichlorodiphenyltrichloroethane               PAH  polycyclic aromatic hydrocarbon 
dw  dry weight                              PCB  polychlorinated biphenyl 
EE/CA  engineering evaluation/cost analysis           PRG  preliminary remediation goal 
EPA  US Environmental Protection Agency           SL  screening level 
HPAH  high-molecular-weight polycyclic aromatic       SQS  sediment quality standards 
hydrocarbon                           SVOC  semivolatile organic compound 
HQ  hazard quotient                          TEQ  toxic equivalent 
LPAH  low-molecular-weight polycyclic aromatic        TOC  total organic carbon 
hydrocarbon 
Bold identifies the concentrations used as the values were identified as SLs. 
In the first step of the COPC and COC identification process, the SLs presented in
Table 3-2 were compared to maximum concentrations in T-117 sediment. Screening
was conducted for sediment (surface and subsurface) data collected since 1990. A
complete description of all the data management rules used in this step is provided in

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Appendix D.8 As part of the second step, a 5% frequency of detection threshold was
selected so that infrequently detected chemicals that may be artifacts in the data as a
result of sampling, analytical, or other issues were excluded from further analysis,
thereby focusing further evaluation on the contaminants most likely to pose the
majority of site risk. This process is consistent with EPA risk assessment guidelines for
focusing risk assessments when large numbers of chemicals are present at a site (EPA
1989). In addition, the possibility that these infrequently detected chemicals are from
of a unique and localized sources was considered prior to the exclusion of those
chemicals as COCs. The final step was included to provide additional refinement of
the COC list by considering whether the CSM suggests that a COPC may be related to
operations within the T-117 EAA. 
Table 3-3 lists each sediment COPC and provides a rationale for the COC designation.
COPCs were retained as COCs if there was a known or suspected T-117 Upland Study
Area source of the chemicals and the concentrations of chemicals in sediment
exceeded their respective SLs. The COPCs include total PCBs, several PAHs (including
cPAHs), six metals, BEHP, BBP, hexachlorobenzene, dioxins and furans, and phenol.
Approximately 50% of the total PCB concentrations in the T-117 Sediment Study Area
wasere greater than the SL, suggesting widespread the presence of PCB contamination
in the area. Total PCB concentrations were as high as 2,600 mg/kg -OC (51 mg/kg
dw), which is more than 200 times the SL. The average total PCB concentration was
greater than the SL by a factor of approximately 10. Concentrations of the other
COPCs were greater than the applicable SLs much less frequently and by much
smaller magnitudes (see Appendix E for all screening results). 





8 As part of the data aggregation necessary for screening, data management rules were established for
the T-117 EAA; these rules were consistent with those used in the LDW RI/FS. Data management
rules ensure consistency among the various datasets used in the screening. Significant Ddata
management rules included summation rules for determining total PCBs or PAHs, carbon
normalization of dry- weight values, and averaging of replicates, and the application of significant
figures. These rules were also used to determine how TEQs for contaminants such as dioxins and
furans and cPAHs were calculated. 
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Table 3-3.  Sediment COPCs and COCs 
Designated
as a COC?                             a
COPC                       Rationale for COC Selection
Metals 
risk estimates from LDW HHRA were well below thresholds of
Aluminum               no 
concern 
risk estimates from LDW HHRA were well below thresholds of
Antimony                no 
concern 
Arsenic                   yes     upland source, one or more recent SL exceedances in sediment 
risk estimates from LDW HHRA were well below thresholds of
Iron                        no 
concern 
risk estimates from LDW HHRA were well below thresholds of
Lead                   no 
concern 
risk estimates from LDW HHRA were well below thresholds of
Manganese              no 
concern 
PAHs 
2-Methylnaphthalene         yes     upland source, one or more recent SL exceedances in sediment 
Acenaphthene             yes     upland source, one or more recent SL exceedances in sediment 
Anthracene               yes     upland source, one or more recent SL exceedances in sediment 
Benzo(a)anthracene          yes     upland source, one or more recent SL exceedances in sediment 
Benzo(a)pyrene            yes     upland source, one or more recent SL exceedances in sediment 
Benzo(g,h,i)perylene          yes     upland source, one or more recent SL exceedances in sediment 
Total benzofluoranthenes       yes     upland source, one or more recent SL exceedances in sediment 
cPAH TEQ             yes    upland source, one or more recent SL exceedances in sediment 
Chrysene                yes     upland source, one or more recent SL exceedances in sediment 
Dibenzo(a,h)anthracene        yes     upland source, one or more recent SL exceedances in sediment 
Dibenzofuran              yes     upland source, one or more recent SL exceedances in sediment 
Fluoranthene              yes     upland source, one or more recent SL exceedances in sediment 
Fluorene                 yes     upland source, one or more recent SL exceedances in sediment 
Indeno(1,2,3-cd)pyrene        yes     upland source, one or more recent SL exceedances in sediment 
Phenanthrene             yes     upland source, one or more recent SL exceedances in sediment 
Total HPAH (calc'd)           yes     upland source, one or more recent SL exceedances in sediment 
Total LPAH (calc'd)           yes     upland source, one or more recent SL exceedances in sediment 
Phthalates 
BEHP               no     single SL exceedance > 10 yrs old 
BBP                 no     no upland source, single SL exceedance > 10 yrs old 
Other SVOCs 
Hexachlorobenzene          no     no upland source, single SL exceedance > 10 yrs old 

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Designated
as a COC?                             a
COPC                       Rationale for COC Selection
Phenol                  yes     upland source, one or more recent SL exceedances in sediment 
PCBs 
Total PCBs               yes     upland source, one or more recent SL exceedances in sediment 
Dioxin and Ffurans 
upland source, assumed to be present at concentrations above the
Dioxin/furan TEQ            yes 
SL, although very few samples have been analyzed 
a 
Upland source indicates there is a known or suspected source of the COPC in the T-117 Upland Study Area.
BBP  butyl benzyl phthalate                            PAH  polycyclic aromatic hydrocarbon 
BEHP  bis(2-ethylhexyl) phthalate                        PCB  polychlorinated biphenyl 
COC  contaminant of concern                         SL  screening level 
COPC  contaminant of potential concern                   SVOC  semivolatile organic compound 
cPAH  carcinogenic polycyclic aromatic hydrocarbon            T-117  Terminal 117 
HPAH  high-molecular-weight polycyclic aromatic hydrocarbon     TEQ  toxic equivalency quotient 
LPAH  low-molecular-weight polycyclic aromatic hydrocarbon 
Most of the COPCs were also designated COCs, except for phthalates,
hexachlorobenzene, and five of the six metals (all but arsenic). The phthalates and
hexachlorobenzene were not designated as COCs because only a single sample result
for each contaminant exceeded SLs and the samples was collected more than 10 years
ago. Concentrations from all of the more recently collected samples were less than the
SLs for these chemicals. Concentrations for aluminum, antimony, iron, lead, and
manganese in T-117 sediments were similar to concentrations evaluated in the LDW
HHRA for which risk estimates were well below thresholds of concern (i.e., hazard
quotient [HQ] of 1 or blood lead concentrations of 10 g/dl). Consequently, these 
metals were not designated as COCs for the T-117 Sediment Study Area. 
3.3.2  Soil 
This section presents the soil SL development process and the identification of COPCs
and COCs for soil for each relevant exposure pathway. As noted in Section 3.2, the
terrestrial ecological exposure pathway is not complete. The soil-to-groundwater
pathway was directly addressed by evaluating the groundwater concentrations versus
relevant SLs in Appendix B (see Section 3.3.3). The soil SLs for direct human contact
were based on the MTCA Method B standard formula values, with the exception of
lead and TPH. For lead and TPH, the soil SLs were based on the MTCA Method A
unrestricted land use CULs (Table 3-4). Method A provides the only applicable SLs for
these chemicals. As noted in Table 3-1, SLs for the protection of sediment were not
developed. There are no significant transport mechanisms to the T-117 Sediment
Study Area for most of the soils present in the T-117 Upland Study Area and the
Adjacent Streets and Residential Yards Study Area. Consequently, there is no need to
address the protection of sediment quality for most of the soil areas. HoweverUnder
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present conditions, soil in some portion of the T-117 Upland Study Area, particularly 
on or near the bank, could be transported to the sediment, either now or after the
NTCRA is completed through the erosion of bank soil to surface water and sediment
via stormwater runoff. However, there are no bank surface soil data available to
perform a risk-based screening. After completion of the NTCRA, Because all of these 
bank or near-bank soils will either be removed or completely isolated so that it cannot
be transported to sediment, so as part of the NTCRA, there is no need to conduct
additional risk-based screening for the protection of sediment quality. Any current soil
areas in the T-117 Upland Study Area that would become part of a future LDW
sediment area as the result of the post-NTCRA configuration will meet applicable
sediment RvALs at the appropriate point of compliance as discussed in Section 4. 
Table 3-4.  Soil screening levels 
Concentration (mg/kg) 
MTCA Method B        SL Used for
Detected Chemicals       Carcinogen    Non-Carcinogen      EE/CA 
Metals 
Aluminum                   nc           nc           nc 
Arsenic                       0.67            24            0.67 
Barium                      nc          16,000         16,000 
Cadmium                  nc          80          80 
Chromium                  nc          nc           nc 
a 
Chromium (III)                   nc           120,000          240
Chromium (VI)                  nc           240           240 
Copper                     nc          2,960         3,000 
b
Lead                       nc           nc           250
Mercury                      nc           24            24 
Nickel                          nc            1,600           1,600 
Silver                            nc             400             400 
Zinc                           nc           24,000          24,000 
SVOCs 
1-Methylnaphthalene              nc            nc            nc 
2-Methylnaphthalene              nc           320           320 
Acenaphthene                 nc          4,800         4,800 
Acenaphthylene                nc           nc            nc 
Anthracene                   nc          24,000         24,000 
c 
Benzo(a)anthracene             0.14           nc            nc
c
Benzo(a)pyrene                0.14           nc           nc 
c
Benzo(b)fluoranthene             0.14           nc            nc 
Benzo(g,h,i)perylene               nc            nc             nc 

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Concentration (mg/kg) 
MTCA Method B        SL Used for
Detected Chemicals       Carcinogen    Non-Carcinogen      EE/CA 
c
Benzo(k)fluoranthene             0.14           nc            nc 
Benzofluoranthenes               nc            nc            nc 
Benzoic acid                    nc          320,000         320,000 
Benzyl alcohol                   nc           24,000          24,000 
BEHP                   71         1,600         71 
BBP                     nc         16,000        16,000 
c
Chrysene                   0.14          nc           nc 
c
Dibenzo(a,h)anthracene           0.14           nc            nc 
Dibenzofuran                   nc           160           160 
Dimethyl phthalate                nc           80,000          80,000 
Fluoranthene                   nc           3,200          3,200 
Fluorene                      nc           3,200          3,200 
c
Indeno(1,2,3-cd)pyrene            0.14           nc            nc 
Naphthalene                  nc          1,600          1,600 
Phenanthrene                 nc           nc           nc 
Pyrene                      nc          2,400          2,400 
cPAH TEQ                 0.14         nc          0.14 
PCBs 
Total PCBs                   0.50           nc           0.50 
TPH 
b
Total diesel-range hydrocarbons       nc            nc           2,000
b
Gasoline-range hydrocarbons         nc            nc           100
Dioxin and Furans 
Dioxin/furan TEQ              0.000011          nc          0.000011 
a
Hexavalent chromium criterion used because chromium speciation was not performed. 
b
Value from MTCA Method A for soil for unrestricted land use. 
c
Individual carcinogenic PAHs were evaluated only as part of the cPAH TEQ. 
BBP  butyl benzyl phthalate                      SL  screening level 
BEHP  bis(2-ethylhexyl) phthalate                  SVOC  semivolatile organic compound 
cPAH  carcinogenic polycyclic aromatic hydrocarbon     TEQ  toxic equivalency quotient 
EE/CA  engineering evaluation/cost analysis           TPH  total petroleum hydrocarbons 
MTCA  Model Toxics Control Act                 TSCA  Toxic Substances Control Act 
nc  no criteria                                  VOC  volatile organic compound 
PCB  polychlorinated biphenyl 
Bold values were identified as SLs. 


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3.3.2.1   T-117 Upland Study Area 
Similar to the approach used to evaluate the T-117 Sediment Study Area, the first step
of the COPC and COC identification process was to compare the SLs presented in
Table 3-4 with maximum concentrations in T-117 Upland Study Area soil samples. All
available T-117 Upland Study Area soil data were evaluated in the screening process,
except data associated with soil that has been removed as part of the 1999 and 2006
TCRAs. The screening process included a general statistical review of detected soil
chemicals. Appendix E details and summarizes the T-117 Upland Study Area soil
screening process. 
For the second step, a 5% frequency of detection threshold was selected so that
infrequently detected chemicals in the dataset were excluded from further analysis,
thereby focusing further evaluation on the contaminants most likely to pose the
majority of site risk. This process is consistent with EPA risk assessment guidelines for
focusing risk assessments when large numbers of chemicals are present at a site (EPA
1989). 
Table 3-5 summarizes the soil COPCs and COCs for the T-117 Upland Study Area,
which include total PCBs, TPH, cPAH, dioxins/furans, and arsenic. Approximately
58% of the detected total PCB concentrations were greater than the SL, suggesting 
widespread PCB contamination in this area. The maximum detected total PCB
concentration was over 8,000 times the SL. The average PCB concentration was greater
than the SL by a factor of approximately 60. 
Table 3-5.  Soil COPCs and COCs in the T-117 Upland Study Area 
Designated as
COPC       a COC?        Rationale for COC Selection 
Arsenic           yes          one or more recent SL exceedances in soil 
Total PCBs        yes          one or more recent SL exceedances in soil 
TPH (diesel range)    yes          one or more recent SL exceedances in soil 
cPAH TEQ       yes        one or more recent SL exceedances in soil 
Dioxin/furan TEQ     yes          one or more recent SL exceedances in soil 
COC  contaminant of concern 
COPC  contaminant of potential concern 
cPAH  carcinogenic polycyclic aromatic hydrocarbons 
PCB  polychlorinated biphenyl 
SL  screening level 
TEQ  toxic equivalent 
TPH  total petroleum hydrocarbons 
More than 50% of the detected concentrations of cPAHs, dioxins and furans, and
arsenic exceeded the applicable SLs. Approximately 17% of detected TPH

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concentrations exceeded the applicable SL. These contaminants were thus retained as
COCs because they were detected in more than 5% of the samples and exceeded 
applicable SLs. 
3.3.2.2   Adjacent Streets and Residential Yards Study Area  Adjacent Streets 
Soil investigations conducted in the Adjacent Streets since 2005 were described in
Section 2.3.3. All available soil data, including both discrete samples (surface samples
and borings) in streets and road shoulders and multi-incrementMIS samples collected
along road shoulders in 2009, were included in the evaluation. Data were not included
for catch basin solids9 or for samples collected from areas removed during
independent cleanup actions or from areas where more recent MIS was conducted. 
Table 3-6 summarizes the soil COPCs and COCs designations for the Adjacent Streets,. 
COPCs which include total PCBs, TPH, cPAH, dioxins and furans, and arsenic.arsenic, 
total PCBs, TPH, cPAHs, and dioxins and furans. Approximately 30% (51% for
Adjacent Streets and 14% for Residential Yards) of the detected total PCB
concentrations were greater than the SL, suggesting widespread PCB contamination in
this area. The maximum detected total PCB concentration was over 960 times the SL.
The average PCB concentration was greater than the SL by a factor of
approximately 14. PCBs were thus retained as COCs because they were detected in
more than 5% of the samples and exceeded applicable SLs. 
Table 3-6.  Soil COPCs and COCs for Adjacent Streets 
COPC     Designated as a COC?          Rationale for COC Selection 
Total PCBs      yes                 upland source, SL exceedances 
yes, in locations where
Dioxin/furan TEQ  PCB concentrations      potential upland source, SL exceedances 
a
exceeded the PCB RvAL
administrative decision by EPA based on lack of clear evidence
Arsenic         no                  that T-117 Upland Study Area was significant source of COPC
to Adjacent Streets 
administrative decision by EPA based on lack of clear evidence
TPH         no               that T-117 Upland Study Area was significant source of COPC
to Adjacent Streets 
administrative decision by EPA based on lack of clear evidence
cPAH TEQ     no              that T-117 Upland Study Area was significant source of COPC
to Adjacent Streets 
a
Per EPA directive. 
COC  contaminant of concern                   SL  screening level 
COPC  contaminant of potential concern             T-117  Terminal 117 

9 Samples of catch basin solids were not considered to be soils for this streamlined risk assessment and
were not screened. Catch basin data were presented in Section 2 and are discussed in Section 5 with
respect to sediment recontamination potential. 
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cPAH  carcinogenic polycyclic aromatic hydrocarbons     TEQ  toxic equivalent 
EPA  US Environmental Protection Agency           TPH  total petroleum hydrocarbons 
PCB  polychlorinated biphenyl 
Approximately 75% of dioxins and furans exceeded the applicable SLs (70% for
Adjacent Streets and 79% for Residential Yards). Dioxins and furans were thus
retained as COCs because they were detected in more than 5% of the samples and
exceeded applicable SLs. However, they were only designated as COCs in areas where
they were co-located with total PCB concentrations above the selected PCB RvAL, per 
administrative direction by EPA (2009a). This decision was based on an assumption
that a minor portion of the dioxins and furans in the Adjacent Streets and Residential
Yards Study Area may be associated with PCBs from asphalt manufacturing facility
operations. 
In Adjacent Streets, approximately 83% of cPAH, 14% of TPH, and 100% of arsenic
detected values exceeded the applicable SLs. However these were not designated as
COCs for the Adjacent Streets and Residential Yards Study Area, per administrative
direction by EPA (2009a). EPA's decision was based on a lack of clear evidence that the
T-117 Upland Study Area was a significant source of these contaminants to the
Adjacent Streets. Although TPH and cPAH are expected to be associated with PCB-
containing oil, they are also common urban contaminants (e.g., associated with asphalt
paving). The limited arsenic concentration data available for the Adjacent Streets were 
within the range of background concentrations (Ecology 1994c) or were collected from 
areas identified for soil removal. 
Based on the forensic work completed by the Dioxin Technical Workgroup and
their 2008 and 2009 findings (Appendix M), EPA made the determination that
the former asphalt manufacturing facility operations are likely not the source of
the majority of the dioxins and furans detected in the Adjacent Streets and
Yards Study Area, and that the source of the dioxins and furans is as yet
undetermined. However, based on an assumption that a minor portion of the
dioxins and furans in the Adjacent Streets and Residential Yards Study Area
may be associated with PCBs from asphalt manufacturing facility operations,
EPA directed dioxins and furans be designated as COCs where they are colocated
with total PCBs above the action level in the Adjacent Streets and
Residential Yards Study Area. 
TPH, cPAHs, and Arsenic -TPH, cPAHs, and arsenic were not designated as
COCs for the Adjacent Streets and Residential Yards Study Area, per
administrative direction by EPA (2009a). EPA's decision was based on a lack of
clear evidence the T-117 Upland Study Area was a significant source of these
contaminants to the Adjacent Streets. While TPH and cPAH are expected to be
associated with PCB-containing oil, they are also common urban contaminants 
(e.g., associated with asphalt paving). The limited arsenic concentration data
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available for the Adjacent Streets were within the range of background
concentrations (Ecology 1994c) or were collected in areas identified for soil
removal. 
3.3.2.3   Adjacent Streets and Residential Yards Study Area  Residential Yards 
Following removal actions in 2004 and 2005, additional soil sampling was conducted 
in yards within the Adjacent Streets and Residential Yards Study Area in 2008 and
2009. Samples were analyzed for total PCBs and dioxins and furans (Ecology analyzed
splits of a subset of the 2009 samples for dioxins and furans). Both total PCBs and
dioxins and furans were selected as COPCs and COCs in this area (Table 3-7). The
detailed screening results are provided in Appendix E. 
Table 3-7.  Soil COPCs and COCs for Residential Yards 
Designated
COPC       as a COC?        Rationale for COC Selection 
Total PCBs          yes         upland source, SL exceedances 
Dioxin/furan TEQ      yes         upland source, SL exceedances 
COC  contaminant of concern 
COPC  contaminant of potential concern 
PCB  polychlorinated biphenyl 
SL  screening level 
TEQ  toxic equivalent 
TPH  total petroleum hydrocarbons 
As discussed in the previous section, EPA directed that dioxins and furans be 
designated as COCs where they are co-located with total PCB concentrations above 
the action level in the Adjacent Streets and Residential Yards Study Area (see
Section 4.3.32.2). 
3.3.3  Groundwater 
As noted in the introduction to Section 3, groundwater was not explicitly addressed in
the streamlined risk assessment. However, because protecting groundwater quality is
an important goal of the NTCRA, technical analyses were conducted to address
groundwater. Two of the analyses presented in Appendix B that pertain to
groundwater potability and the identification of COCs for groundwater are
summarized briefly below. 
3.3.3.1   Groundwater potability 
The potential for groundwater to be used as a drinking water source is important for
the evaluation of site-specific potential groundwater exposure pathways. A full
potability evaluation that details the regulatory basis for a non-potable designation for
groundwater in the vicinity of the T-117 Upland Study Area is provided in
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Appendix B. The area suggested for application of the non-potability designation is
shown on Map 3-1. This area includes the T-117 Uplands Study Area and portions of
the Adjacent Streets Study area near Basin Oil. Groundwater beneath other areas of
the Adjacent Streets and Residential Yards Study Area was assumed to be potable. The
non-potable designation for groundwater is reflected by the absence of the direct
contact with groundwater exposure pathway in Section 3.2.2. 
EPA's policy is to defer to a "State's determination of current and future groundwater
uses" provided that the state's program is recognized in the Comprehensive State
Ground Water Protection Program (CSGWPP) (EPA 2009d). The State of Washington's
potability determination under MTCA is recognized by the CSGWPP; therefore,
MTCA is the guiding regulation for this potability determination. 
Based on MTCA, groundwater in the vicinity of the T-117 Upland Study Area is not
potable as summarized below: 
EPA's policy is to defer to a "State's determination of current and future
groundwater uses" provided that the state's program is recognized in the
Comprehensive State Ground Water Protection Program (CSGWPP) (EPA
2009d). The State of Washington's potability determination under MTCA is
recognized by the CSGWPP; therefore, MTCA is the guiding regulation for this
potability determination. 
Based on MTCA, groundwater in the vicinity of the T-117 Upland Study Area is
not potable as summarized below: 
Groundwater in the vicinity of the T-117 Upland Study Area does not flow into
a source of drinking water. Groundwater flows directly into the adjacent
portion of the LDW, which has been deemed by the State of Washington as
being unsuitable for domestic use. 
Groundwater in the vicinity of the T-117 Upland Study Area could not become
a source of drinking water and does not flow into a water body that could
become a source of drinking water. Groundwater exceeds the state standard for
specific conductance because of its location along the LDW and the upwelling
of saline deep groundwater along a localized bedrock outcropping. As stated
above, the LDW, as determined by the State of Washington, is not suitable for
domestic use. 
In addition to the MTCA non-potability determination, local codes prohibit the
construction of drinking water wells in the vicinity of the T-117 EAA: 
Based on the King County Board of Health (KCBOH) regulations and King
County Code sections cited below, a drinking water well would be prohibited
at the site. 

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KCBOH Code  12.32.010.D requires that lots created by subdivision, short
subdivision, re-zone, or lot line adjustment that were created after 1972 and that 
are less than 5 acres must be connected to a public water supply. 
KCBOH Code  12.32.010.A requires that property owners undertaking "new
development" must connect to available public water supply. "Development"
is defined broadly to include "land utilization" and according to County staff
would itself include any proposal to install a groundwater extraction well,
which effectively prohibits installation of such a well. 
King County Code  13.24.140 (King County Water and Sewer Comprehensive
Plan contained in Title 13 of the code) applies to properties outside the City and
requires all new development within the Urban Growth Area to be served by
the appropriate existing Group A water supplier, unless service cannot be
timely and reasonably provided. Therefore, because all of the properties in the
vicinity of the T-117 EAA are served by a public water supply, any new
development at or near the T-117 EAA must also be connected to this supply. 
KCBOH Code  12.24.010A states that the drinking water supply must come
from the "highest quality source feasible." The highest quality source available
at the T-117 EAA is the SPU water supply from the Cedar River Watershed. 
KCBOH Code  12.24.010(C) specifies the minimum setbacks for drinking water
wells, which are 100 ft from surface water, roads, utilities, and buildings. The
T--117 Upland Study Area is a narrow piece of land (approximately 200 feet
wide) situated between Dallas Avenue S and the LDW. 
These KCBOH code sections reaffirm state regulations found at WAC 246-290-130(1)
and WAC 246-290-135(2)(b). 
3.3.3.2   Groundwater COCs 
Similar to the process discussed above for sediment and soil COCs, SLs were
developed for groundwater. With the exception of TPH, SLs were based on ambient
water quality criteria to protect surface water beneficial uses. The TPH SL was based
on MTCA Method A. These SLs are re-evaluated in Section 4 as part of the RvAL
development to ensure the concentrations are also sufficiently low to prevent
sediment recontamination. 
There are no drinking water wells in the T-117 EAA, and as indicated in the previous
section, future construction of drinking water wells is prohibited within the T-117 
EAA Upland and Adjacent Streets and Residential Yards Study Areas. In addition, as
discussed in Section 2.3.4.2 and Appendix B.4, the presence of groundwater
contamination beneath the Adjacent Streets Study Area due to former T-117
operations is unlikely. As a result, groundwater COCs and RvALs have not been
developed for the Adjacent Streets and Residential Yards Study Area. 
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Table 3-8B-1, of Appendix B, includes a summary of the selected groundwater SLs.
Screening was conducted using groundwater chemistry results from monitoring wells
sampled since 2003. The groundwater COPCs included arsenic, copper, silver, total
PCBs, TPH, cPAH TEQ, and BEHP (Table 3-89). All but copper COPCs were
designated as COCs. Under WAC 173-340-730(5)(c), copper was not retained as
groundwater COC because concentrations in the vicinity of the T-117 Upland Study
Area are not significantly different than the site specific background populations.
Copper concentrations in upgradient wells (wells MW-01, and MW-09 through MW-
-13) were compared to concentrations in T-117 Upland Study Area wells (wells MW-02
through MW-08R). Copper concentrations between these two data sets are not
significantly different, and therefore, concentrations at the T-117 Upland Study Area
wells are considered to be background values (Appendix B). 













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Table 3-8.  Groundwater screening levels 
Concentration (g/L) 
a
Aquatic Life Criteria
Washington State WQC           National AWQC                 Surface Water Criteria 
Human Health
Freshwater        Marine      Freshwater     Marine                 MTCA Method B 
Criteria for
All Detected                                                         Consumption              Non-     SL Used
b       c        b       c      d      e      d      e            f
Chemicals      Chronic  Acute  Chronic  Acute  CCC  CMC  CCC  CMC  of Organisms  Carcinogen  Carcinogen  for EE/CA 
Metals and Trace Elements 
g, h
Arsenic               190     360      36      69     150    340    36     69      0.14        0.098        18        0.14 
Cadmium           1.0     3.7     9.3     42    0.25   2.0    8.8    40      nc        nc       20      0.25 
Chromium (hexavalent)     10      15      50     1,100    11    16    50   1,100      nc         nc        486       10 
Chromium (trivalent)      180     550      nc      nc     74    570                                                  k
nc     nc        nc          nc       243,056      10 
Copper              11      17      3.1     4.8     9     13    3.1    4.8       nc         nc       2,665      3.1 
Nickel                 160     1,400     8.2      74     52    470    8.2     74       4,600         nc        1,103       8.2 
Silver                   nc       3.4       nc       1.9     nc     3.2     nc     1.9        nc           nc        25,926       1.9 
Zinc                  100      110      81       90     120    120    81     90      26,000        nc        16,548       81 
TPH 
j
Total TPH             nc      nc      nc      nc     nc    nc     nc     nc       nc         nc        nc       500 
PCBs 
g
Total PCBs           0.014     2      0.03     10    0.014   nc    0.03    nc     0.000064     0.00011      nc      0.000064 
PAHs 
1-Methylnaphthalene      nc      nc      nc      nc     nc    nc     nc     nc       nc         nc        nc        nc 
i
Acenaphthene         nc      nc      nc      nc     nc    nc    nc    nc      990        nc       643      990 
l 
Anthracene            nc      nc      nc      nc     nc    nc     nc    nc      40,000        nc       25,926     40,000
g
Benzo(a)anthracene      nc      nc      nc      nc     nc    nc    nc    nc      0.018      0.030       nc       0.018 
g
Benzo(a)pyrene         nc      nc      nc      nc     nc    nc    nc    nc      0.018      0.030       nc       0.018 

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Concentration (g/L) 
a
Aquatic Life Criteria
Washington State WQC           National AWQC                 Surface Water Criteria 
Human Health
Freshwater        Marine      Freshwater     Marine                 MTCA Method B 
Criteria for
All Detected                                                         Consumption              Non-     SL Used
b       c        b       c      d      e      d      e            f
Chemicals      Chronic  Acute  Chronic  Acute  CCC  CMC  CCC  CMC  of Organisms  Carcinogen  Carcinogen  for EE/CA 
g
Benzo(b)fluoranthene      nc      nc      nc      nc     nc    nc     nc     nc      0.018       0.030       nc       0.018 
g
Benzo(k)fluoranthene      nc      nc      nc      nc     nc     nc     nc     nc      0.018       0.030       nc       0.018 
g
Chrysene             nc      nc      nc      nc     nc    nc    nc    nc      0.018      0.030       nc      0.018 
g
Dibenzo(a,h)anthracene    nc      nc      nc      nc     nc    nc     nc     nc      0.018       0.030       nc       0.018 
i
Fluoranthene           nc      nc      nc      nc     nc    nc     nc     nc       140         nc        90       140 
i
Fluorene              nc      nc      nc      nc     nc     nc     nc     nc      5,300        nc       3,457      5,300 
g
Indeno(1,2,3-cd)pyrene     nc      nc      nc      nc     nc     nc     nc     nc      0.018       0.030        nc       0.018 
Naphthalene           nc      nc      nc      nc     nc    nc    nc    nc       nc         nc       4,938      4,938 
Phenanthrene          nc      nc      nc      nc     nc    nc    nc    nc       nc         nc        nc       nc 
l 
Pyrene               nc      nc      nc      nc     nc    nc     nc    nc      4,000        nc       2,593      4,000
g
cPAH TEQ           nc     nc     nc     nc    nc    nc    nc    nc     0.018      0.030      nc      0.018 
BTEX 
Xylene               nc      nc      nc      nc     nc    nc     nc     nc       nc         nc        nc        nc 
Phthalates 
g
BEHP             nc     nc     nc     nc    nc    nc    nc    nc      2.2       3.6      399      2.2 
SVOCs 
l 
Phenol               nc      nc      nc      nc     nc    nc     nc    nc     1,700,000       nc      1,111,111   1,700,000
VOCs 
1,1,1-Trichloroethane      nc      nc       nc      nc     nc     nc     nc     nc        nc          nc       416,667    416,667 
Acetone              nc      nc      nc      nc     nc    nc    nc    nc       nc         nc        nc        nc 
Chlorobenzene         nc      nc      nc      nc     nc    nc    nc    nc      1,600        nc       5,034      1,600 

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Concentration (g/L) 
a
Aquatic Life Criteria
Washington State WQC           National AWQC                 Surface Water Criteria 
Human Health
Freshwater        Marine      Freshwater     Marine                 MTCA Method B 
Criteria for
All Detected                                                         Consumption              Non-     SL Used
b       c        b       c      d      e      d      e            f
Chemicals      Chronic  Acute  Chronic  Acute  CCC  CMC  CCC  CMC  of Organisms  Carcinogen  Carcinogen  for EE/CA 
cis-1,2-Dichloroethene      nc      nc      nc      nc     nc     nc     nc     nc        nc          nc         nc        nc 
g                                   l 
Tetrachloroethene        nc      nc      nc      nc     nc     nc     nc     nc       3.3        0.39       836       3.3
g                                   l 
Trichloroethene          nc      nc      nc      nc     nc     nc     nc     nc       30         6.7        71        30
Dioxin/Furans 
-9 g                                          -9 g
2,3,7,8-TCDD TEQ       nc      nc      nc      nc     nc    nc    nc    nc    5.0 x 10       nc        nc     5.0 x 10
a
Aquatic life criteria are based on dissolved concentrations for metals (except mercury) and total concentrations for mercury and organic compounds. 
b
Chronic criteria are 4-day average concentrations not to be exceeded more than once every 3 years on the average, with the exception of pesticide and PCB
concentrations, which are 24-hr average concentrations not to be exceeded at any time. 
c
Acute criteria are 1-hr average concentrations not to be exceeded more than once every 3 years on average, with the exception of silver and pesticide
concentrations, which are instantaneous concentrations not to be exceeded at any time, or the PCB concentration, which is a 24-hr average concentration not
to be exceeded at any time. 
d
The CCC is defined as an estimate of the highest concentration of a chemical in surface water to which an aquatic community can be exposed indefinitely
without resulting in an unacceptable effect. 
e
The CMC is defined as an estimate of the highest concentration of a chemical in surface water to which an aquatic community can be exposed briefly without
resulting in an unacceptable effect. 
f
Washington State and national water quality criteria for the protection of human health are the same. Human health criteria are based on dissolved
concentrations for all chemicals for marine water for ingestion of only organisms only (not water). 
g                      -6
Criteria are based on 10  excess cancer risk for carcinogenic chemicals. 
h
WQC represents the inorganic fraction of arsenic. 
I
The criteria for pentachlorophenol are pH-dependent; a pH of 7 was assumed. 
j
Criteria for MTCA Method A for groundwater. 
k
Hexavalent chromium criterion was used because chromium speciation was not performed. 
l
SL was selected based on MTCA Method B CUL site-specific calculated value is higher than MTCA Method B default value. 
AWQC  ambient water quality criteria                EE/CA  engineering evaluation/cost analysis     SVOC  semivolatile organic compound 
BEHP  bis(2-ethylhexyl) phthalate                  MTCA  Model Toxics Control Act             TEQ  toxic equivalent 

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BTEX  benzene, toluene, ethylbenzene, and xylene       nc  no criteria                         TCDD  tetrachlorodibenzo-p-dioxin 
CCC  criteria continuous concentration               PAH  polycyclic aromatic hydrocarbon          TPH  total petroleum hydrocarbons 
CMC  criteria maximum concentration               PCB  polychlorinated biphenyl              VOC  volatile organic compound 
cPAH  carcinogenic polycyclic aromatic hydrocarbon      SL  screening level                     WQC  water quality criteria 
CUL  cleanup level 
Bold identifies values calculated using a hardness value of 100 mg/L. In most cases, the Washington State WQC and national AWQC are the same. In cases
where they are different, the lower of the two values is used. 
Gray-shaded values were identified as SLs.













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The site-specific background groundwater dissolved copper concentration was 5 
g/L based on the 90th percentile. This concentration is lower than, but consistent, 
with, the background groundwater dissolved copper concentration (8 g/L, as
established by EPA) calculated for the Boeing Plant 2 site (Environmental Partners
2006). 
Greater than 50% of the detected sample concentrations exceed the SLs for silver, total
PCBs, TPH, and cPAH TEQ. Approximately 43% of the detected concentrations exceed
the BEHP screening values. Approximately 19% of the detected sample concentrations
exceed the SLs for arsenic. However, 43% of the concentrations reported below the
laboratory reporting limits for arsenic also exceed the SL. All of these compounds have
a detected frequency greater than 5%. 
Table 3-98. Groundwater COPCs and COCs 
Designated as
COPC      a COC?          Rationale for COC Selection 
Arsenic              yes      one or more recent SL exceedance in groundwater 
concentrations less than or equal to upgradient
Copper             no 
background concentration 
Silver                 yes       one or more recent SL exceedance in groundwater 
Total PCBs          yes      one or more recent SL exceedance in groundwater 
TPH             yes     one or more recent SL exceedance in groundwater 
cPAH TEQ         yes     one or more recent SL exceedance in groundwater 
BEHP           yes     one or more recent SL exceedance in groundwater 
BEHP  bis(2-ethylhexyl) phthalate 
COC  contaminant of concern 
COPC  contaminant of potential concern 
cPAH  carcinogenic polycyclic aromatic hydrocarbon 
PCB  polychlorinated biphenyl 
SL  screening level 
TPH  total petroleum hydrocarbons 
3.3.4  RAA contaminants 
According to the SOW (EPA 2007c), in addition to COCs selected for each of the T-117
EAA Study Areas discussed in Section 3.3.2 and summarized in Section 3.3.3,
contaminants found on the Basin Oil property or Marina that pose a potential for
post--NTCRA sediment recontamination must be identified. This section presents the
results of this identification analysis. 
Basin Oil groundwater and soil data (Ecology 2009b) were screened using the SLs
developed for the T-117 EAA in Appendix B and Section 3.3.2, respectively. 
Concentrations of arsenic, total PCBs, BEHP, copper, TPH, nickel, cPAHs,
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ethylbenzene, xylenes, and carbazole were greater than SLs in soil and groundwater 
upgradient of the T-117 Upland Study Area. Except for nickel, xylenes, carbazole, and
ethylbenzene, these contaminants were already included as COCs for the T-117 EAA. 
Specific results were as follows: 
Monitoring wells downgradient of the Basin Oil property, and upgradient of 
the T-117 Upland Study Area, had SL exceedances for arsenic (MW-01 and
MW-11), copper (MW-01 and MW-10), total PCBs (MW-01), BEHP (MW-01,
MW-9, MW-10, and MW-11), and TPH (MW-10). 
Monitoring wells upgradient of Basin Oil property had arsenic concentrations
greater than the SL (MW-12, MW-13). 
Concentrations of arsenic, TPH (lube oil and gas), cPAHs, total PCBs,
ethylbenzene, and xylenes in surface soils were greater than SLs. Arsenic,
cPAH, and carbazole concentrations in surface soil samples from upgradient
monitoring wells were greater than their SLs. 
The total PCB concentration in one 12.5-ft-deep soil sample (BSB-3) was greater
than the SL. 
With respect to the Marina, as discussed in Section 2.4.2, metals, total PCBs (quantified
as Aroclor 1254), pesticides, PAHs, TPH, and VOCs were detected above SLs in soil
samples. Of the contaminants with concentrations greater than SLs in soil, only total
PCBs (quantified as Aroclor 1260) had concentrations greater than the SQS in Marina
sediment. 
The chemicals identified in these RAAs at concentrations above SLs will be
incorporated into the analysis presented in Section 5.2 of the recontamination potential
from these two areas (Basin Oil property and the Marina). 
3.3.5  Summary of streamlined risk assessment 
This section provides an overview of the pathways, receptors, and COCs for each of
the T-117 EAA Study Areas discussed in this section. A summary of the exposure
pathways and receptors identified in the streamlined risk assessment is presented in
Table 3-910. A summary of the COCs identified in each T-117 study area is presented
in Table 3-1011. Total PCBs and dioxins and furans were identified as COCs in all
study areas. RvALs for COCs identified for sediment and soil are presented in
Section 4. 



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Table 3-910. Summary of exposure pathways and receptors identified in the
streamlined risk assessment 
Sediment             Soil            Groundwater 
T-117     T-117
Exposure              Sediment   Upland   Adjacent Residential  T-117 Upland
Pathways      Receptors    Study Area  Study Area   Streets    Yards     Study Area 
Aquatic Organisms 
benthic
X                                    X 
invertebrates 
Ingestion, dermal   mammals          X 
contact 
fish                 X                                              X 
birds              X 
mammals        - 
Inhalation 
birds               - 
People 
kayakers          X                                    X 
fishermen          X                                     X 
Ingestion, dermal   clammers          X                                      X 
contact          beachgoers         X                                       X 
residents                               X         X 
workers           X         X        X        X          X 
kayakers 
fishermen 
clammers 
Inhalation 
beachgoers 
residents                     X         X         X 
workers                    X        X        X 
People and Animals 
fish                 X 
Seafood       birds           X 
cConsumption     mammals         X 
people            X 
T-117  Terminal 117 




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Table 3-1011.    Summary of COCs identified in the streamlined risk assessment 
Sediment               Soil              Groundwater 
T-117      T-117
Sediment    Upland    Adjacent   Residential  T-117 Upland
COCs         Study Area   Study Area    Streets     Yards    Study Area 
Metals 
Arsenic                     X          X                                X 
Copper                                                         X 
Silver                                                                          X 
PAHs 
2-Methylnaphthalene            X 
Acenaphthene               X 
Anthracene                 X 
Benzo(a)anthracene            X 
Benzo(a)pyrene               X 
Benzo(g,h,i)perylene             X 
Total benzofluoranthenes          X 
cPAH TEQ               X        X                         X 
Chrysene                  X 
Dibenzo(a,h)anthracene          X 
Dibenzofuran                 X 
Fluoranthene                 X 
Fluorene                    X 
Indeno(1,2,3-cd)pyrene           X 
Phenanthrene               X 
Total HPAH (calc'd)             X 
Total LPAH (calc'd)              X 
TPH 
Diesel- and lube oil-range
X                              X 
hydrocarbons 
Other SVOCs 
BEHP                                                 X 
Phenol                    X 
PCBs 
Total PCBs                  X          X          X          X          X 
Dioxins and Furans 
Dioxin/furan TEQ              X          X          X          X 

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BEHP  bis(2-ethylhexyl) phthalate                       PAH  polycyclic aromatic hydrocarbon 
COC  contaminant of concern                        PCB  polychlorinated biphenyl 
cPAH  carcinogenic polycyclic aromatic hydrocarbon           SVOC  semivolatile organic compound 
HPAH  high-molecular-weight polycyclic aromatic hydrocarbon     T-117  Terminal 117 
LPAH  low-molecular-weight polycyclic aromatic hydrocarbon     TEQ  toxic equivalent 
OC  organic carbon                               TPH  total petroleum hydrocarbons 




















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4    Identification of Removal Action Scope, Goals, and Objectives 
This section presents the NTCRA scope, goals, and objectives for the T-117 EAA in
accordance with EPA's Guidance on Conducting Non-Time-Critical Removal Actions Under
CERCLA (EPA 1993) and discusses the development of RvALs for the T-117 EAA. This
section includes: 
A description of specific scope, goals, and objectives for the T-117 EAA 
Regulatory requirements and guidance, including applicable or relevant and
appropriate requirements (ARARs) 
Definition Development of of RvALs, which are defined as site- specific
removal action levels 
Presentation of the numerical RvALs for each medium, including sediment,
soil, and groundwater, which wereRvALs selected to meet these goals,
objectives, and ARARs 
Final removal boundaries for each study area, based on the RvALs for each
mediumBoundaries for the removal actions in the study areas 
4.1   NTCRA SCOPE, GOALS, AND OBJECTIVES 
The scope of this NTCRA includes the removal (or removal and capping) of sediment
and the removal of soil to meet RvALs at the appropriate points of compliance. This
NTCRA is designed to address sediment COCs within the T-117 Sediment Study Area
and soil COCs in the T-117 Upland Study Area and Adjacent Streets and Residential
Yards Study Area. 
The goal of the NTCRA for the T-117 EAA is to reduce the current and future exposure
of ecological and human receptors to COCs. Reasonably anticipated future land uses
include various non-industrial uses such as river and/or shoreline aquatic habitat and 
upland habitat, public access and recreation, residential and commercial uses, as well
as industrial uses. Consistent with MTCA, unrestricted land use will be evaluated.
These potential future site uses were considered in the selection of RvALs. 
In summary, the removal action objectives (RAOs) for the T-117 EAA includeare: 
Sediment 
Human Health  seafood consumption. Reduce human health risks associated
with the consumption of resident LDW fish and shellfish by to reducing
sediment concentrations of COCs to protective levels. 
Human Health  direct contact. Reduce human health risks associated with
exposure to COCs through direct contact with sediments and incidental
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sediment ingestion by reducing sediment concentrations of COCs to protective
levels. 
Ecological Health  benthic. Reduce toxicity to benthic invertebrates by
reducing sediment concentrations of COCs to comply with SMS. 
Ecological Health  seafood consumption. Reduce risks to crabs, fish, birds
and mammals from exposure to COCs by reducing concentrations of COCs in 
sediment to protective levels. 
Soil 
Sediment Protection. Reduce PCB concentrations in upland soils to ensure
protection of sediments. 
Sediment removal and/or capping to be protective of: 
Biological resources 
Human health 
Direct contact  tribal clamming, netfishing, beach play 
Indirect contact  fish consumption 
Soil removal to be protective of: 
Human health  direct contact, incidental ingestion 
Ecological health 
Sediment quality 
Groundwater quality 
Because of the residential land use within the T-117 EAEA, EPA has established that
the RAOs for the T-117 EAA must consider RvALs associated with MTCA-defined
unrestricted land use in the upland portions of the site (Appendix A). 
Groundwater at the T-117 EAA has been evaluated and groundwater action levels 
have been developed to ensure that groundwater quality at the point of discharge to
LDW surface water and sediment will not result in the recontamination of sediment
(Section 5.2) or in the contamination of water at levels that could pose risks through
seafood ingestion (Appendix B). 
Specific removal actions for soil and sediment must meet the RAOs if they are to be
considered and selected for implementation. The development and selection of
specific removal actions must also consider reasonably anticipated future land uses.
Selected RvALs must be sufficient to allow for the entire range of these potential uses.
In addition, any future development projects must comply with land-use regulations
(development, environmental, zoning) and the associated permitting procedures and
requirements. 
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Selected RvALs for the T-117 Upland Study Area are also expected to be sufficiently
protective to allow for possible future habitat development, as well as other final site
uses including commercial site uses (e.g., restroom facilities). The Port is examining
habitat restoration opportunities within all or a portion of the T-117 Sediment Study
Area and the T-117 Upland Study Area. As part of this potential site use, locations
within the T-117 Upland Study Area may be converted to aquatic habitat; portions of
the upland soil may become located within or beneath a portion of the intertidal
sediment. In addition, any sediment removal action that includes excavation or
dredging will expose new sediments within the aquatic area. To address ensure the
protectiveness of sediment, these potential future configurations, the specific cleanup
objective of any T-117 removal action that creates generates new sediment surfaces 
will be to achieve contaminant concentrations at or below the sediment RvALs to the
prescribed depth of compliance. Furthermore, an additional cover or cap (e.g., clean,
imported backfill material) may be placed over sediment areas at certain locations to
meet the RvALs to the prescribed depth and/or to ensure the permanence of the
removal action. If the removal action can seamlessly transition to habitat restoration,
upland areas that would be converted into intertidal areas would be completed in
accordance with the sediment NTCRA (i.e., meet the sediment RAOs). 
Section 7 of this EE/CA describes removal action alternatives that are compatible with
habitat restoration. It is expected that the existing aquatic sediment portion of the site
will remain aquatic and will be subject to the RvALs defined for the Sediment Study
Area. The future land use for the Adjacent Streets and Residential Yards Study Area is
expected to retain a combination of residential and commercial uses. Current City
zone designations for this study area include Commercial 1 (C1) and Neighborhood
Commercial 3 (NC3) (City of Seattle 2007a). The City's Comprehensive Plan future
land use map shows the Adjacent Streets and Residential Yards Study Area as
commercial/mixed use and industrial (City of Seattle 2007b). Street improvements
conducted in conjunction with this NTCRA will be consistent with current codes for
street paving width and curb, gutter, and sidewalk installation. 
4.2   REGULATORY REQUIREMENTS AND GUIDANCE 
Potential ARARs and guidance for removal activities within the LDW Superfund Site
were identified in the LDW Phase 1 RI (Windward 2003a).10 Most of these regulations
are relevant to the scope, goals, objectives, and development of RvALs for the NTCRA
described in this EE/CA, as well as the detailed evaluation of removal action 
alternatives (Section 8.2.3 and Table 8-1) and eventual NTCRA implementation. A 
listing and description these requirements and guidance, including CERCLA, TSCA,
MTCA, SMS, and other requirements to be considered for the T-117 NTCRA, are 
provided in Appendix G. 
10 This information is being updated as part of the LDW FS. 
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Of particular importance to the cleanup and disposal of PCB contaminated waste at
the T-117 EAA are the substantive requirements under TSCA (40 CFR 761.61) as an
ARAR requirements under 40CFR761.61. Because of the complexity of the site, the
removal of PCB contaminated soil and sediment is best suited for a risk-based disposal
(40CFR761.61(c)), which is attained through application by providing the information
outlined in 40CFR761.61(a)(3). The application informationprocess is intended to
demonstrate that the removal action will not pose an unreasonable risk to human
health or the environment. In order to meet this substantive requirement, tThis
application will be prepared during the NTCRA design phase. Appendix H describes
in further detail the information required to be provided for the risk-based disposal
application. 
4.3   REMOVAL ACTION LEVELS 
This section discusses the derivation of RvALs for the soil and sediment COCs
identified in Section 3 and also considers practical quantitation limits (PQLs),
background concentrations, and the total cancer risk per WAC 173-340-740(5)(a). 
The development of sediment RvALs is discussed in Section 4.3.1, Section 4.3.2
discusses the development of the soil RvALs, Section 4.3.3 discusses the development
of groundwater RvALs, and Section 4.3.4 provides a summary of the selected RvALs
for the T-117 EAA. The RvALs are used in Section 4.4 to develop the sediment and soil
removal boundaries. A detailed discussion of the development of groundwater RvALs
is presented in Appendix B. 
MTCA CULs are used as one basis for deriving RvALs, as MTCA is an ARAR for this
site. Under MTCA, CULs for individual carcinogenic COCs for which other ARARs do
not apply are typically calculated based on a risk level of 1  10-6. The total cancer risk
allowed for multiple chemicals under MTCA is 1  10-5 (WAC 173-340-740(5)(a)). 
EPA's range is 10-4 to 10-6. Both MTCA and CERCLA equations and assumptions were
used to calculate the total risks associated with the selected RvALs for soil. 
As noted above, the T-117 Sediment Study Area is located within the LDW and 
sediment remedial action levels have not been finalized under the LDW-wide
CERCLA and MTCA remedial program. Consequently, T-117 sediment action levels 
cannot be set as final until the LDW ROD is completed. EPA has therefore specified 
that the T-117 NTCRA use a site-specific RvALs. Sediment RvALs for the T-117
Sediment Study Area are based on SMS (except for arsenic, cPAHs, and dioxins and
furans which are discussed in more detail in Section 4.3.1 below). 
Similarly, EPA has also specified that the T-117 NTCRA use RvALs for soil in the
Upland Study Area and the Adjacent Streets and Yards Study Area that have been
developed based on the methodology set forth under MTCA for calculating soil CULs
and defining appropriate points of compliance. Soil RvALs are thus protective of
human health for exposure pathways present in the soil within the Adjacent Streets
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and Residential Yards Study Areas. Soil RvALs must also be protective of sediment
and aquatic life where excavation occurs and these soils are converted from uplands to
intertidal sediment 
4.3.1  Development of sediment removal action levels 
This section describes the development of sediment RvALs for the T-117 Sediment
Study Area. As presented in Table 3-910, the COCs for the T-117 Sediment Study Area
are PAHs, total PCBs, phenol, dioxins and furans, and arsenic. RvALs for phenol
(0.42 mg/kg) and individual PAHs were set equal to the SQS, consistent with the
corresponding lowest SLs used for these contaminants (Table 3-2). 
The SL for cPAHs was based on an EPA preliminary remediation goal (PRG) soil
value protective of residential land use (0.015 mg/kg). cPAHs were also identified as a
risk driver in the LDW HHRA (Windward 2007b) for seafood consumption and the
direct sediment contact exposure pathways (i.e., beach play, netfishing, and
clamming). Risk-based threshold concentrations (RBTCs) calculated from the LDW
HHRA results were considered as RvALs for cPAHs because they are more relevant to
exposure to sediment. The three RBTCs for cPAHs that were calculated in the LDW RI
(Windward 2008), based on an assumed excess cancer risk of 1  10-6, were 0.09 mg/kg
(for beach play), 0.15 mg/kg (for clamming), and 0.38 mg/kg (for netfishing). The
lowest of these RBTCs (0.09 mg/kg) was selected as the RvAL for cPAHs in sediment 
at the T-117 EAA. An RBTC was not calculated for cPAHs for seafood consumption
because most of the risk was associated with the consumption of clams from
throughout the LDW, and the relationship between cPAHs in tissue and sediment was
highly uncertain (Windward 2008). 
For total PCBs, RBTCs were calculated in the LDW RI (Windward 2008) for seafood
consumption and the three direct sediment contact exposure scenarios. The RBTCs for
the direct-contact scenarios were higher than the SL of 12 mg/kg OC (i.e., the SQS
value); the RBTC for seafood consumption was lower than background concentrations
(Windward 2008). Ultimately, total PCB sediment action levels for the LDW RI/FS
may be influenced by background concentrations and other regulatory considerations.
At the present time, EPA and Ecology have not made a final determination of action
levels for the LDW project. Therefore, for the purposes of the T-117 EAA, the SQS
(12 mg/kg OC ) was selected as the sediment RvAL for total PCBs. Because this RvAL 
is lower than all of the LDW RBTCs for the direct- contact scenarios, it is considered to
be protective of human health under those scenarios. The RvAL is higher than the
RBTC for seafood consumption, so it is not fully protective of human health for the
seafood consumption pathway. Similarly, because the seafood consumption RBTC is
below multiple potential background PCB concentrations and action levels will not be 
below background concentrations (WAC 173-340-700), the ultimate action level for the
LDW project will be also be above the RBTC for seafood consumption. The removal of
PCB-contaminated sediment, with concentrations above the SQS from within the
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T-117 Sediment Study Area will reduce the site-wide PCB concentration and the risks
associated with seafood consumption in the LDW. 
The SL for dioxins and furans was based on an EPA PRG for residential land use
(4.5 ng/kg dioxin/furan TEQ). RBTCs were calculated in the LDW RI for the three
direct sediment contact exposure scenarios. Although it was recognized that seafood
consumption may also be an important exposure pathway for dioxins and furans,
RBTCs were not derived for dioxins and furans because tissue data were not available
at the time of the risk assessments (Windward 2008). The RBTCs for the three direct
sediment contact exposure scenarios ranged from 13 to 37 ng/kg for a target risk of
1  10-6; these RBTCs were higher than the SL. Because the sediment RBTCs were
based on sediment exposure scenarios, they are more relevant to the establishment of 
a sediment RvAL than the SL, which was derived for the direct contact residential soil
exposure. Accordingly, the lowest of the three RBTCs (13 ng/kg, based on a tribal
clamming scenario) was selected as the sediment RvAL for dioxins and furans.
Ultimately, background concentrations of dioxins and furans may influence the
derivation of an action level for the LDW RI/FS. Action levels determined for the
LDW will be tracked to ensure the NTCRA is consistent with those of the LDW. 
The SL for arsenic was also based on an EPA PRG soil value for residential land use
(0.39 mg/kg). Because arsenic was also a risk driver in the LDW HHRA, RBTCs were
calculated in the LDW RI (Windward 2008) for the three direct sediment contact
exposure scenarios discussed above.11 The RBTCs ranged from 1.3 to 3.7 mg/kg for a
target risk of 1  10-6; these RBTCs were higher than the SL but were all lower than
preliminary sediment background concentrations for arsenic that were reported in the
LDW RI (Windward 2008). The action level for the LDW RI/FS have has yet to be
determined, and but it will be influenced by background concentrations. The arsenic
RvAL to be used for the T-117 Sediment Study Area will also be influenced by 
background sediment concentrations when such a determination iscan be made infor 
the LDW RI/FS. Therefore, an RvAL for arsenic of 12 mg/kg is assumed for the 
purposes of this EE/CA, which is similar to the background concentrations being
considered for arsenic. This assumption will be reviewed during the design of the T--
117 NTCRA. 
Risk estimates were made for the proposed sediment RvALs for the purposes of
evaluating compliance with the MTCA requirements that cancer risks from individual
contaminants not exceed 1  10-6 and that cumulative cancer total risks for all
contaminants not exceed a excess cancer risk of 1  10-5 (Table 4-1). The cancer risk
associated with the risk-based RvAL for each of the four carcinogenic COCs was at or

11 An RBTC was not calculated for arsenic for seafood consumption because most of the risk was
associated with the consumption of clams from throughout the LDW, and the relationship between
arsenic in tissue and sediment was highly uncertain (Windward 2008). 
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below the threshold of 1  10-6. A background-based RvAL was also developed for
arsenic. The excess cancer risk for the background-based RvAL for arsenic was
4  10-6. TThe total cumulative risk from the carcinogenic COCs, regardless of whether
the risk-based or background-based RvAL for arsenic was used, was well below the
for the four carcinogenic COCs was 21  10-65, below the MTCA threshold. The sum of
the HQs for the seven COCs with non-carcinogenic endpoints was 0.04, well below the
MTCA threshold of 1. This evaluation indicates that the sediment RvALs are
sufficiently protective. 
Table 4-1.   T-117 Sediment Study Area total risks for sediment removal action
levels under the recreational scenariosediment removal action
levels 
RvAL 
(dwdry weight      Source of     Excess      Hazard
COC         equivalent, mg/kg)     RvAL     Cancer Risk   Quotient 
a 
Sediment  Recreational Scenario
b, c                                      -67
Arsenic (risk-based)              2.812           LDW RI      15  10          na 
ba                                      -6
Arsenic (background-based)         12           LDW RI       4  10         na 
b
2-Methylnaphthalene             0.59          SQS d        na         0.0005 
db
Acenaphthene                0.25          SQS        na        0.00007 
db
Anthracene                   3.4           SQS         na        0.00005 
ec                                                                         -6
cPAH TEQ               0.09        LDW RI     1  10       na 
db
Dibenzofuran                  0.23          SQS         na          na 
db
Fluoranthene                  2.5           SQS         na         0.0003 
db
Fluorene                     0.36           SQS         na         0.00004 
db 
Phenanthrene                 1.6           SQS         na          na 
Phenol                     0.42           SQS         na        0.000004 
dd
0.19  or            bd          -7
Total PCBs                               SQS       2  10        0.04 
(12 mg/kg -OC) 
-5          ce                               -7
Dioxin/furan TEQ           1.3  10 0.000013      LDW RI       5  10         na 
-6
Total (risk-based)                                        3  10         0.04 
-6
Total (background-based)                              62  10       0.04 
Note: a     Recreational scenario equivalent to beach play scenario used in the LDW HHRA (Windward 2007b). 
ba
The RBTCs for arsenic are less than preliminary background concentrations (Windward 2008). For the
purposes of this evaluation, a value of (12 mg/kg) was used for the RvAL, which is similar to the background
concentrations being considered in the LDW RI/FS for arsenic. 
b
For the purposes of risk estimation, the SQS value originally given in units of mg/kg OC was converted to a dry
weight concentration using the average TOC concentration in the T-117 Sediment Study Area (1.55%). 
ec
Other PAHs identified as sediment COCs are not explicitly evaluated for human health risk, including the
individual components of the cPAH TEQ sum [benzo(a)pyrene, benzo(b)fluoranthene, benzo(a)anthracene,
benzo(k)fluoranthene, indeno(1,2,3-cd)pyrene, dibenz(a,h)anthracene, and chrysene]; benzo(g,h,i)perylene, for
which human health toxicity benchmarks have not been established; and total LPAHs and HPAHs, which are 
not typically evaluated for human health risk. 

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d
If the SQS of 12 mg/kg OC is not used because the TOC in a sediment sample is either higher or lower than
0.5 to 3.5%, then a site-specific calculation, or "surrogate," can be applied, which results in a value of 0.19
mg/kg dw. 
ce
This RvAL is derived from an RBTC (equivalent to 1  10-6) for tribal clamming. The excess cancer risk
estimate given is for the beach play scenario, which has an RBTC approximately 2 times the RBTC for the
tribal clamming scenario. 
d
For the purposes of risk estimation, the SQS value originally given in units of mg/kg OC was converted to a dry
weight concentration using the average TOC concentration in the T-117 Sediment Study Area (1.55%). If the
SQS of 12 mg/kg OC is not used because the in a sediment sample is either higher or lower than 0.5 to 3.5%,
then a site specific calculation, or "surrogate" can be applied which results in a value of 0.19 mg/kg dw. 
COC  contaminant of concern                         PCB  polychlorinated biphenyl 
cPAH  carcinogenic polycyclic aromatic hydrocarbon            RBTC  risk-based threshold concentration 
dw  dry weight                                     RI  remedial investigation 
FS  feasibility study                                     RvAL  removal action level 
HHRA  human health risk assessment                    SQS  sediment quality standard 
HPAH  high-molecular-weight polycyclic aromatic hydrocarbon     T-117  Terminal 117 
LDW  Lower Duwamish Waterway                    TEQ  toxic equivalent 
LPAH  low-molecular-weight polycyclic aromatic hydrocarbon      TOC  total organic carbon 
OC  organic carbonRvAL  removal action level 
PCB  polychlorinated biphenyl 
As mentioned previously, portions of the T-117 Upland Study Area may be converted
in the future to aquatic habitat as part of the restoration and redevelopment plans for
the T-117 EAA. As described further in Section 7, the sediment removal and/or
capping actions would be sufficient to result in clean sediment or cap material
extending to a minimum depth of up to 45 cm (Figure 4-1), which and would provide
protection for clammers and children playing within the intertidal areas (i.e., between
approximately +13.8 ft and 0 ft mean lower low water [MLLW]). Clams, which have a
maximum burrowing depth of 35 cm (1.1 ft), and clammers, who may dig up as deep
asto 45 cm (1.5 ft), and have direct-contact exposure would be protected. Figure 4-1
presents a conceptual diagram of the anticipated post-NTCRA conditions for both
upland and aquatic areas. This latter depth would also be sufficient to accommodate a
maximum erosion potential of 6 cm (2.5 in.) during a 100-yr storm event; monitoring
to assess the stability of the cap may be a part of the sediment monitoring program.
Additional information regarding LDW sediment dynamics within the T-117 Sediment
Study Area is provided in Section 5.
Because the final configuration of the sediment portion of the site is still being
evaluated, a sediment cap design, if needed, would be based on US Army Corps of
Engineers (USACE) guidance regarding the determination of cap thickness and the
specific layers that are necessary for a cap that is dependent on the environment and
the habitat in which it will be constructed. The cap design will be prepared during the
NTCRA design phase and will take into account potential future habitat requirements. 
Section 6.1.2.2 presents additional details on the cap design. 

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Figure 4-1.  Conceptual diagram of points of compliance for upland soil and sediment cleanup 
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4.3.2  Development of soil removal action levels 
This section describes the development of soil RvALs for the T-117 Upland Study Area
and the Adjacent Streets and Residential Yards Study Area. As shown in Figure 4-2
and Table 4-2, the RvALs were calculated or developed using: 
MTCA Method B (Equations 740-1 and 740-2, WAC 173-340-740) 
ARARs 
CULs from MTCA based on potential exposure to applicable upland ecological
receptors (TEE) (WAC 173-340-7490 through 7494) 
Potential influences on other media (e.g., the soil-to-groundwater [WAC 173-340-747]
and groundwater-to-sediment pathways) were also considered. In addition, residual 
risks associated with COCs remaining at concentrations at or below the candidate
RvALs were examined to determine if additional modifications were warranted or if
adjustments were needed for COC-specific exposure scenarios (e.g., early life-stage 
exposure to cPAHs). The potential for the erosion of soil to sediment will be addressed
as part of the NTCRA design. 










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Figure 4-2. Development of soil removal action levels 
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Table 4-2.  T-117 Upland Study Area soil removal action levels 
MTCA                        TPH                             Metals 
Regulation                               Heavy Oil-Range             Dioxin/Furan     Total
a
173-340-           Basis          Unit        Organics      cPAH TEQ      TEQ        PCBs     Arsenic     Silver 
Potential CULs 
TSCA  
740(3)(b)(i)                             mg/kg           nc             nc           nc           1.0         nc         nc 
40 CFR 761.61(4)(i)(A) 
TEE mammalian
mg/kg        6,000         11.75        nc         0.65       7.1       nc 
predator (shrew) 
TEE, avian predator
mg/kg        6,000          nc         nc         3.5       150.3       nc 
740(3)b)(ii)        (robin) 
TEE, mammalian
mg/kg        6,000         82.35        nc         14.4       42.9       nc 
herbivore (vole) 
-6
TEE, plants/soil biota       mg/kg           200            nc         2  10         40         10        2.0 
direct contact, non-
740(3)b)(iii)(B)(I)                           mg/kg            nc             nc            nc            nc          24         400 
carcinogen 
direct contact,                                                       -5
mg/kg         nc          0.14      1.1  10       0.50       0.67       nc 
carcinogen 
740(3)b)(iii)(B)II) 
preliminary human                                             -5
b                  mg/kg              2,000               0.14          1.1  10            1.0           0.67          400 
health CUL
c                d               -10            e 
PQLs              mg/kg       25/100       0.008     1.5  10      0.01      0.1      0.02 
700(6)(d) 
f
background            mg/kg          na           na          na          na        7.3        na 
Summary of Applicable CULs Used as a Basis for RvALs 
TEE wildlife/plants/soil                                                -5
h    1.1  10 2 
biota, human health      mg/kg          200        0.140.008        -6        0.65        7.3        2.0 
g                                                    10
direct contact (< 2 ft)
TEE plants/soil biota,
740                                                         h         -5
human health direct      mg/kg          200        0.140.008     1.1  10        1.0        7.3        2.0 
g
contact (2 to 6 ft) 
all other soil ( 6 to15 ft                                                      -5
mg/kg        2,000         0.14      1.1  10       1.0       7.3       400 
below grade) 
a 
NWTPH-Dx (diesel and lube oil ranges).

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b                                                         -6
Total cancer risk for all human health CULs is 5  10 ; total hazard index is 1. 
c 
25 mg/kg is the diesel-range PQL; 100 mg/kg is the heavy oil-range PQL. 
d
PQL is based on site-specific PQLs for benzo(a)pyrene. 
e
PQL assumes a single Aroclor (1260) for PCBs. 
f 
Background soil concentrations based on Puget Sound average from Natural Background Soils Metals Concentrations in Washington State Toxics Cleanup
Program (Ecology 1994c). 
g 
Soil CULs (used as a basis for selecting RvALs) for TPH, dioxins and furans, copper, and silver based on protection of plants or soil biota per the TEE
requirements are subject to change based on further site-specific TEE evaluation. 
h
cPAH TEQ is adjusted for combined early life stage adjustments and soil exposure factors for residential and recreational PRG (Appendix I). 
ARAR  Applicable or Relevant and Appropriate    nc  no criteria                           TEE  terrestrial ecological evaluation 
Requirement                      nd nc  not datacalculated                   TEQ  toxic equivalent 
BCF  bioconcentration factor                 NWTPH  Northwest total petroleum hydrocarbons     TPH  total petroleum hydrocarbons 
cPAH  carcinogenic polycyclic aromatic         PCB  polychlorinated biphenyl                 TPH-Dx  total petroleum hydrocarbons  
hydrocarbon 
PQL  practical quantitation limit                      diesel and oil extractable 
CPF  carcinogenic potency factor 
RfD  reference dose                        TSCA  Toxic Substances Control Act 
CUL  cleanup level 
RvAL  removal action level                    WAC  Washington Administrative Code 
CWA  Clean Water Act 
T-117  Terminal 117 
na  not availableapplicable 








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4.3.2.1   T-117 Upland Study Area 
As presented in Table 3-110, the soil COCs for the T-117 Upland Study Area are total 
PCBs, TPH, cPAHs, dioxins and furans, silver, and arsenic. Table 4-2 lists the MTCA
regulations that were used to determine the T-117 Upland Study Area soil RvALs for
the identified COCs. The derivation of the RvALs for each COC is described below. 
Total PCBs 
An RvAL of 1.0 mg/kg was selected for total PCBs for most of the T-117 Upland Study
Area based on the TSCA ARAR. According to MTCA, if it can be demonstrated that an
ARAR is sufficiently protective, the ARAR may be used to establish a CUL under
MTCA (WAC 173-340-740(3)(b)(iii)). An ARAR is considered sufficiently protective if it
is associated with a cancer risk of 1  10-5 or less (WAC 173-340-740(5)(b)). The TSCA
CUL of 1.0 mg/kg, proposed for use as an RvAL for the T-117 NTCRA, equates to an
excess cancer risk12 of 2  10-6. 
A different RvAL is applicable to areas within the T-117 Upland Study Area that may
become upland habitat. For those areas, the RvAL is based on the MTCA-defined soil
CUL for total PCBs of 0.65 mg/kg, which is relevant within limited soil depths based on
a TEE for terrestrial receptor exposure (Table 4-2). The development of a TEE-based
RvAL is appropriate inasmuch as the eventual size of the landscaped upland portion of
a future T-117 habitat area may exceed the MTCA-defined 0.25-acre threshold for a TEE
exclusion. Under the habitat restoration scenario, the T-117 Upland Study Area would 
be required to undergo a site-specific TEE rather than a simplified TEE. The most
stringent default TEE CUL under MTCA is based on the protection of the mammalian
predator (shrew) and is also protective of plants (the MTCA TEE CULs for the soil
biota, avian predator, and mammalian herbivore are significantly greater and would
not be a limiting factor). Burrowing mammalian predators, such as the shrew, and their
primary food source of worms and insects are found in the top 1 to 2 ft of soil (Suter
1993). As a result, a conditional point of compliance of the upper 2 ft for the soil RvAL
based on the MTCA TEE CUL is proposed, consistent with WAC 173-340-7490(4)(a). 
Plant roots would penetrate the full depth of the biologically active zone defined as the
upper 6 ft in MTCA. Institutional controls, such as a property usedeed restrictions and a
monitoring and maintenance plan, would be implemented at the developed habitat site
to ensure that any disturbance of soil would be managed to protect ecological receptors.
Institutional controls would also include the written notification of workers regarding
maintenance-related limitations and signs stating the prohibition of unplanned digging
within any habitat areas. 
To address any potential concerns regarding exposure through the consumption of
home-grown produce, the risk level associated with the PCB RvAL of 1.0 mg/kg was

12 Calculated using MTCA Equation 740-2 and a carcinogenic potency factor of 2 per mg/kg-day. 
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Page 133

compared to risks associated with this pathway to determine if adjustment was needed.
Based on a review of the literature, including a risk assessment conducted by the US
Army Corps of Engineers (USACE) and EPA (Weston Solutions 2005) for the 
Housatonic River,13 exposures associated with the consumption of produce grown in
soils that contain total PCBs and dioxins and furans at the T-117 RvALs would not
increase the total risk to a level in excess of 1 x 10-5. Though not reported in the
referenced risk assessment, the risk corresponding to an exposure level of 1.0 mg/kg
would be 1.5  10-6, which is less than the risk of 2  10-6 posed by the ARAR based
TSCA soil RvAL of 1.0 mg/kg. 
TPH 
To accommodate possible future use of the T-117 Upland Study Area for habitat, an
RvAL of 200 mg/kg was selected for the upper 6 ft of soil. For depths below 6 ft, an 
RvAL of 2,000 mg/kg was selected for TPH based on MTCA Method A CULs 
(Table 4-2). The Method A CUL is based on preventing the accumulation of diesel-
range TPH in groundwater in a coarse sand and gravel matrix and is lower than health-
based TPH criteria for diesel. A TPH fraction analysis was not performed at T-117 to
calculate a human health risk-based TPH value. 
cPAH TEQ 
Per EPA (2005e) guidance, the evaluation of early life-stage exposure to cPAHs was
considered in the development of the RvAL for cPAHs because of the potential for the
future exposure of children in areas of the T-117 Upland Study Area that may be made
available for public access. cPAHs are the only COCs considered to be mutagenic, so
they are the only COCs for which this adjustment may be necessary. The adjusted RvAL
was less than the PQL, thus an RvAL of 0.008 mg/kg TEQ was selected for cPAHs
based on PQLs for individual PAHs. Nevertheless, the adjusted RvAL was Early lifestage
exposure parameters were used in the calculations of total risk to evaluate
protectiveness under CERCLA for the recreational exposure scenario (Table 4-3).
Additional details of this adjustment to account for early life-stage exposure are
provided in Appendix I. The cPAH RvAL of 0.14 mg/kg TEQ was selected based on the
MTCA Method B ARAR. 



13 The risk assessment estimated that the reasonable maximum exposure cancer risk associated with the
consumption of produce grown in garden soil containing total PCBs at 2 mg/kg was 3  10-6. The
assessment used consumption rates for home-grown foods in three categories: exposed vegetables
(11 kg/yr), root vegetables (10 kg/yr), and exposed fruit (12 kg/yr). 
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Page 134

Table 4-3.  T-117 Upland Study Area total risks for soil removal action levels 
Excess Cancer Risk at RvAL 
MTCA Unrestricted Land Use         CERCLA 
MTCA     MTCA
Unrestricted  Unrestricted
Land Use    Land Use    CERCLA    CERCLA
Total     Incremental    Industrial   Recreational
RvAL    Source of   Risk(unitless Risk(unitless)  Scenario    Scenario 
a            b            b, cd         (unitless)cd            cd, e, f
COC    (mg/kg)     RvAL       )                     (unitless)
d                                       -56                           -7     2.6 x 10-602 
Arsenic      0.677.3   MTCA Method B     1  10         0        04  10         -7
10
-8              -78
Silver          2400     MTCA Method B       nNc           nc        837  10       2  10
-6                -6               -7                -6
cPAH TEQ    0.14    MTCA Method B    1 6  10     16  10     6  10     6  10
-6                -6                -6                -7
Total PCBs     1.0     Method B/TSCA     2  10       2  10      1  10      6  10
Dioxin/furan        -5                       -6           -6          -7          -7
1.1  10   MTCA Method B     1  10       1  10       6  10       3  10
TEQ 
-56              -6              -6              -6
Total                              1.52  10      49  10      23  10       7  10
a 
For total PCBs, the RvAL was based on the TSCA ARAR using MTCA Method B CUL development procedures.
For other COCs, the MTCA Method B standard equation value was used. 
b 
Risk was calculated according to the standard MTCA Method B equation and assumptions with adjustments to
the cPAH risk based on early life-stage exposure parameters (Appendix I). 
dc 
The arsenic RvAL is based on natural background. The MTCA risk calculation was performed both using the
natural background risk associated with arsenic and the incremental risk of the arsenic RvAL relative to natural
background (which is zero). The second risk calculation demonstrates compliance with the MTCA total risk
-5
threshold of 1x10  (WAC 173-340-740(5)(a)).and corresponding risk used to calculate total risks is the MTCA
Method B value, which is lower than the selected RvAL of 7.3 mg/kg, which is based on the soil background
concentration. 
c 
Risk was calculated according to CERCLA equations and assumptions appropriate to the scenario. 
e 
The exposure frequency for the recreational scenario was 48 days/yr. 
f 
The CERCLA recreational scenario risk calculation incorporates early life stage adjustments (Appendix I). 
CERCLA  Comprehensive Environmental Response, Compensation,  PCB  polychlorinated biphenyl 
and Liability Act                                       RvAL  removal action level 
COC  contaminant of concern                           T-117  Terminal 117 
cPAH  carcinogenic polycyclic aromatic hydrocarbon             TSCA  Toxic Substances Control Act 
MTCA  Model Toxics Control Act 
nc  non-carcinogens (not included in the MTCA total cancer risk
analysis) 
Ecology is currently evaluating early life-stage exposure and is considering rule
revisions to address this issue. On March 22, 2010, Ecology released a document with
examples of updates to MTCA specifically related to cPAHs and early -life-stage 
exposure (Appendix I). The information and examples are currently under discussion
among the MTCA /SMS Advisory Group members. Although early life-stage exposures
are not currently incorporated into MTCA, the total risk calculation in Table 4-3 for the
MTCA unrestricted-land-use scenario incorporates early life-stage exposure
assumptions. Additional details on the adjustment to account for early life-stage
exposures are provided in Appendix I. The cPAH soil RvAL may be below natural or
anthropogenic background concentrations. Background concentrations have not been
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Page 135

evaluated in this EE/CA but may be evaluated during remedial design. Ecology's
document provided a mean background cPAH concentration of 1.8 mg/kg. 
Dioxin/Furan TEQ 
The RvAL of 11 ng/kg TEQ for dioxin/furan was selected for the T-117 Upland Study
Area. This RvAL is equal to the MTCA Method B risk-based concentration that
corresponds to a carcinogenic risk of 1 x 10-6. 
A recurring issue in risk assessment is the calculation of acceptable or safe levels of
dioxins and furans in soil. EPA is currently undertaking a comprehensive review of this
issue as part of its "dioxin reassessment." This work includes an examination of dioxin
and furan soil action levels in use across the United States and internationally. On
January 7, 2010, EPA's Office of Solid Waste and Emergency Response (OSWER) issued
draft recommended interim PRGs for dioxin and furan soil at CERCLA and RCRA sites 
(EPA 2009b). The proposed draft recommended interim PRGs are 72 ng/kg TEQ for
residential land uses and 950 ng/kg TEQ for commercial/industrial land uses. These
draft recommended interim PRGs are lower than the previous value of 1,000 ng/kg
TEQ for dioxin in residential soil and lower than the range of 5,000 to 20,000 ng/kg TEQ
for dioxin in commercial/industrial soil. EPA expects to issue a final interim PRG by
June 2010. 
Currently, several soil criteria are being used by different government organizations, as
listed below. These criteria are presented for informational uses only; none of these
criteria are applicable under MTCA (i.e., they are not ARARs). 
EPA current residential soil cleanup standard: 1,000 ng/kg TEQ (EPA 1998). This 
standard forms the basis of the 1998 PRG and is the starting point for the
derivation of CULs at CERCLA and RCRA sites. This value reflects an excess
cancer risk of approximately 2.5  10-4 based on exposure and toxicity parameters
used in 1998. This PRG is being reassessed as noted above, and may be lowered
to 72 ng/kg TEQ. This draft PRG corresponds to an excess cancer risk of 1  10-5. 
The EPA 2009 residential PRG (for Regions 3, 6, and 9) used for screening:
4.5 ng/kg TEQ (EPA 2009e). This PRG is based on an excess cancer risk of 1  
10--6 and uses somewhat different exposure and toxicity parameters than those
used in 1998 (listed above). This concentration is used for screening at CERCLA
sites and is not necessarily used as a CUL. 
Agency for Toxic Substances and Disease Registry (ATSDR) direct-contact
residential exposure SL is 50 ng/kg TEQ (73 FR 61133). This value is not a
threshold for toxicity but is used as a SL by ATSDR health assessors to determine
when to conduct health evaluations (i.e., when dioxins and furans are present
above this level). 
Washington State Department of Health (WSDOH) site-specific health
assessment: levels that trigger health assessment by WSDOH are site-specific. 
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Page 136

Silver 
To accommodate possible future use of the T-117 Upland Study Area for habitat, an 
RvAL of 2.0 mg/kg was selected for the upper 6 ft of soil based on the MTCA TEE. For
depths below 6 ft, an RvAL of 400 mg/kg was selected for silver based on MTCA
Method B (Table 4-2). The higher concentration was evaluated in conjunction with those
of other non-carcinogenic COCs to ensure that the total hazard index for the site was
less than 1.0. 
Arsenic 
A preliminary RvAL of 0.67 mg/kg was calculated for arsenic based on human health
considerations. However, because this concentration was less than the preliminary
natural background concentration in the Puget Sound region (7.3 mg/kg) (Ecology
1994c), an RvAL of 7.3 mg/kg was selected. This RvAL does not result in a total hazard
index of greater than 1.0 when considered together with contributions from other noncarcinogenic
COCs. 
Assessment of Total Risk 
The total excess cancer risk associated with each for the selected RvALs was assessed
for the MTCA unrestricted- land- use scenario and for recreational and industrial 
scenarios under CERCLA. The MTCA unrestricted land use and CERCLA recreational
scenarios incorporated early life-stage exposure parameters risk calculations and RvALs
based on MTCA-derived CULs, described above for individual contaminants, were
assessed for total risk for both recreation and commercial exposure scenarios to ensure
compliance. Detailed back-up for these risk calculations is presented in Appendix I. 
The total risks for the recreational and coindustrialmmercial land use scenarios (under
CERCLA) were 7 6  10-6 and 3 2  10-6, respectively (Table 4-3), which were within the
acceptable CERCLA 10-4 to 10-6 risk range. The total risks for the recreational and
commercial land use scenarios (under MTCA unrestricted land use scenario) wasere
each 1.552  10-56 (Table 4-3). When the incremental arsenic risk was adjusted relative to
natural background, the risk was reduced to 49  10-6, ; risks estimates for both
scenarios were less than the 10-5 MTCA threshold. 
4.3.2.2   Adjacent Streets and Residential Yards Study Area 
As presented in Table 3-110, the soil COCs for the Adjacent Streets and Residential
Yards Study Area are total PCBs and dioxins and furans. An RvAL of 1 mg/kg was
selected for total PCBs based on the TSCA ARAR, and an RvAL for dioxin/furan TEQ 
of 11 ng/kg was selected based on MTCA Method B. 
Utility workers and residents may be exposed to soils within the Adjacent Streets and
Residential Yards Study Area. MTCA does not have a CUL for utility workers, so the
residential scenario was used to evaluate exposures under MTCA for both areas.
CERCLA does have a utility worker scenario; risks were calculated for the worker
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Page 137

scenario.14 As shown in Table 4-4, these total risk estimates were less than 10-5 (MTCA)
and were within the CERCLA range of 10-4 to 10-6. 
Table 4-4.   T-117 Adjacent Streets and Residential Yards Study Area total risks 
for soil removal action levels 
Excess Cancer Risk at RvAL 
CERCLA 
MTCA   CERCLA Utility  CERCLA Residential  CERCLA
Unrestricted Worker Scenario  Scenario for Adjacent  Recreational
RvAL  Source of Land Use    for Adjacent  Streets and Residential  Scenario
a                 b                  b            c, d,. e
COC     (mg/kg)   RvAL   (unitless)  Streets (unitless)   Yards (unitless)   (unitless)
Adjacent Streets  Utility Worker Scenario 
-6                 -8                      -6                     -6
Total PCBs       1.0     TSCA     2  10       2  10           5  10         4.5  10
-5                       -6                 -8                      -6                     -6
Dioxin/furan TEQ  1.1  10  Method B    1  10       1  10           2  10         2.4  10
-6                 -8                      -6                     -6
Total                            3  10        3  10           7  10         6.9  10
a 
Risk was calculated according to the standard MTCA Method B equation and assumptions. 
b 
Risk was calculated according to CERCLA equations and assumptions appropriate to the scenario. For the
residential scenario, these are standard default assumptions used by EPA Regions 3, 6, and 9. 
c 
Risk was calculated according to CERCLA equations and assumptions appropriate to the scenario. 
d 
The exposure frequency for the recreational scenario was 48 days/yr. 
e 
The CERCLA recreational scenario risk calculation incorporates early life- stage adjustments (Appendix I). 
CERCLA  Comprehensive Environmental Response,     PCB  polychlorinated biphenyl 
Compensation, and Liability Act                  RvAL  removal action level 
EPA  US Environmental Protection Agency            TEQ  toxic equivalent 
MTCA  Model Toxics Control Act 
4.3.3  Development of groundwater removal action levels 
This section describes the development of groundwater RvALs for the T-117 Upland
Study Area and the Adjacent Streets. As shown in Figure 4-3 and Table 4-5, the RvALs
were calculated or developed using: 
MTCA Method B (Equations 7240-1 and 7240-2, WAC 173-340-7240) 
ARARs ( 
Ssurface water protection criteria using MTCA Equation 730-2 with a site-specific
fish consumption rate of 57 g/day and a fish diet fraction of 1 for the Duwamish

14 Risks for the utility worker scenario were calculated using the following equation: risk = 1 x 10-6 x
MTCA CUL/utility worker PRG, where risk is unitless and the MTCA CUL and the utility worker PRG
are both expressed as mg/kg. The utility worker PRGs for PCBs and dioxins and furans were derived by
adjusting the industrial PRGs as follows: the exposure frequency was adjusted down from 250 days/yr to
30 days/yr; the exposure duration was adjusted down from 25 yr to 1 yr; and the soil ingestion rate was
adjusted up from 100 mg/day to 330 mg/day. 
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T-117 Early Action Area                                                 June 3, 2010 
Page 138

corridor and Elliott Bay based on the King County Asian Pacific Islander seafood
consumption survey) (EPA 1999) 
CULs from MTCA based on background concentrations (e.g., Method A for
arsenic) 
CULs from based on site site-specific background concentrations 




















Lower Duwamish Waterway Superfund Site:                             Draft Final EE/CA 
T-117 Early Action Area                                                 June 3, 2010 
Page 139

Figure 4-3. Development of groundwater cleanup levels 
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FINAL                January 19June 3, 2010 
Page 140

Table 4-5.  T-117 Upland Study Area groundwater removal action levels 
TPH 
(Heavy Oil 
MTCA Regulation                           -Range     Total             Total
a
(WAC 173-340)-          Basis          Unit  Organics)  cPAH TEQ    BEHP     PCBs     Silver     Arsenic   Total Risk 
Surface Water 
b
730(3)(b)(i)(A)     WAC 173-201A, marine        g/L      nc         nc         nc       3.00E-02      1.9         36 
c
730(3)(b)(i)(B)    Sec. 304, CWA, marine, chronic  g/L       nc         nc         nc       3.00E-02      1.9         36 
c
730(3)(b)(i)(B)    Sec. 304, CWA, organism only   g/L       nc       1.80E-02      2.2      0.000064       nc        0.14 
40CFR131, NTR, marine,
730(3)(b)(i)(C)          d                   g/L       nc         nc         nc        0.03        1.9         36 
chronic
40CFR131, NTR, organism
730(3)(b)(i)(C)       d                      g/L       nc       3.10E-02      5.9       0.00017       nc        0.14 
only 
environmental effects          g/L      nc        nc        nc        nc        nc        nc 
appropriate ARAR           g/L      nc      0.0180      2.2     0.000064     1.9        5 
CPF (kg-day/mg)                   na       7.3      0.014       2        na       1.5 
oral RfD (mg/kg-day)                  na        na        0.02        na       0.005      0.0003 
730(3)(b)(ii) 
BCF                       na       30      130     31000      0.5       44 
6.01.38E-    1.3E-    066.12E-            1.43E1E-
cancer risk                          na                                      na                 1.1E-04 
076     66.18E-07   071.3E-6              0604 
0.0120.005            1.5E-   0.5970.007
hazard quotient                      na        na                  na                          0.609 
5157             047.3E-05     92 
human health, fish consumption,
730(3)(b)(iii)(A)                               g/L       nc         nc         399         nc        25,926       17.7 
non-carcinogen 
human health, fish consumption,                                  0.00010000
730(3)(b)(iii)(B)                               g/L       nc      0.0296014     3.61.7                   nc      0.0982047 
carcinogen                                                   5 


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TPH 
(Heavy Oil 
MTCA Regulation                           -Range     Total             Total
a
(WAC 173-340)-          Basis          Unit  Organics)  cPAH TEQ    BEHP     PCBs     Silver     Arsenic   Total Risk 
human health, fish consumption,
g/L      500        na        na        na        na        na 
petroleum mixture 
0.00006400
preliminary CUL             g/L     500     0.0180014    2.21.7                1.9     0.0982047 
005 
730(3)(b)(iii)(C) 
6.11.0E-    1.0E-     1.0E-              1.0E-     4.0E-
cancer risk                          na                                      na 
0706    066.2E-07   066.1E-07           061.43E-06  063.3E-06 
7.33E-
hazard quotient                      na        na      0.006009      na               0.008006     0.015 
050.0002 
e
PQLs              g/L   250/500    0.15      1.0      0.01     0.02     0.02 
700(6)(d)                                               0.00022ntc   1.37not   0.00033not    nanot     0.71not
f
background               g/L              not    calculatedn  calculatedn  calculatedn  calculatedn
calculated      tc         tc         tc         tc 
730           CUL                   g/L     500       0.15      2.21.7      0.01       1.9      0.710.05 
Groundwater 
MCL, SDWA            g/L     nc       nc      6.0      0.5      nc       10 
MCLG for non-carcinogens,
720(4)(b)(i)                                 g/L       nc         nc         nc         nc         100         10 
SDWA 
MCL, WSDOH           g/L     nc      nc      nc      nc      nc      nc 
protect surface water (from                                       0.00006400
g/L      500     0.0180014    2.21.7                1.9       0.7105 
above)                                                    005 
0.00006400
preliminary CUL             g/L     500     0.018014     2.21.7                1.9      0.09805 
005 
720(4)(b)(ii) 
6.11.0E-    1.0E-    6.11.0E-
cancer risk                          na                                      na      1.4E0E-06   3.34.0E-06 
0706    066.2E-07    0706 
7.3E-
hazard quotient                      na        na      0.006009      na                0.0068     0.014015 
050.00002 
e                                     g
PQLs              g/L   250/500    0.15      1.0      0.01     0.02      0.5 
700(6)(d) 
h
background             g/L     na       na       na       na       na        5 
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TPH 
(Heavy Oil 
MTCA Regulation                           -Range     Total             Total
a
(WAC 173-340)-          Basis          Unit  Organics)  cPAH TEQ    BEHP     PCBs     Silver     Arsenic   Total Risk 
720           CUL                   g/L     500       0.15      2.21.7      0.01       1.9        5 
720(8)(e)        shoreline compliance level             12,500      0.15      5542.5      0.01       47.5       17.85 
a
NWTPH-Dx (diesel- plus lube oil-ranges). 
b    Table 240(3) WAC 173-201A. 
c    National recommended water quality criteria (EPA 2002). 
d    40CFR131.35, revised July 1, 2003. 
e    PQL assumes a single Aroclor (1260) for PCBs and incorporates the TEF calculation for cPAH. 
f     Background surface water concentrations are based on water quality upgradient of the LDW as indicated in the draft feasibility study (ENSR|AECOM 2009). 
g    250 g/L is the diesel-range PQL; 500 g/L is the lube oil-range PQL. 
h    Background groundwater concentration for arsenic is based on MTCA Method A, and concentration for copper is based on site-specific statistical data analysis. . 
i    CULs are MTCA-defined CULs. These serve as a basis for the RvALs throughout the EE/CA. Human health surface water quality criteria based on bioaccumulation have been
conservatively assumed to apply to groundwater discharges even though the applicability of these criteria is uncertain. 
I     Equation 730-2 in MTCA was modified to include the site-specific Asian Pacific Islander fish consumption rate of 57 g/day and fish diet fraction of 1 for the Duwamish corridor and
Elliott Bay. The EPA consumption rate for the LDW of 97 g/day is not appropriate for the computation of MTCA surface water CULs. 
ARAR  applicable or relevant and appropriate requirement    EPA  US Environmental Protection Agency                  PCB  polychlorinated biphenyl 
BCF  bioconcentration factor                       LDW  Lower Duwamish Waterway                        PQL  practical quantitation limit 
BEHP  bis(2-ethylhexyl) phthalate                    MCL  maximum contaminant level                        RfD  reference dose 
CFR  Code of Federal Regulations                   MCLG  maximum contaminant level goal                  RvAL  removal action levels 
cPAH  carcinogenic polycyclic aromatic hydrocarbon        MTCA  Model Toxics Control Act                        SDWA  Safe Drinking Water Act 
CPF  carcinogenic potency factor                    na  not applicable                                  TEF  toxic equivalency factor 
CUL  cleanup level                             nc  no criteria                                     TPH  total petroleum hydrocarbons 
CWA  Clean Water Act                        NTR  National Toxics Rule                          WAC  Washington Administrative Code 
EE/CA  engineering evaluation/cost analysis             NWTPH-Dx  Northwest total petroleum hydrocarbons  diesel and   WSDOH  Washington State Department of
EPA  US Environmental Protection Agency                lube oil                                        Health 




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Because groundwater in the vicinity of the T-117 Upland Study Area is not potable, as
described in Appendix B, MTCA cancer risks for groundwater ingestion were not
calculated. The total cancer risk was calculated (Table 3-B-348) based on surface water
protection using MTCA Equation 730-2, as modified. The total cancer risk for
groundwater protective of surface water was less than 44.0  10-6, below the
acceptable total risk range threshold of 10-5. The HQ, calculated using MTCA
Equation 730-1, was 0.015, well below the acceptable total HQ of 1. CERCLA risks 
were not calculated for groundwater, inasmuch as it is not suitable for domestic use. 
As presented in Table 3-98, the groundwater COCs for the T-117 Upland Study Area
include arsenic, copper, silver, PCBs, TPH, cPAH TEQ, and BEHP. Table 4-5 lists the
regulations that were used to determine the T-117 Upland Study Area groundwater
RvALs for the identified COCs. The derivation of the RvALs for each COC is
summarized below. and described in detail in Appendix B. 
Arsenic 
Arsenic background values were determined based on MTCA Method A. A
site-specific background value was not calculated because of the small sample set and
elevated reporting limits. Reporting limits for select sampling events were
significantly greater than the MTCA Method A value. The arsenic RvAL was 5 g/L. 
Silver and BEHP 
Silver and BEHP RvALs are based on the protection of surface water. RvALs were
derived from published standards defined in the Clean Water Act. The silver RvAL is
1.9 g/L, and the BEHP RvAL is 2.21.7 g/L. 
TPH 
The TPH RvAL is based on the MTCA Method A value because no surface water
quality criterion is available. The TPH RvAL is 500 g/L. 
Total PCBs and cPAH TEQ 
The total PCBs and cPAH TEQ RvALs are based on practical qualitative limits, which
represent the practical level that analytical laboratories can sample and report results.
The RvAL for total PCBs is 0.01 g/L, and the RvAL for cPAH TEQ is 0.15 g/L. 
4.3.4  Summary of T-117 EAA removal action levels 
Sediment, soil, and groundwater RvALs derived in Section 4 for T-117 EAA COCs are
summarized in Table 4-6. 


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Table 4-6.  T-117 EAA sediment, and soil, and groundwater removal action 
levels 
a                          b
Sediment                 Soil                Groundwater 
T-117 Sediment  T-117 Upland    Adjacent    Residential  T-117 Upland
ic
COCs        Study Area    Study Area     Streets      Yards    Study Area
Metals 
cd
Arsenic               12 mg/kg       7.3 mg/kg         na           na         5 g/L 
Copper                na           na          na          na        3.4 g/L 
de
Silver                      na        2.0/400 mg/kg        na            na          1.9 g/L 
PAHs 
ef
2-Methylnaphthalene     0.59 mg/kg        na           na          na          na 
ef
Acenaphthene        0.25 mg/kg        na          na         na         na 
ef
Anthracene           3.4 mg/kg         na           na          na          na 
ef
Benzo(a)anthracene      1.7 mg/kg        na          na          na          na 
ef
Benzo(a)pyrene        1.5 mg/kg        na          na          na          na 
ef
Benzo(g,h,i)perylene     0.48 mg/kg         na           na          na           na 
Total                       ef
3.6 mg/kg        na          na          na          na 
benzofluoranthenes 
fg                    fg
cPAH TEQ          0.09 mg/kg   0.00814 mg/kg      na         na       0.15 g/L 
ef
Chrysene            1.7 mg/kg        na          na          na          na 
ef
Dibenzo(a,h)anthracene   0.19 mg/kg        na           na          na          na 
ef
Dibenzofuran          0.23 mg/kg        na           na          na          na 
ef
Fluoranthene          2.5 mg/kg         na           na          na          na 
ef
Fluorene             0.36 mg/kg         na           na          na          na 
ef
Indeno(1,2,3-cd)pyrene   0.53 mg/kg        na           na          na          na 
ef
Phenanthrene         1.6 mg/kg        na          na          na          na 
ef
Total HPAH (calc'd)       15 mg/kg         na           na           na           na 
ef
Total LPAH (calc'd)       5.7 mg/kg         na           na           na           na 
TPH 
Diesel- and lube oil-                    200/2,000
na             gh        na          na        500 g/L 
range hydrocarbons                   mg/kg
Other SVOCs 
BEHP               na          nc         na         na      2.21.7 g/L 
Phenol              0.420 mg/kg        na           na          na          na 
PCBs 
ef,
Total PCBs          0.19 mg/kg dw            hj
0.65/1.0 mg/kg    1.0 mg/kg     1.0 mg/kg     0.01 g/L 
ij
or 12 mg/kg -
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a                          b
Sediment                 Soil                Groundwater 
T-117 Sediment  T-117 Upland    Adjacent    Residential  T-117 Upland
ic
COCs        Study Area    Study Area     Streets      Yards    Study Area
OC 
Dioxins and Furans 
Dioxin/furan TEQ         13 ng/kg       11 ng/kg       11 ng/kg      11 ng/kg        na 
a 
Sediment point of compliance for the intertidal area is the top 10 cm for protection of benthic organisms and
human health; the subtidal point of compliance is the top 45 cm for protection of human health. 
b 
Upland soil point of compliance is the depth at which the RvAL is reached, not to exceed 15 ft. 
jc
If the SQS value of 12 mg/kg OC is not used because the TOC in a sediment sample is either higher or lower
than 0.5 to 3.5%, then a site-specific calculation, or "surrogate," can be applied, which results in a value of 0.19
mg/kg dw. 
cd
This RvAL is lower than preliminary background concentration (Windward 2008) and has been adjusted
upward. The background concentration forlowest LDW RBTC for arsenic is 1.3 mg/kg; however, the RvAL is
12 mg/kg, which is similar to background concentrations being considered for arsenic. 
d e    The TEE-based RvAL is 2.0 mg/kg in the upper 02 to 6 ft of soil for areas to be protective for terrestrial
ecological exposures defined under MTCA and as determined by the type of biota to be present. The RvAL is
400 mg/kg for soils deeper than 6 ft. 
e f    These RvALs were established based on SQS values, which were originally presented in units of mg/kg OC.
The OC-normalized units were converted to mg/kg dry weight using a TOC concentration of 1.55%, reflecting
the average TOC concentration in the T-117 Sediment Study Area based on both surface and subsurface
sample results. For PCBs, If the SQS value of 12 mg/kg OC is not used because the TOC value in a sediment
sample is either higher or lower than 0.5 to 3.5%, then a site-specific calculation, or "surrogate," can be
applied, which results in a value of 0.19 mg/kg dw. 
f g    These RvALs are likely to be lower than applicable background concentrations and may need to be adjusted
upward. 
g h    TEE-based RvAL is 200 mg/kg in the upper 02 to 6 ft of soil for areas to be protective for terrestrial ecological
exposures defined under MTCA and as determined by the type of biota to be present. The RvAL is
2,000 mg/kg for soils deeper than 6 ft. 
h i    TEE-based RvAL is 0.65 mg/kg in the upper 2 ft of soil for areas to be protective for terrestrial ecological
exposures defined under MTCA. The RvAL is 1.0 mg/kg for soils deeper than 2 ft. 
i j     The point of compliance for the groundwater RvALs is the point of exposure or the location where groundwater
discharges to surface water (see Figure 4-1). 
BEHP  bis(2-ethylhexyl) phthalate                  nc  no criteria 
cPAH  carcinogenic polycyclic aromatic hydrocarbon      OC  organic carbon 
COC  contaminant of concern                    PAH  polycyclic aromatic hydrocarbon 
dw  dry weight                               PCB  polychlorinated biphenyl 
HPAH  high-molecular-weight polycyclic aromatic       RBTC  risk-based threshold concentration 
hydrocarbon                            RvAL  removal action level 
LDW  Lower Duwamish Waterway               SQS  sediment quality standards 
LPAH  low-molecular-weight polycyclic aromatic        SVOC  semivolatile organic compound 
hydrocarbon 
TEE  terrestrial ecological evaluation 
MTCA  Model Toxics Control Act 
TEQ  - toxic equivalent 
na  not applicable 
TOC  total organic carbon 
nc  no criteria 
TPH  total petroleum hydrocarbons 


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4.4   REMOVAL BOUNDARY DETERMINATION 
This section discusses the process for identifying the removal boundaries for each of
the T-117 EAA study areas and presents the boundaries. Removal boundaries were
determined based on RvALs for the identified T-117 COCs. The lateral extent of the
removal boundary boundaries for each portion of T-117 EAA study areas is presented
on Map 4-1. The area within the removal boundary is referred to as the removal area. 
4.4.1  T-117 Sediment Study Area 
A sediment removal boundary was developed in the 2005 EE/CA (Windward et al.
2005c) using a weight-of-evidence approach that included a comparison of site
sediment chemistry data to SMS and consideration of COCs identified in the LDW
HHRA (Windward 2007b) and ERA (Windward 2007a). Since that time, RBTCs were
developed and preliminary background data were compiled for the LDW RI
(Windward 2008). Although the LDW RI does not specify sediment action levels, a 
preliminary comparison presented in the RI showed that many of the RBTCs were less
than background concentrations. 
EPA's stated intention for the T-117 EAA is to sufficiently clean up the EAA so that
future T-117 cleanup actions are not necessary under the LDW Record of Decision
(ROD) (EPA 2007b). EPA therefore is requiring that the T-117 sediment cleanup 
boundary be based on a point-by-point RvAL rather than based on the previously
approved weight-of-evidence approach that was used to derive the 2005 sediment
removal boundary. 
The sediment removal boundary shown on Map 4-1 has been delineated to encompass
all sampling locations with PCB concentrations greater than the RvAL. Total PCBs was
the most prevalent COC, and the PCB RvAL is primarily responsible for determining
the delineation of the removal boundary. All other COCs with concentrations greater
than their RvALs are also contained within the removal boundary. As discussed in
Section 4.3.1, the depth of compliance is 45 cm. 
4.4.2  T-117 Upland Study Area 
The removal boundary for the T-117 Upland Study Area is presented on Map 4-1 and
is discussed relative to each applicable upland COC in this section. PCBs, dioxins and
furans, cPAH, arsenic and TPH were identified as COCs for the T-117 Upland Study
Area. This boundary encompasses all of the areas where soil will be removed to meet
the RvALs for the COCs both spatially and by depth (i.e., up to 15 ft deep) to allow for
the broadest possible range of land uses in the future. 
As required per SOW Amendment 1, a spatial analysis of the distribution of PCB and
TPH concentrations (Maps 4-2 through Map 4-7) was used to verify that the proposed
removal prisms (i.e., the three-dimensional removal boundaries) will be located and
sized to ensure the removal of all soil that exceeds the RvAL. These maps were created
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using statistical interpolation to estimate PCB and TPH concentrations at locations
other than those that were actually sampled, and thus introduce some uncertainty. 
4.4.3  Adjacent Streets and Residential Yards Study Area 
Two different types of soil samples have been collected from the Adjacent Streets and
Residential Yards Study Area: point samples (i.e., single point surface and subsurface
samples, including soil and monitoring well borings) and MIS samples. Both point and
MIS samples are used to delineate Adjacent Street ROW cleanup boundaries, whereas
MIS samples alone are used to delineate Residential Yards cleanup boundaries. Soils
represented by point samples will be removed from areas with concentrations greater
than 1 mg/kg PCBs. 
Based on EPA's statistical evaluation of MIS sample triplicate data (Appendix L), EPA
has directed that variability (as the upper confidence limit on the mean [UCL]) be
incorporated into the establishment of CULs. Accordingly, soils represented by MIS
samples will be removed from areas where the UCL is greater than 1 mg/kg. As
described in Section 9.3.3.2, final soil excavation depths will be based on confirmation
sampling to ensure that RvALs have been attained. 
As discussed in Section 3, dioxins and furans are designated as COCs in areas where
they are co-located with PCBs above the PCB RvAL, per administrative direction by
EPA (2009a). Based on the forensic work completed by the Dioxin Technical
Workgroup and their 2008 and 2009 findings (Appendix M). Measurable 
concentrations of dioxins are always present in urban soils because of the
contributions from various typical combustion and chemical sources. Elevated dioxin
concentrations on the T-117 Upland Study Area have been documented. Potential
T-117 sources that contribute contaminants to nearby streets and yards include the
track-out of PCB- or dioxin-contaminated soil, air emissions from the burning of PCB-
contaminated waste oils, and typical oil-fired furnace air emissions. Data from
numerous studies assembled and evaluated by the Dioxin/Furan Technical
Workgroup indicate that levels of dioxins in the neighborhood are higher than would
be expected from typical urban sources, such as vehicle or residential emissions. Given
the PCB concentrations measured in the Adjacent Streets and Residential Yards Study
Area and the results of chemical pattern analyses for samples with concentrations of
dioxins and furans, the contribution of direct PCB track-out to total dioxin
concentrations appears to be small. The overall apportionment between T-117 and
non-T-117 contributions, primarily related to potential air emission pathways, remains
uncertain. Given this current uncertainty, dioxins and furans are not being used
independently to define removal boundaries at this time. However, in areas where
removal actions are required for PCBs, dioxins and furans will remain a COC and will
be included as part of confirmation sampling for the Adjacent Streets and Residential
Yards Study Area. This will eliminate the potential that any given street or yard area
will have to be re-excavated, should the uncertainty about total T-117 contributions be
resolved in the future. 
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As discussed in Section 3, dioxins and furans are designated as COCs in areas where
they are co-located with PCBs above the PCB RvAL, per administrative direction by
EPA (2009a). Based on the forensic work completed by the Dioxin Technical
Workgroup and their 2008 and 2009 findings (Appendix M), EPA has made the
determination that the asphalt manufacturing facility operations were likely not the
source of the majority of the dioxins and furans detected in the Adjacent Streets and
Yards Study Area, and that the source of the dioxins and furans is as yet
undetermined. However, based on an assumption that a minor portion of the dioxins
and furans in the Adjacent Streets and Residential Yards Study Area may be
associated with PCBs from asphalt manufacturing facility operations, EPA has
directed that dioxins and furans be designated as COCs where co-located with PCBs
above the PCB RvAL in the Adjacent Streets and Residential Yards Study Area
(Appendix M). 
In summary, cleanup in the Adjacent Streets and Yards Study Area will be guided by 
the following assumptions: 
PCBs will beare the driver for streets and yards cleanup. 
Wherever PCB cleanup occurs, co-located dioxins will also be removed. 
Where PCB concentrations are below the PCB RvAL but dioxin/furan TEQs
exceed the dioxin/furan TEQ RvAL, no cleanup will occur as part of this
removal action. 
Post NTCRA PCB sampling will include analysis of dioxins and furans. 
Additional dioxin and furan data are expected to be generated as a result of additional
sampling in the LDW, at adjacent upland sites, and in stormwater conveyance
systems. These data will provide information to better identify dioxin and furan
sources and upland soils concentrations in the area and will help put the dioxin and
furan concentrations in the Adjacent Streets and Residential Yards Study Area into
broader perspective with respect to sources and possible future removal actions.
Removal areas for Adjacent Streets and Residential Yards, based on the distribution of
PCBs, are shown on Figure 4-1. 





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5    Recontamination Assessment 
The long-term effectiveness of the planned NTCRA at the T-117 EAA relies on the
identification, characterization, and control of potential recontamination sources and
pathways as they may exist after completion of the removal action. To assess this
future recontamination potential, this section: 
Provides an overview of the source control strategy 
Establishes the baseline condition for a post-NTCRA T-117 EAA and discusses
potential recontamination sources and pathways 
Critically evaluates the potential for these sources/pathways to contribute to
the recontamination of post-NTCRA sediments 
Provides recommendations for multi-media monitoring to ensure long-term
protectiveness of the remedy 
The recontamination assessment in this EE/CA is necessary to ensure that the
potential for recontamination is addressed as part of the NTCRA design and through
future source control actions by the responsible site owners, in coordination with the
ongoing LDW-wide source control activities for the LDW Superfund Site. The
potential for recontamination will also be considered in the design of post-NTCRA
monitoring programs to help ensure the long-term effectiveness of the removal action. 
This assessment builds upon the initial evaluation presented in the draft EE/CA
(Windward et al. 2008) and takes into consideration newly obtained site data for soil,
catch basin solids, and groundwater. Also considered are the results of Ecology's
recent sediment recontamination assessment for the Marina (SAIC 2009), and the
investigation of soil and groundwater at the Basin Oil property (Ecology 2009b), and
the findings of the sediment transport analysis presented in the LDW RI (Windward
2008) as it relates to the T-117 EAA. 
5.1   OVERALL SOURCE CONTROL STRATEGY 
Source control for the T-117 EAA is governed by the strategy outlined for the LDW
(Ecology 2004a). The goal of the LDW strategy is to minimize the potential for
chemicals in sediments to exceed the LDW sediment cleanup goals and the SMS
(WAC 173-204). Ecology is the lead agency implementing source control; Ecology
works in cooperation with local jurisdictions and EPA, together forming the LDW
Source Control Work Group (SCWG), to pursue this goal. The member agencies of the 
SCWG rely upon a variety of tools and strategies to encourage, implement, and
monitor source control activities within the LDW and adjoining drainage basins,
including public education, implementation of source-tracing programs, evaluation of
potential upland and in-water contaminant sources, and enforcement of requirements
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for the cleanup of contaminated sites and drainage systems that may have an ongoing
or future potential to contaminate LDW sediment. 
Ecology's source control investigation findings and plans for implementing source
control activities at the LDW Superfund Site are documented in various data gaps
reports and source control action plans (SCAPs) (Ecology and SAIC 2008). The original
SCAP for the T-117 EAA (Ecology 2005a) was published relatively early in the LDW
source control process and, thus, did not include the results of later investigations and
evaluations of groundwater and potential contaminant sources and pathways
associated with the expanded T-117 EAA and adjacent properties (i.e., the Marina and
Basin Oil property). Nonetheless, the T-117 EAA has continued to be a high priority
for Ecology and the SCWG. The T-117 EAA SCAP identified storm drain outfalls and
soil from Basin Oil, the former A&B Barrel, the T-117 Upland Study Area, and the
Adjacent Streets as potential sources of recontamination to the sediment. Ecology
recently completed a sediment recontamination assessment for the Marina (SAIC 2009) 
and site investigations at the inactive Basin Oil property (Ecology 2009b). Ecology also
performed a facility review of Boeing South Park and determined that the likelihood
of recontamination from stormwater discharges from parking lot runoff and noncontact
cooling water from air conditioners to the LDW is low (Ecology 2004c). The
City and the Port have also conducted source control-related activities, including the
implementation of drainage controls, independent cleanup actions, catch basin 
monitoring, and bank stabilization of the T-117 shoreline. SubsequentOngoing source
evaluation work by the Port and other SCWG members includes ongoing
groundwater monitoring and the evaluation of the stormwater drainage system
design and monitoring at the Marina. All of these post-SCAP activities and results are
discussed in Section 2. SCAP activities identified but not yet completed include the
verification of compliance with the NPDES permit requirements and the verification of
catch basin drainages and discharge locations, connections to the sanitary sewer, and
the presence of any septic systems. Ecology recently identified the ongoing EE/CA
process as the principal vehicle for advancing source control for the T-117 EAA
(Ecology and SAIC 2008). 
5.2   POTENTIAL POST-NTCRA RECONTAMINATION SOURCES AND PATHWAYS 
The interrelationships between the potential pathways and associated source areas
that may affect the post-NTCRA T-117 EAA are complex. Since the cessation of asphalt
manufacturing operations in the mid-1990s, the potential for recontamination of soils 
has largely been restricted to the redistribution of existing contaminants. The NTCRA
removal action described in this EE/CAs isare expected to remove the potential for
recontamination to upland, street, and yard soils from this historical source. Thus, this
section focuses on the potential for recontamination of post-NTCRA sediment. 
Figure 5-1 provides an overview of the potential sediment recontamination routes
relevant to the T-117 sediment area after completion of the removal action. The T-117
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Upland Study Area and the Adjacent Streets and Residential Yards Study Area are
either adjacent to or upgradient of the T-117 Sediment Study Area, which is located
between RM 3.5 and RM 3.7 on the west side of the waterway within the LDW
Superfund Site. The neighboring Marina and Basin Oil property are not 
geographically within the T-117 EAA but are considered to be potential upland source
areas (referred to as RAAs). Although the NTCRA will not include the cleanup of
these areas, they are evaluated in this EE/CA relative to their potential to contribute to
the recontamination of the T-117 Sediment Study Area. and are thus included in this
analysis inasmuch as they may serve as potential sources of recontamination to the
EAA. The scope of work for the NTCRA (EPA 2007c) also stipulates that the RAAs
must be considered in view of their recontamination potential. 









ia
Deposition of airborne contaminants has been theorized for the T-117 EAA. King County (2008) has measured
airborne deposition at various locations within the Duwamish corridor. However, no data are currently available
to determine if urban and industrial sources not within the T-117 EAA are impacting the T-117 EAA and the
rate at which airborne contaminants may be deposited at the site. 
Figure 5-1.  Overview of post-NTCRA potential sediment recontamination
source areas and routes at the T-117 EAA 

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Potential sources of COCs and pathways to the post-NTCRA T-117 EAA sediment 
discussed in this section include: 
Erosion and transport of onsite surface soil not isolated after the completion of
the removal action 
Erosion and transport of surface or subsurface soil from adjacent properties 
Transport of contaminants via stormwater (including entrained soil/sediment
and airborne contaminants) 
Migration and discharge of onsite and offsite contaminated groundwater from
the T-117 EAA and RAAs to LDW sediment 
Transport and deposition of LDW sediment (upstream contributions and
impacts from other removal actions)Transport and deposition of LDW
sediment, including upstream contributions, and potential impacts from other
nearby in--water actions that may occur prior to the implementation of the
LDW remedy (e.g., a RCRA action or interim measure that addresses sediment
adjacent to Boeing Plant 2) 
Sorption from LDW surface water 
Atmospheric deposition to the water surface and to surfaces in contact with
stormwater discharging to the river 
The section is organized to first present the more localized potential sources and
pathways (e.g., soil, groundwater) followed by larger-scale potential sources and
pathways (e.g., upstream sediment, atmospheric deposition). The order in which the
information is presented does not necessarily imply the relative importance of the
pathway. Figure 5-2 presents a conceptual view of the potential pathways that are
discussed further in this section. 






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Slipsheet for (11x17) 

Figure 5-2. T-117 EAA possible post-NTCRA recontamination routes 
















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5.2.1  Erosion and transport of surface soil 
This section provides a discussion of the potential for sediment recontamination via
surface soil erosion from each of the upland source areas, including the T-117 Upland
Study Area, Adjacent Streets and Residential Yards Study Area, the Marina, and Basin
Oil property. Post-NTCRA T-117 EAA sediment could potentially be recontaminated
through bank erosion and stormwater transport of contaminated surface soils from
upland source areasnot otherwise addressed through the removal action or postremoval
action monitoring and controls. 
5.2.1.1   T-117 Upland Study Area soil 
As part of the T-117 EAA NTCRA, contaminated surface, shallow subsurface, and
bank soils will be removed and disposed of offsite, and the removal areas will be
backfilled with clean soil or covered with clean fill or capped if they are located within
the intertidal area. Therefore, upon completion of the NTCRA, the potential for any
remaining soils from the T-117 Upland Study Area to impact LDW sediment quality
will be significantly reduced if not eliminated. 
Residual contaminants, if present, would be located at depth and are expected to be at
concentrations below their respective RvALs or will be capped. Measures will be taken
to isolate any remaining subsurface contaminants that might be exposed through
modified site topography. This isolation will be achieved through soil excavation and,
where necessary, through the placement of clean, imported backfill materials to
establish the post-NTCRA topography. This removal and isolation action is
particularly important in areas where the final site use may include enhanced aquatic
habitat and where the upland topography will be lowered to increase the intertidal
surface area. In summaryThus, the NTCRA willis being designed to ensure the 
effective long-term isolation of any remaining contaminants in soils in the T-117
Upland Study Area. 
5.2.1.2   Adjacent Streets and Residential Yards Study Area soil 
The adjacent streets and residential yards that have been cleaned up are expected to be
minorimal sources of PCB contribution to the T-117 Sediment Study Area. Soil from
some yards with elevated dioxin/furan concentrations will not be removed as part of
this cleanup action. PCB and dioxin/furan concentrations are elevated around two of
the T-117 Upland Study Area catch basins (CB-3 and CB-5). To date, the source of
these contaminants has not been identified, and further investigations is being
conducted. The possibility that the contaminants may have come from the Adjacent
Streets and Residential Yards Study Area has not been ruled out. When the removal
action in the Adjacent Streets and Residential Yards Study Area is complete, the
concentrations of contaminants in stormwater that dischargesing to the T-117
Sediment Study Area may resemble those in stormwater from similar LDW
stormwater sub-basins. This possibility will be confirmed through subject to empirical
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sampling verification. The erosion of surface soils from yards and unpaved street
shoulders in the Adjacent Streets and Residential Yards Study Area, with subsequent
transport to the T-117 Sediment Study Area or CSS, has also been identified as a
potential post-NTCRA recontamination pathway. Although soils entrained in
stormwater flows could reach the LDW through various storm drain systems that
discharge to the waterway (see Section 5.2.2.2), this post-NTCRA pathway is expected
to be minimal because of street pavement and vegetative cover in the yards. 
Recent independent cleanup actions for the Adjacent Streets (Integral 2006b) have
included the paving of streets and either the paving of the gravel shoulder areas or
removal of contaminated material in the unpaved road shoulders and replacement
with clean gravel. NTCRA cleanup actions for the Adjacent Streets will include the
removal and offsite disposal of remaining contaminated soil. Where soil is removed,
these areas will be backfilled with clean soil resulting in the attainment of RvALs in
the remaining surface or near-surface soil. Upon completion of the NTRCA, the
majority of the Adjacent Streets will be repaved and curbed to meet current City
design standards, greatly minimizing the potential for the transport of residual
low-level surface soil contaminants from this area. In addition, these actions should
greatly limit the potential for wind-erosion of surface soils. 
5.2.1.3   South Park Marina soil 
In 2007 and 2008, Ecology collected soil, sediment, and groundwater samples at the
Marina. As described in the subsequent recontamination assessment report (SAIC
2009), the sampling focused on the location of a former disposal pond associated with
the former A&B Barrel recycling facility on the Marina property. Work included the
advancement of 16 soil borings to depths that rangeding from 2.5 to 20 ft. Ecology
reported a number of exceedances of MTCA CULs as well as draft soil-to-sediment
and groundwater-to-sediment SLs developed by Ecology for COCs at the Marina.
Subsequent to this data collection work and initial screening, Ecology concluded that
the potential for these COCs to reach the LDW was not clearly established. For 
example, groundwater showed only limited exceedances of Ecology's CULs and draft
SLs. As stated in the recontamination assessment report (SAIC 2009), river bank soil 
samples also had a number of exceedances, but the link between these COCs and
those in the intertidal sediment was uncertain. In order to evaluate and resolve these
uncertainties, a sediment recontamination assessment was conducted (SAIC 2009). 
completed a sediment recontamination assessment for the Marina (SAIC 2009) based
on the results of soil, groundwater, and sediment sampling activities conducted in
2007 and 2008. The investigation identified a number of contaminants with
concentrations in soil that exceeded MTCA CULs and draft soil-to-sediment and
groundwater-to-sediment SLs used by Ecology and described in the investigation
report (SAIC 2009). The sampling focused on the location of a former disposal pond in
the vicinity of the Marina and included the advancement of 16 soil borings to depths
ranging from 2.5 to 20 ft. Although the presence of elevated contaminant
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concentrations in upland soil was documented, it was unknown whether these soils
could migrate to the LDW. Therefore, a quantitative recontamination assessment was
undertaken using a conservative fate and transport analytical model (SAIC 2009).
Results showed that any potential erosion and transport of COCs in soils from the
Marina would have little effect on COC concentrations in the post-NTCRA T-117 EAA
sediment. Table 5-1 presents the soil and groundwater COCs identified and evaluated
by Ecology in their source control study of the Marina. 
Table 5-1.  Concentrations of Contaminants of concern COCs identified by
Ecology for at the Marina compared with T-117 Upland Study Area
removal action levels 
Maximum     T-117 Upland      Maximum      T-117 Upland
Concentration in     Study Area    Concentration in Soil     Study Area
a                                         a 
Groundwater (ug/L)   Groundwater        (mg/kg)        Soil RvALs
b                                             b 
COCs      Min     Max    RvALs (ug/L)    Min      Max      (mg/kg)
Metals 
Arsenic          1.56       8.07          5           1.0       9.410.8        7.3 
Cadmium       0.022     0.091       NSns       0.021      31.4        ns 
Chromium       1.31      40.4       NSns       6.04      465        ns 
Copper         2.83      9.83        3.4ns        5.43       198         ns 
Lead           0.192     0.519        ns         1.18      3180        ns 
Mercury        0.00115    0.001569       ns         0.004      29.5         ns 
cb
Silver            0.01 U      0.005          1.9          0.038       0.299        2.0/400
Zinc             2.93       5.2          ns          14.8       1,510         ns 
PCBs 
d
Total PCBs       0.2 U     0.21 U        0.01        0.0059       36       0.65/1.0
PAHs 
cPAH TEQ       nc      Unc       0.15       0.0017     1.01      0.14008 
TPH 
Gasoline-range
U         ns                  U         ns 
organics 
Diesel-range                                                            e
0.2 U     0.21 UU        500         1.8 U     2312,000 J     200/2,000 
organics 
Residual-range                                                         e
0.2 U     0.21 UU        500         6.5 U     2127,000 J     200/2,000 
organics 
a 
Source: SAIC (2008). 
b 
Soil RvALs as defined in Section 4. 
c
The TEE-based RvAL is 2.0 mg/kg in the upper 0 to 6 ft of soil for areas where the terrestrial ecological
exposure scenario defined under MTCA is applicable. The RvAL is 400 mg/kg for soils deeper than 6 ft. 
d
TEE-based RvAL is 0.65 mg/kg in the upper 2 ft of soil for areas where the terrestrial ecological exposure 
scenarios defined under MTCA is applicable. The RvAL is 1.0 mg/kg for soils deeper than 2 ft. 
e
TEE-based RvAL is 200 mg/kg in the upper 0 to 6 ft of soil for areas where the terrestrial ecological exposure 
scenario defined under MTCA is applicable. The RvAL is 2,000 mg/kg for soils deeper than 6 ft. 
COC  contaminant of concern               RvAL  removal action level 

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DDD  dichlorodiphenyldichloroethane           SAIC  Science Applications International Corporation 
DDE  dichlorodiphenyldichloroethylene          SVOC  semivolatile organic compound 
DDT  dichlorodiphenyltrichloroethane            TEE  terrestrial ecological evaluation 
MTCA  Model Toxics Control Act              TPH  total petroleum hydrocarbons 
nc  not calculated                          U  not detected at given concentration 
ns  not specified                           VOC  volatile organic compound 
PCB  polychlorinated biphenyl 
Ecology's recontamination assessment (SAIC 2009) considered the erosion of bank
contaminants and the migration of COCs in groundwater to LDW sediment. The
recontamination assessment concluded that COCs associated with soil at the Marina 
might cause recontamination of the LDW if soil particles were to eroded and be
transported to the LDW by stormwater. The owners of the Marina recently provided a
map of the storm drain system at the Marina (Crow 2010). The quality of storm solids
in the facility's catch basins that could eventually be transported to the T-117 Sediment
Study Area will be assessed during the removal action design phase (See Section 9.4). 
If the stormwater pathway is determined to poses a risk of sediment recontamination,
additional soil erosion and/or stormwater controls or monitoring will be required.
These will be developed in cooperation with the Marina owner and in consultation
with Ecology. 
5.2.1.4   Basin Oil property soil 
Ecology initiated an investigation of surface and subsurface soil and groundwater
conditions at the Basin Oil property in 2009 through the collection of 10 soil borings to
depths of 14 to 16 ft at various locations throughout the property (see discussion of
Basin Oil investigation sampling locations and results in Section 2.4.1). Soil samples
from the 0-to-6-in. depth were analyzed, and many of the COCs identified for the T--
117 Sediment Study Area (PCBs, TPH, PAHs, phenol) were detected. Boring logs from
the investigation indicated the presence of slight to moderate sheens at some borehole
locations in shallow soils (1 to 2 ft) and again at the 7-to-8-ft depth range. These sheens
were likely associated with the detectable organic vapors recorded using field
instrumentation, as noted on the boring logs. Soil samples from the near-surface
interval (0-to-6-in. depth) and the deepest interval from each boring were submitted
for analysis; the remaining samples were archived. 
Petroleum hydrocarbons (i.e., diesel, lube oil, and gasoline-range organics) were
detected in the near-surface soil samples, particularly at boreholes BSB-6 through BSB-
10. PAHs were also detected in the shallow soil from borehole BSB-1. Gasoline-range
organic compounds and LPAHs were detected in shallow soil samples from BSB-7 and
BSB-10. Other contaminants detected at the Basin Oil property included PCB Aroclor
1260, BEHP, arsenic, and dioxins and furans. As described in Section 3.3.4, Basin Oil
groundwater and soil data (Ecology 2009b) were screened using the SLs developed for
the T-117 EAA in Section 3.3.2. Concentrations of arsenic, total PCBs, TPH, nickel,
cPAHs, ethylbenzene, xylenes, and carbazole were greater than their respective SLs in
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Basin Oil soil. However, the concentrations of these contaminants were below soil
RvALs (Section 4.3.3), and thus, the contaminants from this RAA do not pose a
potential for recontamination of T-117 soil. No PCB concentrations were detected in
surface soil, and the highest dioxin/furan TEQ was 1.59 ng/kg; thus, the contaminants
from this RAA do not pose a potential for recontamination of T-117 sediment. 
5.2.1.5   Soil pathway summary and post-NTCRA monitoring recommendations 
The activities to be completed as part of the NTCRA as well as those planned for the
Adjacent Streets and Yards are expected to eliminate the potential for surface soils to
recontaminate post-NTCRA T-117 EAA sediment at concentrations above the
proposed RvALs. In addition, evaluations of recontamination potential from soils
from the Marina and Basin Oil property indicated a low potential for LDW PCB
recontamination of T-117 sediment recontamination from these sources. A plan for
monitoring stormwater solids and sediment quality after the removal action will be
developed and implemented. The plan will include adaptive management response
measures to be implemented in the event monitoring data indicate the potential for
sediment recontamination. 
5.2.2  Stormwater transport 
As discussed in Section 5.2.1, one pathway for contaminants to reach the T-117
Sediment Study Area is via stormwater runoff. Urban runoff carries contaminants
from various sources, including soil, fertilizers and pesticides from yards and gardens, 
spills, drips from automobiles, tire wear, road surface wear, and atmospheric
deposition. Available information regarding stormwater runoff from the T-117 Upland
Study Area, Adjacent Streets and Residential Yards Study Area, the Marina, and Basin
Oil property is discussed below. 
5.2.2.1   T-117 Upland Study Area stormwater 
Historically, contaminated surface soils within the T-117 Upland Study Area likely
served as a source of contamination to the LDW via several pathways, including the
stormwater pathway (Ecology 2005a). More recently, much of the T-117 Upland Study
Area, except the upper bank area immediately east of the edge of the T-117 Upland
Study Area pavement, has been paved, isolating most of the underlying contaminated 
soils from stormwater. In the future, and as discussed above in Section 5.2.1.1, planned
NTCRA actions will include the removal of upland soils with COC concentrations
greater than the RvALs followed by backfilling or capping with clean materials. 
Nevertheless, stormwater runoff will continue to originate on the surface of the T-117
Upland Study Area. This runoff will discharge to the LDW through existing or newly
constructed conveyances, swales, and outfalls; via sheet flow or infiltration through
permeable surfaces (e.g., vegetated or gravel-covered shoreline areas). Stormwater 
could become contaminated through the deposition of regional airborne contaminants
(as discussed in Section 5.2.6) or as a result of future onsite activities. 
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PCBs, PAHs, dioxins and furans, and some metals were detected in recent (2009)
solids samples collected within and adjacent to catch basins CB-3 and CB-5 (Map 2-1). 
Some of the contaminants (i.e., PCBs and PAHs) in theThe contaminated solids
adjacent to the catch basin could have potentially originated from atmospheric
deposition because these same contaminants have been observed in atmospheric
deposition samples elsewhere in the Duwamish corridor (King County 2008) or from
surface soil at the top of within the T-117 unpaved bank at the east side of the T-117
Upland Study Area. The NTCRA will remove any T-117 Upland Study Area sources 
through the remediation of contaminated surface soils. In addition, new drainage
systems for the T-117 Upland Study Area will be designed to include BMPs for
retaining solids (e.g., sumps, swales, or filters) and will be required to meet the City
code as described below for the Adjacent Streets and Residential Yards Study Area. 
Solids that accumulate in these new drainage systems will also be monitored for COCs
as described further in Section 9.4 
5.2.2.2   Adjacent Streets and Residential Yards Study Area stormwater 
Following cleanup of the Adjacent Streets and Residential Yards, a permanent
drainage system will be constructed to collect and treat runoff from the approximately
1.7-ac area that is currently served by the temporary system that was installed by SPU
as part of the interim cleanup that occurred in December 2004 (Map 2-2). This area
includes approximately 1.1 acres of public ROW in the triangle-shaped area formed by
the intersections of 17th Avenue S, Dallas Avenue S, and S Donovan Street, as well as
about 0.6 acres of private property (Basin Oil and the hillside adjacent to S Donovan
Street). Treated runoff from this area will be discharged to the T-117 Upland Study
Area as it was prior to the 2004 interim cleanup. Runoff from the Residential Yards 
outside this area that will be affected by the cleanup will continue to be discharged to
the combined sewer system (Map 2-2). 
Samples collected to date from streets and catch basins adjacent to T-117 indicate that
except for PCBs, the concentrations of other LDW contaminants of concern are
comparable to those found in urban streets and storm drains sampled throughout the
LDW. As described in Section 2.3.3.1, elevated concentrations of PCBs were found in
ROW soils in 2004, which led SPU to conduct an interim action to protect residents in
the area from being exposed to PCBs by removing and/or capping the PCB-
contaminated soil. Recent samples collected from the temporary drainage system
indicate that the 2004 interim cleanup has been effective in containing PCBs. Table 5-2 
compares the results for sediment samples collected from catch basins in roadways
adjacent to T-117 with the results from 124 to 133 ROW catch basins throughout the
LDW (number of samples varies depending on the parameter analyzed). These LDW
ROW catch basin samples are considered to be representative of the stormwater solids
that will originate from the roadways in the vicinity of the T-117 EAA following the
NTCRA. As shown in Table 5-2, concentrations in samples from the temporary storm
drains generally fall within the lower range of concentrations detected in other
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roadway samples. The samples collected from the Dallas Avenue S storage tanks
contain higher levels of metals, but because these samples contained a large amount of
rust from weathering of the tanks, they are probably not representative of metals
concentrations in the roadway solids.
















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Table 5-2.  Stormwater sampling results 
T-117 Temporary Storm Drain System Sampling Locations and Dates          Lower Duwamish ROW Catch Basinsc 
Concentrations 
CB3-DAL   SW1/    SW1/                         Concentrations 
CB1-DAL  CB2-DAL  CB2-DAL   (CB)    Tanks    Tanks   RCB 101  CB4-DAL 
b
SQS/   CSL/    (CB)     (CB)     (CB)    03/22/05   (Tank)    (Tank)    (CB)     (CB) 
b       b             a                          b
Contaminant   Unit    LAET   2LAET  03/22/05  03/22/05  03/10/10    05    02/25/08   03/10/10  03/14/07  03/10/10   n   Min   Max   Median  Mean 
Arsenic      mg/kg dw    57     93      na       na      10 U      na       20      30 U      7 U       8     129    3     750      9      18 
Copper     mg/kg dw   390    390     na      na      147      na      472     284     50.6     143    128   9.1   4,520    99    168 
Lead      mg/kg dw   450    530     na      na     237 J     na      450     250 J     22      67J    129   4    3,690    89    168 
Mercury     mg/kg dw   0.41    0.59     na      na      0.08      na     0.08 U     0.33     0.05 U     0.04    129   0.02    2.2     0.07    0.17 
Zinc        mg/kg dw    410     960      na       na      571      na      1,890     1,040      237      588     128   58    3,650    333     464 
TPH diesel  mg/kg dw  2,000d   nc     na     na     530     na     na     900    730 U    75U   124   35   6,800   370    917 
TPH  oil    mg/kg dw  2,000d   nc     na     na    2,300    na     na    3,500    4,100    550   124  110  20,000   2,350   3,669 
Total LPAH   g/kg dw   5,200   13,000    na      na     3,270 J     na      120     1,100 J    180 J     110    133   14   8,900    310    895 
Total HPAH   g/kg dw   12,000  17,000    na      na     8,060 J     na     1,272    7,480 J    1,160    1,226 J   133   42   36,520   1,603   3,768 
BEHP     g/kg dw  1,300   1,900    na     na    21,000    na    6,200   18,000   2,500   1,600 J   126   24   36,520   1,957   3,977 
Total PCBs   g/kg dw    130    1,000    23,000    14,000    420 NJ    3,900     350     620NJ     310     560 NJ   133   10   23,000    64     670 
a    Catch basins cleaned after sampling. 
b    Same as CB4-DAL. 
c    Samples collected from catch basins located in the right-of-way throughout the Lower Duwamish Waterway study area. Non-detected values are included in the summary statistics
at their detection limits. 
d    MTCA Method A soil CUL for unrestricted use. 
BEHP bis(2-ethylhexyl) phthalate                            LPAH  low-molecular-weight polycyclic aromatic hydrocarbon 
CB catch basin                                   N  tentative identification (presence or identity of the analyte is in doubt and the
CSL cleanup screening level                                  reported concentration is estimated) 
CUL cleanup level                                    na  not analyzed 
dw dry weight                                        nc  no criteria 
HPAH high-molecular-weight polycyclic aromatic hydrocarbon                PCB  polychlorinated biphenyl 
J  estimated concentration                                          ROW  right-of-way 
LAET lowest apparent effects threshold                            SQS  sediment quality standards 
2LAET second lowest apparent effects threshold                       U  not detected at given concentration 
Boldidentifies detected concentrations. 

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As discussed in Section 2, runoff from the portion of the Adjacent Streets and
Residential Yards Study Area located just east of 17th Avenue S (approximately
1.7 acres) is a potential post-NTCRA recontamination pathway to the T-117 Sediment
Study Area (Figure 5-2). Runoff from this area is currently collected and conveyed by a
temporary stormwater system to storage tanks, where it is subsequently released at a
controlled rate to the CSS at 17th Avenue S and S Donovan Street (Section 2.2). The
City obtained discharge authorization from the King County Industrial Waste
Program for this discharge; as part of the authorization, SPU tests the quality of water
discharged to the CSS every month in which discharges occur. Since 2005, PCBs have
been detected once (in January 2008) in the runoff collected by the temporary system
at a concentration of 0.12 g/ L (Appendix C). This detection does not represent a
recontamination concern to the LDW because it is an isolated detection and the
reported concentration was only slightly above the method detection limit. The
majority of the stormwater represented by this sample was discharged to the CSS,
which is conveyed to the County's wastewater treatment plant. 
After the NTCRA, the temporary stormwater system will be replaced with a
permanent collection and treatment system, and runoff from the entire area currently
served by the temporary system will be discharged to the LDW in the vicinity of the
T-117 EAA. The new system will be designed in accordance with the SMC 22.800 and 
the Seattle Department of Planning and Development Director's Rules (City of Seattle
2009a), which establish specific requirements and procedures for designing and
constructing facilities that treat stormwater prior to release to adjacent surface waters.
The potential for runoff from the Adjacent Streets and Residential Yards Study Area to
be a significant source of recontamination to post-NTCRA T-117 EAA sediment is
therefore considered to be limited by the above-described controls. In addition,
previous remediation efforts at residential yards and planned paving upgrades will
greatly limit the potential for stormwater contamination from this area, thus
controlling contaminants that might otherwise reach post-NTCRA T-117 EAA
sediment at concentrations above selected RvALs. Runoff from the remainder of the
Adjacent Streets and Residential Yards Study Area (generally west of 17th Avenue S)
is directed to the CSS, which occasionally overflows to the LDW. The nearest CSO
(operated by the County) is located at 8th Avenue S and discharges to the LDW 
approximately 3,800 ft downriver of the T-117 EAA. County records show that this
CSO has not overflowed in the past 10 years. 
Contaminants from this area (primarily from the road shoulders on 16th Avenue S and
S Donovan Street) could become entrained in stormwater that discharges to the CSS.
Although the cleanup is expected to significantly reduce or eliminate PCB discharges
to the CSS, it is likely that TPH, PAHs, and metals, which are commonly found in
urban runoff in the Study Area and other urban areas in the vicinity, will remain at
concentrations typical of urbanized environments. 

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Page 165

After the cleanup and removal of PCB-contaminated soil in the ROW, runoff from the
Adjacent Streets is expected to be similar in quality to runoff from other urban areas
and as such can be managed in accordance with existing City stormwater
management program/policies and the City's NPDES municipal stormwater permit.
In 2009, the City updated its stormwater code (SMC 22.800) and associated technical
manuals (City of Seattle 2009a) to comply with its NPDES permit. Ecology has
reviewed and approved both as being equivalent to the Stormwater Management
Manual for Western Washington (Ecology 2005b). 
The method of treating runoff from the Adjacent Streets will be determined during
design. Options include biofiltration swales, filter strips, bioretention cells, wet vaults,
and media filtration. These treatment technologies have all been approved by Ecology
for urban stormwater treatment and are considered to be effective in removing 80% or
more of the total suspended solids present in stormwater (Ecology 2005b). Because
many of the pollutants typically found in urban runoff (e.g., metals, petroleum
hydrocarbons and other organic compounds) are hydrophobic and tend to adsorb to
particulates, these treatment systems are also effective in removing other pollutants.
Considering that treatment will be applied and given the relatively small drainage
area (1.7 ac), the post- project stormwater pollutant loadings to the T-117 Sediment
Study Area from the Adjacent Streets will be low. Therefore, the potential for T-117
sediments to recontaminate after cleanup is expected to be low. 
Post-remedial monitoring of the T-117 Sediment Study Areas and stormwater solids 
will provide an indication of how effective upland actions in the Adjacent Streets and
Residential Yards Study Area have been. For all contaminants, not just PCBs,
stormwater monitoring results will be compared with a range of regulatory and
guidance values to evaluate the presence and relative scale of this line of evidence and
the potential for recontamination. Decisions regarding the need for additional source
control, such as increased BMPs or additional treatment, will be made in consideration
of needed load reduction estimates. 
5.2.2.3   South Park Marina stormwater 
Ecology's sediment recontamination assessment of the Marina (SAIC 2009) evaluated
the potential for post-NTCRA T-117 EAA sediment to be recontaminated by COCs
identified at the Marina through erosion and groundwater the stormwater discharge 
pathway. The quantitative assessment used an analytical model, which generally
concluded that the stormwater transport of COCs from the Marina has had and will
continue to have little effect on COC concentrations in T-117 EAA sediment. Although
the assessment did not specifically include the sampling of solids from the Marina
catch basins,Thus, COC loading from the Marina is expected to be minimal, in part
because the southern-most catch basin at the Marina discharges through a general
stormwater NPDES-permitted shoreline outfall fitted with an oil/water separator and
a sand filter (StormwateRx) (see Section 2). Required monitoring of this outfall by the

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Marina owner will provide limited information to support the assessment of this
potential pathwaye long-term effectiveness of the NTCRA. I However, it is generally
recognized that NPDES monitoring may not always address all COCs that may need
to be considered to protect LDW sediment. Post--NTCRA monitoring of the T-117
sediment removal area should detect recontamination that may originate from this
potential source. 
The stormwater system at the Marina has not been completely mapped, and this is
currently a data gap relative to the complete evaluation of this RAA. Additional work
will be performed prior to the NTCRA to characterize the stormwater conveyance
system at the Marina and to verify stormwater drainage areas and points of discharge
(i.e., to the LDW or the CSS). 
5.2.2.4   Basin Oil property stormwater 
Information regarding the quality of surface soil at the Basin Oil property is provided
in Section 2.4.1. As discussed in Section 5.2.1.4, petroleum hydrocarbons and other
contaminants were detected in surface and near-surface soil samples collected by
Ecology. Currently, runoff from the property is largely contained onsite because of
excavation activities that have prevented most runoff from exiting the property. Only
the driveway entrances currently drain offsite. In the future, unconfined contaminated
surface soil, contaminants associated with future activities at this site, or airborne
deposited materials at the Basin Oil property will have the potential to reach the post-
NTCRA T-117 EAA sediment via the storm drain infrastructure planned for portions
of the Adjacent Streets and Residential Yards Study Area. This new stormwater
conveyance will eventually discharge to the LDW in the vicinity of the T-117 Sediment
Study Area. In order tTo prevent potential sediment recontamination, contaminated
surface and subsurface Basin Oil soil s at the Basin Oil property must be addressed
bywill be cleaned up (e.g., by removal or capping) before the NTCRA. If this is not
feasible and soil can only be addressed post-NTCRA, additional care and source
control measures will be needed. Once the site owner (e.g., through removal, capping)
in consultation with Ecology before the NTCRA occurs. When these soils have been
addressed, it is expected that the property will be a minimal source of contamination
to sediments. 
5.2.2.5   Stormwater pathway summary and monitoring recommendations 
TThe preceding discussions indicate that it is unlikely that post-NTCRA T-117 EAA
sediment will be contaminated at concentrations above the RvALs as a result of
stormwater discharge. New stormwater systems installed at the site will be required to
meet the treatment requirements of SMC 22.800 and the SPU Director's Rule 20-005
(SPU), 17-2009 (DPD) (City of Seattle 2009a) that sets forth specific source control
measures under the code. 

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Storm drain solids in the new stormwater system will also be monitored to verify that 
site-related contaminants are not present at elevated concentrations. The potential for 
the enrichment of contaminants in the finer-fraction soils and the increased potential
for the transport of fine-grained materials will be considered in the selection of
monitoring and analytical approaches. Planning for this monitoring will be included
in the long-term post-NTCRA monitoring plan for the T-117 EAA. Monitoring in the
Adjacent Streets and Residential Yards Study Area may be supplemented by
accomplished as part of the City's source- tracing program, which that is conducted in
collaboration with the LDW SCWG. Details of the monitoring program for the T-117
EAA will be tailored to the specific design of the stormwater conveyances. In addition,
T-117 EAA sediments in the vicinity of stormwater discharges may will be monitored
as part of the long-term sediment monitoring plan. 
5.2.3  Groundwater discharge 
After completion of the NTCRA, groundwater will continue to discharge to the T-117
Sediment Study Area and could potentially be a pathway for recontamination of post-
NTCRA T-117 EAA sediment. The potential for this pathway to recontaminate post-
NTCRA sediment is discussed in detail in Appendix B and summarized in the
following subsections. 
5.2.3.1   T-117 Upland Study Area groundwater 
As part of the NTCRA, contaminated surface and subsurface soil will be removed
from the T-117 Upland Study Area to meet the RvALs at the specified compliance
depths detailed in Section 4. This removal will greatly reduce the potential for residual
soil contaminants to partition to groundwater. Even under current conditions at the T-
117 Upland Study Area, the potential for contamination of sediment via groundwater
discharge is low (see Appendix B), and this will be verified through groundwater
monitoring (see Section 5.2.3.5). These empirical data and lines of evidence
demonstrate that groundwater is not causing sediment recontamination under current
conditions. It can therefore be inferred that groundwater will not result in sediment
recontamination after contaminated soils have been removed from the upland site. 
5.2.3.2   Adjacent Streets and Residential Yards Study Area groundwater 
Information on the concentrations of contaminants in groundwater beneath this area is 
limited. However, given the nature and extent of the contamination within the
Adjacent Streets and Residential Yards Study Area (i.e., shallow soils contaminated
primarily with PCBs and dioxins and furans) and the planned removal of
contaminated soil as part of the NTRCA, it is unlikely that water infiltrating through
any exposed soils (i.e., lawns or street ROW soils) will leach contamination to
groundwater (Appendix B). Thus, it is unlikely that contamination transported via the
groundwater pathway from the Adjacent Streets and Residential Yards Study Area
will impact the post-NTCRA T-117 EAA sediment above the RvALs. The need for The
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number and placement of additional wells in Adjacent Streets will be evaluated 
during the NTCRA design phase. 
5.2.3.3   South Park Marina groundwater 
As discussed above, Ecology recently completed a sediment recontamination
assessment of the Marina as part of its lead role for implementing source control in the 
LDW (SAIC 2009). The assessment concluded that groundwater transport from the
Marina is predicted to have little effect on sediment. Sediment sampling in 2008
verified that elevated Marina groundwater contaminants (i.e., arsenic, dieldrin,
tetrachloroethylene [PCE], and mercury) were not elevated in the adjacent Marina 
sediment (SAIC 2008); only PCB concentrations in the Marina sediment were elevated
above the RvALs. 
In addition, a net groundwater flow map (Map 2-75) was prepared for the T-117 
Upland Study Area based on the March 2008 tidal study. This assessment indicated
that groundwater generally travels in an east-northeast direction. Based on
groundwater flow direction and the contaminant distribution at the Marina, it is
unlikely that groundwater is migrating from the Marina to the T-117 Upland Study 
Area. Thus, any COC loading in groundwater from the Marina is not expected to
contaminate T-117 EAA groundwater or recontaminate post-NTCRA sediment at
concentrations above the RvALs. 
5.2.3.4   Basin Oil property groundwater 
Groundwater samples were collected by Ecology from monitoring wells MW-12 and
MW-13, which were installed next to the Basin Oil property on the 17th Avenue S and
S Donovan Street ROWs, respectively (see Map 2-4039, Section 2.4.1). Dissolved
arsenic was detected in all samples at concentrations that ranged from 9.4 to 20.4
g/L. Similar groundwater monitoring results have been reported for downgradient
monitoring wells MW-01, MW-09, MW-10 and MW-11. Arsenic, copper, and BEHP
were detected in one or more wells, and low concentrations of PCBs and TPH-D were
detected in monitoring wells MW-1 and MW-10, respectively, based on recent
groundwater monitoring of these wells by the Port and the City. However, tThese 
concentrations of detected contaminants are not indicative of a concentrated 
upgradient source and thus indicate a low likelihood of recontamination of post-
NTCRA sediment. 
5.2.3.5   Groundwater pathway summary and monitoring recommendations 
Based on available sampling, and monitoring data evaluated in Appendix B, and the
results of independent recontamination analyses for areas upgradient of the T-117
Sediment Study Area, it is unlikely that post-NTCRA T-117 EAA sediment will be
contaminated at levels above the established RvALs via groundwater transport.
Nevertheless, the potential for groundwater transport of COCs to the T-117 Sediment 
Study Area will be considered evaluated during the development of the NTCRA
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design and the long-term effectiveness monitoring program. Post-NTCRA
groundwater monitoring and long-term performance monitoring of the T-117
Sediment Study Area is discussed further in Section 9.5. 
As part of the program, long-term groundwater and sediment monitoring will be
implemented following the NTCRA to ensure that the groundwater flowing to and
through the T-117 Upland Study Area is not a source of recontamination. The
post-NTCRA long-term monitoring program will likely include a monitoring well
network upgradient of the restored T-117 shoreline to monitor groundwater quality
prior to discharge to the LDW. 
5.2.4  In-waterway sediment transport and deposition 
As discussed in Section 5.2, oOne pathway for contaminants to reach the T-117
Sediment Study Area is via transport and deposition of LDW sediment. Sediment may
be transported from upstream areas and/or nearby areas subject to sediment removal
actions. 
The T-117 Sediment Study Area is located in the LDW, an estuarine system that is
influenced by the Upper Duwamish/Green River. A great deal of sediment from this
river is being deposited within the LDW. To estimate the influence of this transport
and deposition on an LDW-wide scale, sediment transport dynamics within the LDW
(including the T-117 Sediment Study Area) have been modeled as part of the LDW RI
to estimate area-specific net erosion rates and maximum scour depths during highflow
events, net sedimentation rates, and bed replacement dynamics (Windward 2008;
QEA 2008). This modeling is currently being used in the LDW FS (ENSR|AECOM
2009) to predict changes in chemical concentrations in sediment over time and can also
be used to estimate the future influence of the Upper Duwamish/Green River on
sediment composition in the river segment (RM 3.5 and RM 3.6) that includes the T--
117 Sediment Study Area. At the end of the 30-year modeling period, 75 to 100% of the
sediment within this segment and the channel-side half of the area between RM 3.6
and RM 3.7 was estimated to be replaced with sediment from the Upper
Duwamish/Green River. Thus, this general area is predicted to take on the
characteristics of the sediment being depositing from the river over Howevertime. 
However, an assessment of sediment deposition or erosion within the spatial scale of
the T-117 Sediment Study Area based on LDW-wide or reach-specific model
predictions hasmay have a high level of uncertainty, and can only should be only be
consideredused as one line of evidence to assess future conditions, and is not a 
substitute for post- removal action sediment monitoring. 
As shown in Figure 5-3, greater than 99% of the sediment load to Reach 2b, where the
T-117 EAA is located, was estimated to come from the Upper Duwamish/Green River
system (QEA 2008). Mean contaminant concentrations in sediment in this upstream

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area (1.7 mg/kg OC total PCBs, 6.8 mg/kg dw arsenic, 51 g/kg dw cPAH TEQ)15 are
much lower than sediment RvALs. Thus, post- NTCRA sediment deposition from
upstream should not result in recontamination of the T-117 EAA to levels that exceed
the selected RvALs. 







Figure 5-3.   Schematic of the net LDW sediment transport processes over a 30-yr
period 
Based on the sediment transport modeling, the T-117 Sediment Study Area was
identified in the LDW RI (Windward 2008) as having the following conditions and 
characteristics: 
Between RM 3.5 and RM 3.6, the sediment area was characterized as a net depositional
environment with a net sedimentation rate > 3 cm/year. From RM 3.6 to RM 3.7 in the
nearshore, the sedimentation rate was estimated to be much lower (0 to 0.5 cm/year). 
The net erosion rate during high-flow events (2- to 100-year flood events) was
estimated to range from 0 to 6 cm/year in the area between RM 3.6 and RM 3.7, with
maximum scour depths up to 6 cm. 
Less than 1% of sediment deposited within the T-117 Sediment Study Area was 
estimated to originate from lateral sources. 
At the end of the 30-year modeling period, 75 to 100% of the sediment between RM 3.5
and RM 3.6 and the channel-side half of the area between RM 3.6 and RM 3.7 was
estimated to be replaced with sediment from the Upper Duwamish/Green River.
15 Note that these concentrations are based on data presented in the RI (Windward 2008); additional
data have been collected since that time and are being evaluated. 
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Thus, this area is predicted to take on the characteristics of the sediment being
depositing from the river over time. 
In contrast, only 0 to 25% of the nearshore sediment between RM 3.6 and RM 3.7 was
estimated to be replaced with sediment from the Upper Duwamish/Green River,
indicating little bed replacement. 
Contaminated areas in the LDW will be addressed through sediment remediation and
source control actions (which could involve actions such as bank remediation)
following the issuance of the ROD for the LDW. However, the relative sequencing of
other actions and the T-117 EAA NTCRA has not yet been established. If areas near or
upstream of the T-117 EAA are addressed after the NTCRA, these actions could
potentially recontaminate T-117 EAA sediment, particularly if these areas are dredged.
Dredging tends to re-suspend sediment, some of which may be transported outside of
the dredging footprint. Sediment transport modeling to specifically assess the
potential for contamination of the T-117 EAA during or following the remediation of
nearby areas has not been conducted. However, it is expected that any remedial
actions carried out at nearby areas will include measures to minimize the potential for
contaminants to spread during remedial actions. Sediment and water quality
monitoring will also likely be required during all remedial activities, and postremediation
monitoring programs willshould be designed to not only assess the
effectiveness of the remedial actions carried out at nearby areas but also ensure that
post-cleanup residuals from those projects do not affect neighboring areas (e.g., the T--
117 Sediment Study Area). 
5.2.5  Surface water transport within the LDW 
Sources of COCs to surface waters of the LDW include maritime activities, which can
occasionally result in releases of fuel and other hazardous materials, and a variety of
other upland/lateral sources, including regional stormwater discharges and CSOs. 
Depending on the location and nature of these releases, they could potentially provide
a source of recontamination to T-117 EAA sediment after the completion of the
NTCRA. 
However, present-day maritime practices, rapid spill response resources, regulatory
requirements, and municipal/industrial wastewater discharge limits have been
established to control and/or eliminate these types of releases to the LDW. Thus, it is
unlikely that they would contaminate post-NTCRA T-117 EAA sediment at levels
above the selected RvALs. This would be verified through a post-NTCRA sediment
monitoring program. 
5.2.6  Atmospheric deposition 
Atmospheric sources of contaminants are generally widespread (EPA 2001);
contaminants are emitted to the air from both point sources (e.g., industrial facilities)
and non-point sources (e.g., motor vehicles, marine vessels, trains) and may be
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transported over long distances, generally in the direction of the prevailing winds.
Contaminants in the atmosphere are deposited to both land and water surfaces
through wet deposition (i.e., precipitation) and dry deposition (i.e., as particles). The
deposition of contaminants from the air directly to a water body (e.g., the LDW)
through either wet deposition or dry deposition is called direct atmospheric
deposition. Although emission sources associated with oil combustion and other
activities were present historically at the asphalt manufacturing facility, no sitespecific
emission sources are currently active within the T-117 EAA. 
Indirect atmospheric deposition of contaminants occurs when contaminants deposited
on upland areas are conveyed to water bodies via stormwater flow. Although not the
only potential source of COCs in stormwater conveyances, contributions from
atmospheric deposition can be detected through the sampling of storm solids and
mitigated through the cleaning of conveyance systems and the application of other
stormwater BMPs. 
In the LDW, the The potential contribution of contaminants via direct atmospheric
deposition on the T-117 Sediment Study Area (approximately 2 ac) is relatively small
compared with the potential contribution via indirect atmospheric deposition on the
upland drainage areas (estimated to be approximately 12 ac, including portions of the 
Marina). For the most part, contaminants deposited on the T-117 upland areas become
entrained in storm solids and are monitored and controlled. because of the relatively
small surface areas of the T-117 Sediment Study Area (approximately 2 acres) and
surrounding LDW study area (441 acres between RM 0 and RM 5) (ENSR|AECOM
2009) compared to the surface area of the Green/Duwamish Watershed (294,600
acres). 
Direct aAtmospheric deposition information hasdata have been collected in the
vicinity of the T-117 EAA by the County (2008) and can be used to evaluate the
potential contribution of contaminants to the T-117 Sediment Study Area from direct
atmospheric deposition. Sixteen rounds of deposition data were collected at the South
Park Community Center (SPCC) atmospheric deposition monitoring station between
2005 and 2007. The SPCC station is the closest monitoring station to the T-117 EAA
and was one of five monitoring stations used by the County in their study of
atmospheric deposition near the LDW. Samples collected at the SPCC station were
analyzed for a number of contaminants, including phthalates, selected PAHs , and
PCB Aroclors, both identified as sediment COCs for the T-117 EAA., and Data from
the SPCC station were converted to atmospheric deposition flux values by the County
(see Table 5-32). Fluxes calculated for other area monitoring stations were similar.16 

16 Together, the SPCC, Duwamish, and Georgetown monitoring stations represent the
commercial/industrial neighborhood conditions in the Duwamish Valley. For comparison, the
average atmospheric deposition flux values (based only on detected results) were: 2.94 g/m2/day
BEHP, 0.95 g/m2/day BBP, and 0.042 to 0.241 g/m2/day for PAHs. In all samples from these three
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Table 5-32. Hypothetical contribution of COCs to T-117 Sediment Study Area 
based on average atmospheric deposition flux rates contribution to
sediment concentrations based on atmospheric deposition flux at
the SPCC station 
Hypothetical Contribution of Direct
Atmospheric Deposition to Sediment
Concentrations over a 1-Year Period by
Average
Sedimentation Rate 
Atmospheric                    b            Sediment
(mg/kg dw): 
Deposition Flux                                   RvAL 
2    a                                                      c
COC        (g/m /day)    0.1 cm/yr    0.5 cm/yr    1 cm/yr   (mg/kg dw)
PAHs 
Benzo(a)anthracene         0.048         0.015        0.003       0.001       1.7 
Benzo(a)pyrene            0.074         0.023        0.005       0.002       1.5 
Benzo(g,h,i)perylene         0.086          0.026        0.005       0.003        0.48 
Total benzofluoranthenes      0.174          0.053        0.011       0.005        3.6 
Chrysene               0.112         0.034        0.007       0.003       1.7 
Dibenzo(a,h)anthracene       0.028         0.009        0.002       0.001       0.19 
Indeno(1,2,3-cd)pyrene        0.051          0.002        0.003       0.002       0.53 
PCBs 
d
Total PCBs              0.011         0.003       0.00066      0.0003       0.19 
a 
Averages were calculated using detected concentrations from only the SPCC station. 
b 
Based on calculations made using the deposition flux values provided in Column 2 and the following
3         3
assumptions: sediment transport deposition rate of 1 cm/yr; sediment density of 1.2 g/cm , or 6g/5cm  (from 
LDW STAR); TOC content of sediment: 2%. Sample calculation for Total PCBs at a sedimentation rate of 0.5 
cm/yr BEHP follows. 
Calculation: 
2                                       2
(0.0112.4 g PCBsBEHP/m /day) x (365 day/yr) = 4.015876 g PCBBEHP/m/yr 
2                                                     3
(4.015876 g PCBBEHP/[m  x yr]) x (1yr/0.51cm) x (100 cm/1 m) = 80387,600 g PCBBEHP/m
3       3        3           3
(80387,600 g PCBBEHP/m ) x (5 cm /6g) x (1m /1,000,000 cm) = 0.000669173 g/g PCBBEHP 
0.00066973 g/g PCBBEHP = 0.00066973 ppm = 0.0006673 mg/kg PCBBEHP (dw concentration) 
OC normalization: (0.073 mg/kg)/(0.02 TOC) = 3.65 mg/kg OC 
c 
Sediment RvALs ias defined in Section 4. 
dc 
Represents single detected concentration of Aroclor 1254 at the SPCC station; no other samples from this
station had detected concentrations of any PCB Aroclors. 



stations, only two PCB Aroclors were detected: Aroclor 1254 was detected in five samples at a range of
0.011 g/m2/day (detected at the SPCC station) to 0.044 g/m2/day (detected at the Georgetown
station). The Beacon Hill station represents urban residential neighborhood conditions. Average
atmospheric deposition flux values (based only on detected results) at this station were: 1.64
g/m2/day BEHP, 0.498 g/m2/day BBP, and 0.012 to 0.090 g/m2/day for PAHs. No PCB Aroclors
were detected in any of the samples from the Beacon Hill station. 
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BBP  butyl benzyl phthalate                      RvAL  removal action level 
BEHP  bis(2-ethylhexyl) phthalate                  SPCC  South Park Community Center 
COC  contaminant of concern                   SQS  sediment quality standard 
dw  dry weight                              STAR  sediment transport analysis report 
CSL  cleanup screening level                    T-117  Terminal 117 
OC  organic carbonLDW  Lower Duwamish Waterway 
PAH  polycyclic aromatic hydrocarbon 
PCB  polychlorinated biphenyl 

Hypothetical Direct
Atmospheric Deposition
Average    Contribution to Sediment 
Atmospheric    Concentration Over
Deposition Flux      1-Year Period        SQS       CSL 
2    a                    B
COC         (g/m /day)       (mg/kg OC)     (mg/kg OC)  (mg/kg OC) 
PAHs 
Benzo(a)anthracene       0.048           0.073               110        270 
Benzo(a)pyrene          0.074           0.113               99         210 
Benzo(g,h,i)perylene        0.086           0.131                31         78 
Total benzofluoranthenes     0.174           0.265                230        450 
Chrysene              0.112          0.170              110        460 
Dibenzo(a,h)anthracene     0.028           0.043               12         33 
Indeno(1,2,3-cd)pyrene      0.051           0.078                34         88 
Phthalates 
BEHP             2.4          3.65             47       78 
BBP               1.5           2.28              4.9       64 
PCBs 
c
Total PCBs             0.011          0.017               12         65 
Using conservative assumptions,17 estimated sediment concentrations for the T-117
COCs based on the average SPCC atmospheric deposition flux values were calculated
17 Conservative assumptions used to estimate sediment concentrations associated with direct
atmospheric deposition: 1) all airborne contaminant mass that falls onto the LDW is sorbed to
sediment, 2) sediment deposition rate of clean sediment is between 0.1 and 1 cm /yr (calculations
were based on three assumed deposition rates of 0.1, 0.5, and 1 cm/year for comparison, and 3)
sediment density is 1.2 g/cm3 (the lower end of the wet sediment density range reported in the LDW
sediment transport analysis report (Windward and QEA 2008)). The calculation used to derive the
hypothetical contributions from direct atmospheric deposition to sediment is considered to be
conservative because it assumes that 100% of contaminants deposited to the LDW surface accumulate
in the sediment. Atmospheric particulate matter is divided into two size classes: fine particulate
matter (less than 2.5 m in diameter [PM2.5]) and coarse particulate matter (between 2.5 and 10 m in
diameter [PM10]). The LDW sediment transport model showed that only 10% of sediment particles
less than 10 m in size (clay or fine silt) are expected to be deposited to LDW sediment. The other 90%
is transported downstream. Particulate matter deposited to the LDW via atmospheric deposition
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(see Table 5-32). The hypothetical contributions from direct atmospheric deposition to
sediment concentrations are all well below the SQS criteria for these chemicals and
thus were less than the RvALs. These results indicate that contributions of
contaminants to sediment from direct atmospheric deposition alone would not be
expected to result in sediment concentrations above the RvALs. 
This type of conservative calculation is acceptable as a screening exercise because it
places the direct atmospheric deposition pathway in context with other potential
pathways and allows an estimation of the importance of this pathway relative to other
pathways and relevant to source control. This type of analysis would not be used to
make decisions about implementing source control measures other than to help
prioritize pathways and sources for additional assessment. Based on available
atmospheric deposition data and the hypothetical deposition contribution from direct
atmospheric deposition, it appears that other pathways are more important for source
control. The potential for recontamination through indirect atmospheric deposition is
more uncertain; periodic sampling of storm solids within the T-117 conveyance
systems will be conducted to assess the importance of this pathway. 
The calculation used to derive the hypothetical contributions from direct atmospheric
deposition to sediment is considered to be conservative because it assumes that 100%
of contaminants deposited to the LDW surface accumulate in the sediment.
Atmospheric particulate matter is divided into two size classes: fine particulate matter
(less than 2.5 m in diameter [PM2.5]) and coarse particulate matter (between 2.5 and
10 m in diameter [PM10]). The LDW sediment transport model showed that only
10% of sediment particles less than 10 m in size (clay or fine silt) are expected to be
deposited to LDW sediment. The other 90% is transported downstream. Particulate
matter deposited to the LDW via atmospheric deposition would be expected to have
deposition rates similar to those of clay or fine silt; therefore, the use of a 100%
deposition rate in the calculation is highly conservative. In addition, a sediment
deposition rate of 1 cm/year is considered to be conservative because the sediment
deposition rate over much of the T-117 EAA is higher than 1 cm/yr. The sediment
density used in the calculations is 1.2 g/cm3, which is considered to be conservative
because it at the lower end of the wet sediment density range reported in the LDW
sediment transport analysis report (Windward and QEA 2008). A higher sediment
density used in the calculations would generate a lower hypothetical contaminant

would be expected to have deposition rates similar to those of clay or fine silt; therefore, the use of a
100% deposition rate in the calculation is highly conservative. In addition, a sediment deposition rate
of 1 cm/yr is considered to be conservative because the sediment deposition rate over much of the T-
117 EAA is higher than 1 cm/yr. The sediment density used in the calculations is 1.2 g/cm3, which is
considered to be conservative because it at the lower end of the wet sediment density range reported
in the LDW sediment transport analysis report (Windward and QEA 2008). A higher sediment density
used in the calculations would generate a lower hypothetical contaminant contribution from direct
atmospheric deposition. 
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contribution from direct atmospheric deposition.Because of the relatively small
quantities of contaminants present in atmospheric deposition samples and the
relatively small contribution of contaminants via direct atmospheric deposition, the
potential for the direct atmospheric deposition pathway to recontaminate
post-NTCRA T-117 EAA sediment is low. The potential for recontamination through
indirect atmospheric deposition is more uncertain; periodic sampling of storm solids
within the T-117 conveyance systems will be conducted to assess the importance of
this pathway. 
5.3   OVERALL SUMMARY AND MONITORING RECOMMENDATIONS 
All of the potential individual recontamination pathways that originate at the T--117
EAA and the RAAs (Basin Oil and Marina) have a relatively low likelihood of
increasing contaminant concentrations in the post-NTCRA T-117 Sediment Study Area
to concentrations above sediment RvALs. The estimated potential for recontamination
is summarized in Table 5-4, and is based on the following factors: 
Potential contribution of contaminants to T-117 Sediment Study Area after 
cleanup from each ongoing source 
Degree of confidence in information regarding the chemical
characteristics/loading from each source or the likely occurrence of an event
that will impact the sediment offshore of T-117, such as a spill 
Table 5-4.   Evaluation of post-removal recontamination risk from ongoing
sources in the T-117 vicinity 
Potential Post-            PotentialLikeli
Rremoval             hood to
Action Impact              Cause
to T-117              Exceedances
Sediment Study  Uncertainty/   of Sediment
a
Source/Pathway          Description             Area      Probability     RvALs 
Runoff from 1.1 ac of road and+ 0.6 ac 
of private property (Basin Oil).
Contaminated soil in ROW to be
removed during the NTCRA. After
Stormwater                                     low        medium       low 
cleanup, runoff will be treated per City
stormwater code (SMC 22.800) using
conventional stormwater treatment
technologies. 
Groundwater      Groundwater discharge to sediment.         low        medium       low 
Spills/over-water    Spills that occur in the vicinity of T-117
high          low          low 
activities           or from adjacent areas. 
Contaminated soil in T-117 upland,
banks and ROW to be removed as part
ab       of NTCRA. RAAs with known soil
Soil erosion                                         low         medium        low 
contamination (i.e., Marina and Basin
Oil) are either paved or will be
remediated by others. 

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Potential Post-            PotentialLikeli
Rremoval             hood to
Action Impact              Cause
to T-117              Exceedances
Sediment Study  Uncertainty/   of Sediment
a
Source/Pathway          Description             Area      Probability     RvALs 
Deposition from local and regional
Direct atmospheric
cb         airshed onto the immediate area               low           highlow          low 
deposition
offshore of T-117. 
In-waterway      Deposition of contaminated sediment
sediment         from sediment cleanup activities           high         low      medium-low 
dc
transport         elsewhere in the waterway. 
Cumulative effects                                 low        medium       low 
a
Uncertainty/probability represents the confidence level in the available data. For event-driven sources (e.g.,
spills and in-waterway sediment), it represents the likelihood of occurrence. 
b 
Soils within the upland areas that drain to the T-117 Sediment Study Area. 
cb
Atmospheric deposition that falls elsewhere on the drainage basin is included under stormwater. 
dc
Cleanup activities elsewhere in the LDW will be tightly controlled to reduce the potential for contaminated
materials to migrate downriver. 
NTCRA  non-time-critical removal action 
RAA  recontamination assessment area 
ROW  right-of-way 
SMC  Seattle Municipal Code 
T-117  Terminal 117 
Each of these factors is qualitatively rated high, medium, or low. These two factors are
then combined to evaluate the overall potential for an individual source to cause
recontamination. Spills and the transport of contaminated sediment from cleanup
activities elsewhere in the LDW have an overall rating of low and medium-low,
respectively, because of the high potential for impacts, but both have a low probability 
of occurrence. For example, the likelihood of a major spill occurring immediately
adjacent to T-117 is fairly low; similarly, the chance of recontamination from upriver
cleanup activities is not expected to be highlow because these cleanups will be tightly 
controlled to minimize the potential for offsite migration of contaminants. 
Groundwater discharges and atmospheric deposition also received medium and low
rankings, respectively. Information regarding atmospheric loading (Section 5.2.6) as
well as groundwater in the proximity of the shoreline is available. 
The quality of groundwater that discharges from the T-117 Uupland Study Area and
Aadjacent Sstreets is expected to improve, primarily as a result of the removal of
contaminated soil located above or in contact with the shallow aquifer. Although little 
is currently known regarding groundwater beneath the Adjacent Streets, additional
pre-design groundwater monitoring will be conducted (Section 9.5) to verify that this
groundwater will not be a future source of recontamination to the post-NTCRA T-117
EAA. 

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Additional groundwater monitoring is also planned to further assess the potential for
groundwater from the Marina and Basin Oil properties to contribute to
recontamination. It is recognized that the data necessary to assess some of the
pathways (e.g., dioxin and furan groundwater data) are limited. These additional
information needs will be addressed through the implementation of measures set forth
in Section 9.4. 
Stormwater discharges and soil erosion are rated low because stormwater will be
treated prior to discharge, which will remove the majority of the solids; and most of
the contaminated soil within the area that drain to T-117 will be removed as part of the
NTCRA. Contaminated soil that remains at the Marina and the Basin Oil properties 
are also not expected to pose a risk for sediment recontamination. 
The Marina was evaluated by Ecology (SAIC 2009), and results of the quantitative
recontamination assessment showed that eroded soil from the Marina would be
unlikely to impact the adjacent T-117 Sediment Study Area. Contaminants in Basin Oil
soil will be addressed through actions by others and overseen by Ecology, ensuring 
that any remaining soil is not subject to erosion and transport at this site.- 
Potential recontamination from transport and deposition of contaminated sediment
from other portions of the LDW has not been addressed. As discussed in Section 5.2.4,
it is inappropriate to apply the LDW STM to the T-117 Sediment Study Area. 
The design phase of the NTCRA will include the design of post-NTCRA stormwater, 
groundwater, and sediment monitoring programs to verify that recontamination of
post-NTCRA T-117 Sediment Study Area does not occur. If it appears that post-
NTCRA contaminant concentrations are increasing, a variety of potential
recontamination sources and pathways will be evaluated, such as, but not limited to: 
Ongoing source control actions in the Adjacent Streets and Residential Yards
Study Area 
Further evaluation of sources and source pathways from the RAAs (the Marina
and Basin Oil) 
Review of groundwater monitoring results for indications of increased COC
concentrations 
Investigation of atmospheric deposition and entrainment in stormwater 
SPU will sample solids in the storm drain system and stormwater in the portion of the
Adjacent Streets and Residential Yards that will discharge at or in the vicinity of T--117
as required by EPA to evaluate whether the removal action and proposed stormwater
treatment system are effective in controlling PCBs and other LDW COCs in the runoff
from this area. An adaptive management strategy will be developed and will phase in
increasingly more aggressive source investigations and, if necessary, an evaluation of

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additional treatment until the source(s) of any future contamination is identified and
controlled. 
Further analysis of airborne particulate loads within the vicinity of the T-117 EAA may
also be necessary in order to further assess inputs from the atmosphere if elevated
COCs are noted in stormwater solids following the implementation of the NTCRA.
Additional source control measures in the vicinity of the T-117 EAA, such as the
completion of the soil cleanup at Basin Oil, are advised to further minimize the
potential for recontamination. Other ongoing LDW-wide source control actions and
information collected by the LDW SCWG member agencies (e.g., SPU stormwater
solids data) will be regularly reviewed as a means of evaluating potential sources in
the T-117 EAA vicinity. This review will occur annually or whenever the LDW Source
Control Work Group publishes an updated source control status report. The post-
NTCRA groundwater monitoring will also be a key element in the evaluation of the
potential for post-NTCRA recontamination of the T-117 sediment. Finally, the timing
and sequencing of in-water LDW cleanups projects (e.g., Boeing Plant 2, Slip 4, South
Park Bridge removal, and the LDW) should be considered. 











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6    Identification, Evaluation, and Screening of Technologies 
This section of the EE/CA considers removal, treatment and disposal technologies that
are suited for implementing the removal action at the T-117 EAA. The cleanup
activities described in this EE/CA focus on sediment and soil removal, so emphasis is
placed upon those technologies that are applicable to those media, are readily
available, and can be implemented within the anticipated NTCRA timeframe. This
section: 
Identifies and provides an evaluation and screening of soil removal
technologies (i.e., excavation) 
Identifies and provides an evaluation and screening of sediment dredging and
capping technologies 
Identifies, discusses, and evaluates treatment and disposal options 
The identification and evaluation of technologies (USACE 2003) takes into account a
broad range of methods, such as the use of multi-user disposal sites that have been
identified by LDWG in Identification of Candidate Technologies for the Lower Duwamish
Waterway (RETEC 2005), hereafter referred to as the Candidate Technologies Report.
This report was designed to help ensure compatibility with remedial technologies that
may eventually be applied within the LDW as a whole. 
The technologies identified in this section of the EE/CA are used to develop the 
removal action alternatives presented in Section 7. These alternatives must be
applicable to all the removal areas within the T-117 EAA as identified in Section 4,
including the T-117 Sediment Study Area, T-117 Upland Study Area, and the Adjacent
Streets and Residential Yards Study Area. Thus, technologies that address submerged
and intertidal sediment as well as upland soil must be included. Removal actions to
address the shoreline and sediment will use a variety of technologies. Figure 6-1 
presents the various shoreline and sediment zones that are described throughout the
rest of this document. 
In addition to the primary removal technology, all alternatives must include
supporting methods needed to prepare the site for the selected removal action and
support the removal activities (e.g., aboveground structural demolition, asphalt
removal, well abandonment, and implementation of site security measures). 
Soil/sediment staging areas and water management systems (for surface water and
groundwater) and other support facilities will also be necessary. A discussion of these
supporting methods is included in the description of each alternative (Section 7). 


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Slipsheet for 8.5 x 11 
Figure 6-1. Locations of zones within the shoreline and sediment 

















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The evaluation and selection of technologies in this EE/CA emphasizes those
technologies demonstrated to be proven and readily implemented at full scale (rather
than research or pilot-scale). An additional key selection criterion includes the
appropriateness of the technology for the size and site-specific conditions of the T-117
EAA, as well as the time frame of the NTCRA. Sediment remediation technologies that
were screened and eliminated in the Candidate Technologies Report (RETEC 2005) for
application in the LDW were not included in this screening. 
General technologies discussed in this section for the T-117 NTCRA include those 
associated with: 
Removal and containment 
Treatment or disposal 
Monitored natural recovery and enhanced natural recovery are not considered to be
applicable strategies for the T-117 EAA because of the elevated concentrations and 
persistent nature of contaminants located in the T-117 EAA Upland and the Adjacent
Streets and Residential Yards Study Areas and the uncertainty regarding low
sedimentation rates estimated for portions of the T-117 Sediment Study Area
(Windward and QEA 2005) within the T-117 Sediment Study Area. 
Some types of institutional controls may be implemented, as necessary, to help ensure
the long-term maintenance and integrity of remediated upland areas and sediment
caps, but institutional controls are not considered to be a substitute for active removal
measures and are not appropriate or sufficiently protective for use at the T-117 EAA if
used as the sole measure for preventing exposure to contaminants. Institutional
controls were not considered for areas where their use would preclude achieving
RAOs. Restrictive covenants may be appropriate in areas where sediment capping is
used to meet sediment RAOs as part of a removal alternative or as a component of
future redevelopment (i.e., construction of upland or intertidal habitat) in order to
prohibit activities that would compromise a cap and potentially release contaminated
materials that remain beneath the cap. However, such controls may be limited and
cannot be used where they might be infeasible (e.g., where they would interfere with
tribal use of the area or could not be effectively implemented or enforced). 
6.1   SOIL AND SEDIMENT REMOVAL AND CONTAINMENT TECHNOLOGIES 
A comprehensive list of potential removal technologies was compiled, reviewed, and
screened against specific criteria (Appendix K); a summary of this evaluation is
presented as Table 6-1. Applicable technologies for the T-117 EAA include those
well-known, proven technologies that can be used for soil and sediment removal (i.e.,
excavation and dredging). Land-based removal technologies are used as a means of
excavating contaminated soil and nearshore intertidal sediment using equipment
positioned on land. Over-water removal technologies include dredging as a means for
removing offshore subtidal sediment. These technologies are effective when used in
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conjunction with procedures and safeguards to limit uncontrolled release of soils and
sediment or excessive turbidity in the LDW during the removal action. 
6.1.1  Land-based technologies 
The primary land-based removal technology under consideration for the T-117 EAA is
excavation. Excavation has already been used as the principal means of removing soil
in the T-117 Upland Study Area (RETEC 2007b) and the Adjacent Streets (Integral
2006a) and is also a viable method for addressing the cleanup of nearshore sediment.
Excavation is typically conducted using backhoes, front-end loaders, and dump
trucks. Supporting methods include shoring (for excavations that are deep or close to
structures), soil stockpiling and containment, dust control, groundwater extraction (for
dewatering deeper excavations), and storing and treating extracted groundwater.
Contaminated soil or sediment can be excavated, placed in lined trucks, and
transported to appropriate treatment or disposal facilities. Truck wheel washing and
inspection are necessary to control soil track-out during excavation work. Excavation
and its supporting methods have been successfully implemented during previous
removal actions and are proven removal methods for this site; they have thus been
retained for inclusion in removal action alternatives. 
Land-based containment technologies (e.g., capping) that require institutional controls
have not been retained for application in the T-117 Upland or Adjacent Streets and
Residential Yards Study Areas have not been retained because they are inconsistent
with the RAO (Section 4.4) of allowing for a range of possible land uses in these study
areas. One exception is the use of clean cover (soil) that would be placed onto cleaned
upland areas as needed for the construction of habitat. As specified in WAC-173-340-
7492(3), an institutional control may be required to ensure that site conditions within
developed habitat areas are maintained and the exposure of species to unacceptable
soil contaminants is prevented. 
6.1.2  Over-water technologies 
This section discusses over-water technologies for addressing contaminated sediment
at the T-117 Sediment Study Area, which are dredging and capping. Both technologies
have been applied elsewhere within the LDW and have been proven to be feasible
methods for removing or containing contaminated sediment. 
6.1.2.1  Sediment dredging 
As mentioned previously, land-based excavation may also be used as a means for
removing contaminated sediment from the intertidal mudflat. This approach could be
implemented without generating excessive turbidity in the water column because
excavation would be conducted "in the dry" during low tides (this process is
discussed in more detail in Section 7.1.1.4). Only the remaining less-contaminated

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subtidal sediment would need to be removed using conventional over-water dredging
methods. 
For subtidal sediment, both mechanical and hydraulic dredging are candidate
technologies. Mechanical dredging involves lowering a bucket or clamshell to the
bottom of the river, excavating the target material, and then lifting the bucket to the
surface. The dredged material is placed onto a barge for transport to an offloading site.
Environmental bucket dredges are equipped with specially designed buckets to
reduce the outflow of contaminated solids during the dredging process. 
The hydraulic dredging process involves using agitation equipment to loosen the
target material from the river bed and then mixing the loosened material with water to
form slurry. A centrifugal pump is used to convey the slurry through a hose or
pipeline to a handling site. Hydraulic dredges for low-volume environmental
remediation can range from small (4-to-6-in.-diameter discharge) diver-guided suction
dredges used for working in and around confined areas to floating cutterhead
hydraulic dredges (8-to-16-in.-diameter discharge) for working in less unrestricted 
areas. Hydraulic dredging would require the development of a large handling site
nearby to dewater the dredge spoils. The resulting solids would then need to be
transported to a disposal facility. 
For the T-117 site, several factors would limit the effectiveness of hydraulic dredging
for sediment remediation, such as: 
Spillage  The cutterhead or auger action associated with hydraulic dredging
would leave a spillage layer of sediment not captured by the dredge. Spillage
layers are composed of a mixture of sediment from the cut face of the dredged
area that is not captured by the hydraulic dredge, with chemical concentrations
similar to the average concentration of the chemical in the dredged material. As
a rule of thumb, the thickness of spillage layer is on the order of half of the
discharge pipe diameter (Palermo et al. 2008). So a 12-in. dredge (12-in.-
diameter discharge pipe) would leave a spillage layer of approximately 6 in.
thick. 
Slurry  Hydraulic dredging generates a slurry that is on the order of 10 parts
water to 1 part sediment. Small hydraulic dredges can generate larger volumes
of water because of the constraints of small working areas. Consequently,
hydraulic dredging requires the mobilization, construction, and operation of a
handling site to manage the slurry generated by a hydraulic dredge, which is
typically only cost effective for long-duration projects or for work that can only
be completed by hydraulic dredging, such as diver dredging around
constrained areas. For example, the remediation of the Thea Foss Waterway in
Commencement Bay used hydraulic dredging because the slurry could be
pumped into a 10- ac placement site (former St. Paul Waterway), which was
large enough to clarify the slurry before discharge to Commencement Bay. 
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Debris  The type of debris commonly found in the T-117 intertidal mudflat,
such as riprap and rock from the shoreline and small wood debris from the
river, area would likely plug and damage the smaller-sized dredges (6- to 14-
in.-diameter discharge pipe) typically used for environmental remediation of
this scope. 
Because of these factors (i.e., spillage, slurry, debris) and the relatively small volume of
material to be dredged, hydraulic dredging was not considered practical for this
removal action. 
Mechanical dredging is therefore the preferred technology for subtidal sediment
removal. The specific type of dredging bucket will be selected based on water quality
performance criteria established during the design phase of the NTCRA. 
6.1.2.2   Sediment capping 
Sediment capping could be completed using either land-based earth-moving
equipment (e.g., backhoes or other types of excavators, front-end loaders, dump
trucks, conveyor systems) or conventional offshore floating equipment. Clean capping
material could be imported to the site in dump trucks or on barges and then placed as
engineered fill. The cap would be designed to resist disturbance and the re-exposure
of materials contained beneath the cap. The three primary functions of capping are 
(Palermo et al. 1998): 
Physical isolation of the contaminated sediment from human and ecological
receptors 
Stabilization of contaminated sediment and the prevention of resuspension and
transport to other sites 
Reduction of the flux of dissolved contaminants into the water column. 
The cap would be specifically designed to provide these functions in a manner that is 
compatible with the site conditions along the T-117 shoreline, including sediment
grain size, bathymetry, surface water flow, and ship traffic. Capping designs prepared 
in accordance with USACE guidance for PCB- contaminated sediments in river 
settings can have caps that range from 12 to 36 in. thick. The caps are often multilayered
to provide chemical isolation immediately over the impacted sediment and 
include a sand and gravel/cobbles layer to prevent erosion from waves and prop
wash and a surficial habitat layer of sand and gravel. A robust 3-ft- thick cap
configuration is being assumed for the EE/CA (portions of the cap could be even
thicker, if needed, to accommodate clamming). It consists ofA typical cap design 
includes three layers: a sandy material to provide primary physical and chemical
containment of the underlying sediment, an armored layer (cobbles) to protect against
erosion, and a surface layer of natural sand and gravel. 

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Sediment capping could also be completed using floating equipment similar to that
used for mechanical dredging. The dredge bucket would be used to collect capping
material from a haul barge and place the material on the bed of the waterway. A
typical cap design includes three layers: a sandy material to provide primary physical
and chemical containment of the underlying sediment, an armored layer to protect
against erosion, and a surface layer of natural sand and gravel. If necessary, Tthe
specific cap design and structural components will would be further evaluated and
incorporated during the design phase of the NTCRA. Cap thicknesses and
composition will would be based on guidance published by EPA and USACE
guidance (Palermo et al. 1998; EPA 2005d). Sediment capping has been retained as a
technology for inclusion in one or more of the removal action alternatives to be
presented in Section 7. 
6.2   MATERIAL TREATMENT AND DISPOSAL 
This section describes the broad range of soil and sediment treatment and disposal
technologies identified and evaluated for the T-117 EAA. A comprehensive list of
potential treatment and disposal technologies was compiled, reviewed, and screened
against specific criteria (Appendix K). The Candidate Technologies Report (RETEC
2005) prepared for the LDW FS serves as a basis for identifying applicable
technologies. However, because the Candidate Technologies Report focused on
sediment treatment technologies, this EE/CA also includes consideration of a full
range of soil treatment technologies. Additional sources of information on
technologies included: 
Federal Remediation Technologies Roundtable. Treatment technologies
screening matrix for SVOCs (Platinum International 2002, Sections 4.1 through
4.8) 
Superfund Guidance on Remedial Actions for Superfund Sites with PCB
Contamination (EPA 1990) 
Engineering Issue: Technology Alternatives for the Remediation of PCB-Contaminated
Soil and Sediment (Davila et al. 1993), prepared for EPA 
Application, Performance, and Costs of Biotreatment Technologies for Contaminated
Soils (Battelle 2002), prepared for EPA 
Commercially permitted PCB disposal facilities (EPA 2008a) 
Table 6-1 includes a list of the identified treatment and disposal technologies and
information regarding the technology evaluation and screening process. Each
technology was evaluated for its applicability to the T-117 NTCRA. The evaluation
addressed expected soil and sediment quantities and physical characteristics,
estimated COC concentrations, processing costs, and the availability of suitable
staging and transfer areas for storing, treating, and loading excavated or dredged

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materials. Technologies were evaluated and selected based on their estimated
implementability, effectiveness, and cost. 

















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Table 6-1.  Review of can     Review of candidate removal action technologies for the T--117 NTCRA 
Contaminants of Concern 
Process Option               Description                      Typically Treated               Screening Decision 
In Situ Treatment 
Biological 
Not applicable: not feasible for PCBDegradation
of organic contaminants in the soil using                                      contaminated soils, site hydrologic
Effective principally to PAHs, other non-
Aerobic         microbes in the presence of oxygen. Enhanced                                      characteristics of the fill (potential
halogenated SVOCs, and BTEX. Biodegradation
biodegradation      bioremediation includes the injection of nutrients,                                       preferential flow pathways) not
of PCBs not feasible. 
oxygen or other amendments.                                                 conducive to treatment. Too much
treatment time would be required. 
Not applicable: not effective for PCB
The injection of a methanogenic culture, anaerobic                                       contaminated soils, site hydrologic
Anaerobic       mineral medium and routine supplements of glucose to  Effective principally on chlorinated VOCs. Bio-   characteristics of the fill (potential
biodegradation      maintain methanogenic activity. Nutrients and pH are    degradation of PCBs is not proven.           preferential flow pathways) not
controlled to enhance degradation.                                                  conducive to treatment; treatment time
constraints. 
Used to address metals, pesticides, solvents,
explosives, crude oil, PAHs, and landfill
Not applicable: not proven to clean up
A process that uses plants to remove, transfer,        leachate. Effective at up-taking PCBs in shallow
Phyto-remediation                                                                         PCBs to site RvALs, unable to
stabilize, and destroy contaminants in soil.            soils (surface to 3 ft depths) and low
remediate to necessary depth. 
concentrations, but not proven to meet RvALs
for higher concentrations of PCBs. 
Chemical 
Delivery of oxidizers into soils using injection wells in                                          Not applicable: not effective for PCB
Used to treat VOCs. Oxidation is less efficient
contaminated soils. Oxidation of organics using                                          contaminated soils, for site soil
Chemical oxidation                                         with SVOCs including pesticides, PAHs, and
oxidizing agents such as ozone, peroxide,                                            characteristics and may pose additional 
PCBs. 
permanganate, or Fenton's reagent.                                                site risks. 
Physical-Extractive Processes 
Vacuum is applied to the vadose zone soil to induce the                                    Not applicable: not appropriate PCBs in 
Soil vapor                                                Effective at extracting VOCs. Not effective at
controlled flow of air and remove VOCs and some                                      contaminated soils due to extremely low
extraction                                                   extracting PCBs. 
SVOCs.                                                       vapor pressure. 
Water or water containing an additive to enhance                                        Not applicable: Unproven technology,
contaminant solubility is applied to the soil or injected    The technology can be used to treat VOCs,      possible contaminant migration to
Soil flushing        into the groundwater to raise the water table into the     SVOCs, fuels, and pesticides. Technology       surface waters and heterogeneous fill
contaminated soil zone. Contaminants are leached into  unproven to treat PCBs to 1 mg/kg.           soils. PCBs are strongly adsorbed onto
the groundwater, which is extracted and treated.                                          soil particles.

Table 6-1.  Review of candidate removal action technologies for the T-117 NTCRA (cont.) 
Contaminants of Concern 
Process Option               Description                      Typically Treated               Screening Decision 
Cracks are developed by fracturing beneath the surface
in low permeability soils to open new passageways that  Used on a variety of COCs, depending on the in-  Not applicable: Some site soils have
Fracturing 
increase the effectiveness of many in-situ processes    situ process it is used in conjunction with.       high permeability. 
and enhance extraction efficiencies. 
Not applicable: Site properties such as
debris (e.g., USTs, remnant
Steam injection, hot air injection, electrical resistance                                         underground asphalt manufacturing
Applicable primarily to VOCs, also used for
heating, electromagnetic heating, fiber optic heating, or                                      facility structures, foundations, rip rap,
Thermal treatment                                        SVOCs, pesticides and fuels. Less effective for
radio frequency heating is used to increase the                                          pilings) make effective application
PCBs. 
volatilization rate of SVOCs and facilitate extraction.                                          infeasible, Not applicable to PCB
contaminated soils, lack of full scale
demonstration. 
Removes metals and polar organic contaminants from
Not applicable: Technology is not
low permeability soil, mud, sludge, and marine dredging
Electro kinetic                                                Typically used for heavy metals, anions, and     applicable to PCB & TPH contaminated
through the application of a low intensity direct current
separation                                               polar organics. Limited applicability to PCBs.     soils, or to highly permeable soils and
between ceramic electrodes that are divided into a
buried debris. 
cathode array and an anode array. 
Physical Immobilization 
Not applicable to PCB contaminated
Traps or immobilizes hazardous substances using     Generally used for inorganics, solidification for   soils and contamination is below the
Soil solidification 
physical or chemical means.                    organics is not a proven technology.          water table, heterogeneous soils, and
leaching potential of solidified soils. 
Not applicable: remediation of PCB
contaminated soils to 1 mg/kg is
Uses an electric current in situ to melt sediment or other
unproven. Additional challenges include
earthen materials at extremely high temperatures      Applicable to inorganic and organic chemicals.
heterogeneous soils, buried debris, and
Vitrification          (2,900-3,650 F). Inorganic compounds are            Has been tested on PCBs, but not at a full scale
dewatering of saturated soils. Risks
incorporated into the vitrified glass and crystalline mass  and at action levels of 1 mg/kg. 
include possibility of generating dioxins
and organic pollutants are destroyed. 
and furans as by-products due to high
treatment temperatures. 
Ex Situ Treatment 
Biological 
Excavated soils are mixed with amendments and
Not applicable to PCBs. Biopile treatment has
placed in aerated aboveground enclosures. Moisture,                                    Not applicable: Not a technology that is
Biopiles                                                    been applied to treatment of non-halogenated
heat, nutrients, oxygen, and pH can be controlled to                                       applied to PCB contaminated soils. 
VOCs and fuel hydrocarbons. 
enhance biodegradation. 


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Table 6-1.  Review of candidate removal action technologies for the T-117 NTCRA (cont.) 
Contaminants of Concern 
Process Option               Description                      Typically Treated               Screening Decision 
Soil is mixed with amendments and placed on a
treatment area that typically includes leachate         Not applicable to PCBs. Contaminants that have
collection. The soil and amendments are mixed using   been successfully treated using land farming    Not applicable: Degradation rates not in
Land farming/      conventional tilling equipment or other means to       include diesel fuel, No. 2 and No. 6 fuel oils, JP-  keeping with NTCRA objectives.
composting       provide aeration. Moisture, heat, nutrients, oxygen, and  5, oily sludge, wood-preserving wastes        Requires long processing time and large
pH can be controlled to enhance biodegradation. Other  (pentachlorophenol and creosote), coke wastes,  processing area. 
organic amendments such as wood chips, potato      and certain pesticides. 
waste, or alfalfa are added to composting systems. 
Fungal biodegradation refers to the degradation of a
Bench scale studies indicate a destruction of     Not applicable: Limited full scale
Fungal         wide variety of organic pollutants by using fungal lignin-
PCBs between 29 and 70%. Limited full scale    experience and limited applicability to
biodegradation      degrading or wood-rotting enzyme systems (example:
application data.                         PCBs. 
white rot fungus). 
Techniques have been successfully used to
An aqueous slurry is created by combining soil with     remediate soils, sludges, and sediments
water and other additives. The slurry is mixed to keep   contaminated by explosives, petroleum
Not applicable: technology for
solids suspended and microorganisms in contact with   hydrocarbons, petrochemicals, solvents,
Slurry-phase                                                                           remediation of PCBs is still developing,
the contaminants. Upon completion of the process, the   pesticides, wood preservatives, and other
biological treatment                                                                               and low throughput of available
slurry is dewatered and the treated soil is removed for   organic chemicals. Effective on PCBs when a
equipment. 
disposal. Sequential anaerobic/aerobic slurry-phase    sequential anaerobic/aerobic slurry-phase
bioreactors are used to treat PCBs.                bioreactor is used, but limited in full scale
demonstrations. 
Chemical 
Reduction/oxidation chemically converts hazardous
Reduction/ oxidation is effective for inorganics
contaminants to nonhazardous or less toxic compounds
Reduction/                                            and is less effective for SVOCs such as PCBs or  Not applicable to PCB and TPH
that are more stable, less mobile, and/or inert. The
oxidation                                                   soils with high levels of oil and grease; not      contaminated soils. 
oxidizing agents most commonly used are
applicable to the site COCs. 
hypochlorites, chlorine, and chlorine dioxide. 
Contaminated soils and the reagent (typically
potassium polyethylene glycol) are mixed and heated in                                   Not applicable due to infrastructure
Dehalogenation     a treatment vessel. The reaction causes the         Applicable to treating PCBs.               requirements and reagent and process
polyethylene glycol to replace halogen molecules and                                     wastes. 
render the compound nonhazardous or less toxic. 
Contaminated soil and solvent extractant are mixed in
an extractor, dissolving the contaminants. The
Effective in treating soils containing primarily
extracted solution is then placed in a separator, where                                      Not applicable: due to infrastructure
Solvent extraction                                            organic contaminants such as PCBs, petroleum
the contaminants and extractant are separated for                                       needs, and fate of solvents in soil. 
wastes, and VOCs. 
treatment and further use (example: B.E.S.T. and
propane extraction process). 


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Table 6-1.  Review of candidate removal action technologies for the T-117 NTCRA (cont.) 
Contaminants of Concern 
Process Option               Description                      Typically Treated               Screening Decision 
Multi-step process of preprocessing, aeration, sediment                                    Not applicable: unproven technology,
Soil washing                                           Applicable to treating PCBs, but unproven at full
washing, cavitation and oxidation and liquid/solid                                          time for permitting, and necessary
(biogenesis)                                               scale to meet RvALs. 
separation.                                                                    infrastructure. 
Physical 
Not applicable: does not destroy
Applicable to SVOCs, fuels, inorganics, and
Contaminated fractions of solids are concentrated                                        contaminants; must be used in
selected VOCs and pesticides. Only applicable
Separation        through gravity, magnetic or sieving separation                                        conjunction with other technologies;
to adsorptive COCs that would adhere to the
processes.                                                               slow throughh put; and extensive
fine-grained soil. 
infrastructure necessary. 
Ultraviolet energy in sunlight destroys contaminants     Limited information on destruction efficiency of   Not applicable: unproven technology in
Solar detoxification 
through photochemical and thermal reactions.         PCBs at previous site applications.           large scale application. 
The mobility of constituents in a solid medium is                                          Not applicable: slow through put of
Primarily used for inorganics; vitrification is
Solidification/       reduced through addition of immobilization additives.                                           available equipment, unpredictable 
effective for organics. Not proven to meet action
vitrification           Various additives and processes are available for                                                  leaching characteristics of solidified
levels at full scale implementation of PCBs. 
different COCs.                                                               PCB contaminated soils. 
Thermal 
Temperatures greater than 1,400 F are used to
Applicable to site COCs where concentrations
volatilize and combust organic chemicals. Commercial
exceed the hazardous waste designation;      Not applicable: due to expense and time
Onsite incineration   incinerator designs are rotary kilns equipped with an
principally PCBs > 50 50 mg/kg. Would also be  of PSCAA new source permits. 
afterburner, a quench, and an air pollution control
effective at destruction of petroleum waste 
system. 
Temperatures in the range of 200 to 600 F are used to
Low-temperature   volatilize and combust organic chemicals. These      Used to treat non-halogenated VOCs and fuels   Not applicable: Not effectively applied to
thermal desorption   thermal units are typically equipped with an afterburner  and SVOCs at reduced effectiveness.          PCB contaminated soils. 
and baghouse for treatment of air emissions. 
Applicable to SVOCs, PAHs, PCBs, pesticides,
volatile metals, VOCs. Limited full scale
demonstrability for PCBs. The process is
Not applicable: does not destroy
Temperatures in the range of 600 to 1,200 F are used   applicable for the separation of organics from
High-temperature                                                                      contaminants; must be used in
to volatilize organic chemicals. These thermal units are   refinery wastes, coal tar wastes, wood-treating
thermal desorption                                                                         conjunction with other technologies;
typically equipped with an afterburner and baghouse for  wastes, creosote-contaminated soils,
then destruction                                                                                slow throughput; and extensive
destruction of air emissions.                      hydrocarbon-contaminated soils, mixed
infrastructure necessary. 
(radioactive and hazardous) wastes, synthetic
rubber processing waste, pesticides and paint
wastes. 
Chemical decomposition is induced in organic materials                                   Not applicable: due to requiring specific
by heat in the absence of oxygen. Organic materials    The target contaminant groups are SVOCs and   feed size and materials handling
Pyrolysis 
are transformed into gaseous components and a solid   pesticides                           requirements, and dewatering of soil.
residue (coke) containing fixed carbon and ash.                                          Does not destroy metals. 

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Table 6-1.  Review of candidate removal action technologies for the T-117 NTCRA (cont.) 
Contaminants of Concern 
Process Option               Description                      Typically Treated               Screening Decision 
Offs-Site Commercial Disposal 
Containment 
Off-site disposal at a licensed commercial landfill facility  Applicable to site COCs below hazardous waste  Applicable: feasible for soils with PCB
Subtitle D landfill 
that can accept nonhazardous soil (PCB < 50 mg/kg).    designations (PCB<50 mg/kg).              concentrations < 50 mg/kg. 
Off-site disposal at a licensed commercial landfill facility
Applicable to site COCs exceeding hazardous   Applicable: feasible for soils with PCB
Subtitle C landfill     that can accept hazardous soil removed by excavation
waste designations (PCB > 50 50 mg/kg).      concentrations > 50 50 mg/kg. 
(PCBs >50 50 mg/kg). 
Physical 
Applicable to SVOCs, fuels, inorganics, and
Contaminated fractions of solids are concentrated                                        Not applicable: commercial permitted
select VOCs and pesticides. Only applicable to
Separation        through gravity, magnetic or sieving separation                                        disposersal facilities not available in the
adsorptive COCs that would adhere to the fineprocesses.
region. 
grained soil. 
Thermal 
Offsite incineration and disposal at a licensed
commercial facility that can accept hazardous soil      Applicable to site COCs where concentrations
Alternate thermal                                                                            Applicable: appropriate for Toxic
removed by excavation (PCB > 50 50 mg/kg).       exceed the hazardous waste designation;
destruction or                                                                                 Substances Control Act (TSCA; PCBs 
Depends on analytical data from excavated soil.       principally PCBs > 50 50 mg/kg. Would also be
incineration                                                                                       >50 50 mg/kg) material. 
Dewatering may be required to reduce water content for  effective at destruction of petroleum waste. 
transportation. 
Chemical 
Contaminated soils and the reagent (typically
potassium polyethylene glycol) are mixed and heated in                                   Not applicable: commercial permitted
Dehalogenation     a treatment vessel. The reaction causes the         Applicable to treating the site COCs.          disposers disposal facilities not available
polyethylene glycol to replace halogen molecules and                                     in the region. 
render the compound nonhazardous or less toxic. 
BTEX  benzene, toluene, ethylbenzene, and xylene       PCB  polychlorinated biphenyl             TPH  total petroleum hydrocarbon 
COC  contaminant of concern                    PSCAA  Puget Sound Clean Air Agency       TSCA  Toxic Substances Control Act 
cy  cubic yards                                RvALs  removal action levels               VOC  volatile organic compound 
FRTR  Federal Remediation Technologies Roundtable     SVOC  semivolatile organic compound 
PAH  polycyclic aromatic hydrocarbon                T-117  Terminal 117 



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As presented in Table 6-1, both in situ and ex situ treatment technologies were 
identified and evaluated. In situ treatment technologies were not retained because of a
variety of implementability and effectiveness limitations, including the following: 
NoAllMany treatment technologies would likely not meet the RvALs specified 
for the site or are not applicable because of performance and processing
limitations. For example, there is a lack of performance data for in situ 
biodegradation, the site contamination at the T-117 EAA is not limited to the
surface so phytoremediation would not be effective, and site soil includes
heterogeneous fill and debris, which would be difficult to process using soil
flushing, vitrification, or thermal treatment. 
Treatment timeframes would be unacceptably long as compared with those for
excavation and would result in a protracted implementation period not in
keeping with the concept of an early action (i.e., there would be a much higher
likelihood that the NTCRA would not be completed prior to the
implementation of remedial action[s] for the LDW). 
Possible discharges to the LDW during treatment (e.g., chemicals associated
with oxidation, soil flushing, and solidification) could pose an unacceptable risk
to LDW sediment, and water quality and would need to be managed. These
chemicals include oxidants, such as permanganate, or surfactants that
supersaturate contaminants in water; these chemicals would be present at high
concentrations and would pose a more significant risk to water quality than is
currently posed by site COCs. 
Ex situ treatment technologies were eliminated because of a variety of
implementability and effectiveness limitations, including the following: 
Treatment technologies cannot be performed onsite because most available land
within the T-117 EAA will be subject to excavation during removal action
implementation. The largest area within the T-117 Upland Study Area not
expected to be excavated is less than 0.10 ac is size; this area is much smaller
than the area that would be needed for any ex situ treatment system. 
Treatment would not likely achieve RvALs at or below those established for the
T-117 EAA, particularly levels sufficient to meet a broad range of possible
future land uses (including terrestrial habitat criteria), and offsite disposal
would still be required. RvALs are difficult to achieve because the mixture of
organic and inorganic COCs and the persistent nature of the organic COCs
make it difficult to effectively treat the soil. 
The longer timeframe required to process large volumes of soil could delay
completion of the NTCRA. For example, a typical mobile thermal treatment
unit would require two to three dry seasons of operation (i.e., years) to treat all
of the excavated soil. 
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EPA-permitted aAlternative PCB treatment technologiestechnologies would
pose unacceptable constraints on the project, including prolonged timeframes
to demonstrate the site-specific efficiency and reliability (e.g., the possible need
for pilot or demonstration testing), low probability of institutional acceptance,
and performance uncertainties relative to disposal methods specifically
approved under TSCA for PCBs. 
Preferred disposal options for both soil and sediment would be at Subtitle C (TSCA)
and Subtitle D landfills. The conclusion that commercial landfill disposal is a cost-
-effective and environmentally acceptable solution is consistent with the findings of
the Puget Sound Confined Disposal Site Study (USACE 2003), which was co-sponsored
by Ecology, WDNR, and the Puget Sound Water Quality Action team with
cooperation from EPA Region 10, US Fish and Wildlife Service (USFWS), and
Washington Public Ports Association. 
Although there are several alternative technology treatment facilities that are
permitted by EPA, these facilities are not located within a reasonable distance from
T-117 and are not cost competitive with Subtitle C or D disposal. The closest applicable
facilities that have an incinerator and a low-temperature thermal desorption unit, are
both located near Salt Lake City, Utah. With disposal, soil would be hauled
approximately 5 miles and loaded onto trains for transport to a commercial landfill. 
Thus, commercial alternative technology treatment technologies facilities were not 
retained. 
6.3   SUMMARY OF RETAINED TECHNOLOGIES 
Table 6-2 presents a summary of technologies retained for inclusion in one or more of
the removal action alternatives discussed in Section 7. 
Table 6-2.  Retained Rremoval action technologies retained for the T-117 NTCRAEAA 
Technology/ 
Category      Method     Applicable Media                 Notes 
land-based     upland soil;      Technology is appropriate and readily available for the
excavation       nearshore sediment  scale and site-specific conditions at the T-117 EAA. 
Removal                            Technology is proven and available within the project
over-water
area. Special bucket designs and operating procedures
mechanical     sediment 
can be used for mechanical dredging to limit release of
dredging 
solids. 
Technology is appropriate for the T-117 Sediment Study
Area, but will would likely require restrictive covenants on
property use to prohibit activities that could disturb the
cap, and long-term monitoring of additional analysis of 
Containment  in-water cap     sediment        COCs and cap thickness monitoring would be necessary
to demonstrate that the cap remains in place and
provides the intended isolation of impacted sediment. 
effectiveness. Capping must consider post-placement
hydraulic conditions.. 

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Technology/ 
Category      Method     Applicable Media                 Notes 
Method is available and typically used for managing
hazardous or dangerous materials, including soil withthat
TSCA-designated  require special landfill design and operation because 
Subtitle C landfill
waste soil or       PCB concentrations that exceed TSCA-specified limits
disposal 
sediment         (i.e., equal to or greater than 50 mg/kg). Applicable
predominately predominantly to soil and some
Disposal                                nearshore/bank sediment. 
Method is available and typically used for managing
non-hazardous or   materials that are not designated as hazardous or
Subtitle D landfill
non-dangerous soil  dangerous wastes. Applicable to sediment, soils in the
disposal 
or sediment       Adjacent Streets and Residential Yards soil Study Area,
and some T-117 Upland Area Study Area soil. 
COC  contaminant of concern                  PCB  polychlorinated biphenyl 
EAA  early action area                        T-117  Terminal 117 
na  not applicable                            TSCA  Toxic Substances Control Act 
















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7    Removal Action Alternatives 
This section presents the two removal action alternatives identified for the T-117 EAA
and describes the No Action alternative, which was developed to provide a basis for
the comparative evaluation of alternatives (Section 8). In particular, this section: 
Discusses how each alternative would be applied to the T-117 EAA 
Discusses the implementability, effectiveness, and estimated cost of each
alternative 
Presents project completion options 
The two removal action alternatives incorporate the technologies evaluated and
retained in Section 6 and address the removal of contaminated soil in the T-117
Upland and Adjacent Street and Residential Yards Study Areas and the removal or
capping of sediment in the T-117 Sediment Study Area. Because the selected action
levels for the upland portion of the site are low enough to provide for a broad range of
future land uses (including the need to achieve RvALs sufficient for possible habitat
redevelopment in the T-117 Upland Study Area), this EE/CA does not include
alternatives that are solely based on current upland land use. Such alternatives might
have been considered for the T-117 EAA if the final site use were to be limited to
industrial or restricted-access facilities. However, RvALs based on industrial or
restricted-access exposure assumptions are not appropriate for the T-117 EAA because
of the EPA mandate for unrestricted land use (EPA 2007b), which was based on the
T-117 EAA's proximity to residential areas and the LDW shoreline, the site RAOs, and
MTCA. The two alternatives retained in this EE/CA represent the "maximum
feasible" removal action in terms of the extent and level of site cleanup, rather than a
mid-range of options as might otherwise be considered given a more limited future
site use and a different set of removal action goals and objectives. . 
A range of treatment and disposal technologies for removal of soil and sediment were
evaluated in Section 6, and used to assemble two removal alternatives as well as the
one technology (i.e., offsite disposal) was retained. The two retained alternatives, as
well as the No Action alternative, which are summarized below and in Table 7-1 and
the following bullets. 
No Action alternative  The No Action alternative has been retained only to
provide a basis for comparing the overall effectiveness of the two identified
removal alternatives (i.e., Alternatives 1 and 2). The No Action alternative is not
a viable removal action alternative and does not meet the requirement to
consider a broad range of possible future land uses or potential habitat
development goals for this project. Under the No Action Alternative, no
activities would be implemented to remove, contain, or treat contaminated

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upland soil or intertidal and subtidal sediment within the EAA. The site would
remain in its current condition with ongoing access restrictions and monitoring
similar to that required under the existing O&M plan and post-removal site
control plan (RETEC 2007a) implemented for the T-117 Upland Study Area
following the 2006 TCRA. 
Alternative 1, upland soil excavation and sediment excavation/dredging 
combined with capping This alternative involves the excavation of soil from
the T-117 Upland Study Area, including the shoreline bank area, as well as the
Adjacent Streets and Residential Yards Study Area. As set forth in Section 4,
this alternative would include soil removal up to the MTCA-specified depth of
compliance of 15 ft as needed to achieve the RvALs. The Upland Study Area
would be backfilled to an elevation of +14 -ft MLLW, and the Adjacent Streets
and Residential Yards would be backfilled to near original grades. In the T-117
Sediment Study Area, the portion of the mudflat sediment offshore of the toe of
the shoreline bank and outward to an elevation of approximately 0 -ft MLLW
would be excavated using conventional shore-based earth-moving equipment.
The depth of excavation would be approximately 2 to 4 ft. Subtidal sediment
removal in the Marina, would be approximately 2 to 5 ft deep, would beand be
accomplishedremoved using over-water mechanical dredging to re-establish
navigable depths within the Marina. Capping material would be placed
throughout the sediment remediation area, except for the Marina, to establish a
clean sediment surface in compliance with the sediment RvALs. Map 7-1 shows
the Alternative 1 removal area excavation prisms. 
Alternative 2, upland soil excavation and sediment excavation/dredging  
This Alternative is the same as Alternative 1 regarding excavation and
backfilling at the T-117 Upland Study Area and adjacent shoreline bank as well
as the Adjacent Streets and Residential Yards Study Area. Alternative 2 only
differs from Alternative 1 relative to the nature of the removal action in the
Sediment Study Area offshore of the toe of the shoreline bank. Alternative 2
requires dredging of all contaminated sediment within the sediment boundary,
including dredging within the Marina to re-establish navigable depths.
Dredging depths will range from 2 to 7 ft. The dredged areas, except the
Marina, will be backfilled with clean material to re-establish site grades. Map 
7--2 shows the Alternative 2 removal area excavation prisms. Map 7-3 presents
an overview of the removal areas and the sediment cap area of both
Alternatives. 



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Table 7-1.  Summary of site-wide removal action alternatives 
Extent of Action and Action Goals Based on Preliminary RAOs 
Adjacent Streets and Residential     T-117 Sediment 
Alternative             Description         T-117 Upland Removal Area         Yards Removal Area           Removal Area 
No Action Alternative. No   Institutional controls (e.g., 
removal of contaminated     access controls) 
material. Ongoing institutional
Monitoring 
controls, monitoring and site-                       None                       None                       None 
wide maintenance would     Site-wide maintenance
continue as presently       (inspections, erosion and
required.                 surface water controls) 
RvALs based on a broad range of
potential future upland site use     Potential future upland site use
Upland soil excavation     conditions or use as upland habitat  conditions and associated RvALs
a
are met based on MTCA  and     met.                    Combined excavation and
Limited intertidal sediment
background.                                          dredging with capping to
excavation in the mudflat                            Restore site to approximate premeet
sediment RvALs
at the toe of the Bank      Alternative includes the baseline    existing grades, with paving and
Alternative 1. Upland soil                                                                           within the T-117 sediment
stormwater improvements meeting
removal and sediment                        completion approach: backfill with
Limited subtidal sediment                                                     removal area to the
City of Seattle design codes.
excavation/dredging                          clean soil to restore the site to
dredging at the marina                                                        specified depth of
intermediate elevation of just above  Restore yards to pre-existing
combined with capping                                                                         compliance (45 cm). A
Sediment capping to meet  +14 MLLW to allow for broad range  conditions and restore any
thicker cap (e.g., up to 3
the sediment RAOs as    of future uses (including possible   improvements that exist at the time
ft) could be required
needed within the       habitat development). Post removal  of initiation of the cleanup. 
depending on final design. 
sediment boundary       redevelopment options may be     Restore yards to pre-existing
chosen by the Port during the      conditions. 
removal design (Section 9.3). 






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Extent of Action and Action Goals Based on Preliminary RAOs 
Adjacent Streets and Residential     T-117 Sediment 
Alternative             Description         T-117 Upland Removal Area         Yards Removal Area           Removal Area 
Excavation and dredging
to meet sediment RAOs
within the T-117 sediment
removal area to the
Upland soil excavation                                                        specified depth of
compliance (45 cm). 
Intertidal sSediment                                                         Capping would not be
excavation between the                                                   used except as a
Alternative 2. Upland soil    bank and subtidal area                                                        contingency for limited
removal and sediment                        Same as Alternative 1.          Same as Alternative 1. 
areas where sediment
excavation/dredging        Subtidal sediment
dredging to the extent of                                                        excavation or dredging
the sediment boundary                                                    might not be feasible (e.g., 
around existing
No capping 
structures). Backfilling
with clean material would 
occur in some locations to
restore the desired final
topography. 
a
According to MTCA unrestricted site use conditions, "Restrictions on the use of the site or natural resources affected by releases of hazardous substances
from the site are not required to ensure continued protection of human health and the environment" (WAC 173-340-200).The point of compliance is typically
throughout the site to a depth of 15 ft (WAC 173-340-740(6)). MTCA CULs are specific to each contaminant and are derived using default or site-specific
assumptions as set forth for soil under WAC 173-340-740 (i.e., the Method A default CUL for total PCBs in soil for unrestricted land use is 1.0 mg/kg). Soil
CULs for upland areas to be developed for use as habitat are set forth under WAC 173-340-7493 and may be more stringent than MTCA Method A. Reliance
on clean soil covers to provide for habitat development may include requirements for institutional controls to maintain habitat areas and prevent exposure of
sensitive species to residual site contaminants located at depth. Soil that is directly erodible into the LDW or that will come to reside within the aquatic portion
of the LDW as a result of this removal action will meet sediment RvALs set forth herein. 
ARAR  applicable or relevant and appropriate requirement    MTCA  Model Toxics Control Act          RvAL  removal action level 
CUL  cleanup level                              na  not applicable                    T-117  Terminal 117 
LDW  Lower Duwamish Waterway                 RAO  removal action objective           WAC  Washington Administrative Code 




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Both alternatives include the extensive removal of contaminated soil and sediment to
meet the RAOs. Both represent a high degree of cleanup, and neither depends on
containment or institutional controls in the upland areas. In addition, there is the
potential for encountering currently unknown site infrastructure, artifacts, and/or
contamination during the removal action, which both alternatives will address, as
appropriate. 
The use of controls or restrictions would only be used as necessary to protect future
habitat in both the upland and aquatic areas. Alternative 1 would depend upon
institutional controls (in the offshore cap area to help ensure the long-term integrity of
these in-water structures. 
Alternatives 1 and 2 include the assumption that after upland and bank soil removal is
completed to remove COCs at concentrations greater than the soil RvALs up to the
appropriate depth of compliance (e.g., up to 15 ft below final upland site grade), the
excavated portions of the T-117 Upland Study Area will be backfilled to a finished
grade just above elevation +14 MLLW, which is slightly above the high water line of
+13.8 ft MLLW. For the purpose of this EE/CA, this is referred to as the baseline
completion option, which is necessary to develop cost estimates. Additional
dDevelopment options for restoring the T-117 EAA that are compatible with a full
range of possible future site uses (i.e., completion options), including habitat
restoration, are discussed in Section 7.3. 
The following subsections describe the two removal action alternatives in detail and 
discuss how each would be implemented. Each alternative is discussed relative to
specific actions within the three T-117 EAA three study areas and in terms of the
overall criteria of implementability, effectiveness, and cost as defined in EPA's
Guidance on Conducting Non-Time-Critical Removal Actions Under CERCLA (1993). 
The evaluation of each alternative includes a discussion of: 
Site preparation requirements 
Soil excavation activities 
Sediment excavation/dredging and capping activities 
Management of excavated and dredged materials 
Site completion and coordination with future site uses 
Quantities and costs 
Evaluation of implementability and effectiveness 
7.1   ALTERNATIVE 1: UPLAND SOIL EXCAVATION AND SEDIMENT EXCAVATION/ 
DREDGING COMBINED WITH CAPPING 
This alternative involves the excavation of soil in the T-117 Upland Study Area
(including the shoreline bank) and Adjacent Streets and Residential Yards Study Area
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to meet the defined soil RvALs at the depths of compliance presented as the RAOs in
Section 4.4. In the T-117 Sediment Study Area, mudflat sediment would be excavated
using conventional land-based earth-moving equipment, and subtidal sediment
would be removed using a barge-mounted dredge to allow for a sufficient postremoval
cap depth. The subtidal (submerged) portion of the removal area would then
be capped (except in the area offshore of the Marina, where removal without capping
would be used to meet the RAOs). The specific combination of excavation and
dredging would be established during the remedial design. Surface water quality
monitoring parameters and criteria for dredging work would be identified as part of
the design phase of the NTCRA. Capping would be used instead of excavation or
dredging to address contaminated sediment at locations where capping could be
implemented without unacceptable shallowing or constriction of the river channel or
Marina. As mentioned previously, specific locations where final cap elevations would
need to be consistent with required channel depths would be identified and evaluated
during the remedial design. For the purpose of this EE/CA, it is assumed that a cap
thickness of 3 ft would be used (see Section 7.1.3). The actual cap thicknesses and
layers would be finalized as part of the NTCRA design and could vary depending on
the location of the capped area. The first (bottom) layer of the anticipated cap cross
section would consist of a 6-in. to 1-ft-thick layer of granular soil, which would serve
as a filter layer and be placed directly on the sediment. Above this layer would be a 1-
ft-thick layer of cobbles to provide stability and resistance to erosion. The final (upper)
portion would consist of a 1-ft-thick layer of habitat-enhancing sand and gravel that
would be appropriately sized for stability during normal river flows. 
7.1.1  Site preparation 
Excavated and dredged materials will need to be removed from the site for offsite
disposal (Section 7.1.4). A number of site preparation activities would need to be
completed prior to the implementation of the removal action. Design details and work 
plans for implementation would be further developed during the design phase. Site
preparation activities are described below. 
7.1.1.1   Public notification and traffic control measures 
A traffic routing plan would be developed during the design phase with input from
the community. Prior to work initiation, public notifications and traffic control
measures would be implemented in accordance with the approved routing plan and
site-specific construction plans. Notifications would inform the potentially impacted
neighborhood residents and businesses of the planned construction dates, duration of
work, areas of work, site access restrictions, and possible alternative traffic routes for
neighborhood residents and construction trucks. Hours of operations (i.e., working
longer hours for shorter overall duration or working shorter hours for potentially 
longer overall duration) will also be determined with community input. In addition,
the timing of road improvement activities (e.g., the pending South Park Bridge
replacement project) would need to be considered. Traffic control measures, including
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signage, warning lights, and the use of traffic control personnel, would be
implemented in accordance with applicable construction codes and guidance. 
7.1.1.2   Dust control plan 
Control of offsite dispersal of dust generated during construction would will be a high
priority for the NTCRA design and implementation. A dust control plan wouldwill be
developed as part of the NTCRA design and would specify methods and criteria for
implementing specific dust control measures. Dust control methods and monitoring
activities similar to those used during the 2006 TCRA (RETEC 2006) wouldwill be
evaluated for applicability to the site and used as appropriate. 
Monitoring of previous remedial actions has been conducted at the T-117 EAA. Air
monitoring was conducted as part of the 2006 TCRA (RETEC 2006). Air sampling and
monitoring for the TCRA consisted of air quality monitoring, meteorological
monitoring, and odor observations. Air monitoring action levels weres specified in the
air quality and meteorological monitoring plan18 (Appendix D in RETEC 2006). 
Monitoring before (background) and during removal identified particulate and PCB
concentrations well below the action levels (RETEC 2007b). 
During the 2005 independent removal action conducted by the City, yard soil was
removed at 8601 and 8609 Dallas Avenue S. During the removal, wipe samples were
collected from metal and painted wood surfaces at the residences. The wipe samples
were analyzed for PCBs, which were not detected above the PQL of 2 g/100 cm2 
(Onsite Environmental 2005). 
Finally, WSDOH conducted indoor dust sampling in conjunction with the 2004-2005 
independent removal action at two homes on 17th Avenue S (8601 and 8609 17th 
Avenue S). Dust was collected with a high- volume, small- surface sampler in areas of
high activity in the homes. PCBs were detected (primarily in rugs) at levels ranging
from 0.756 to 1.57 mg/kg (dust loading ranged from 2.18 to 16.7 g/m2), indicating that
some PCBs were transported into the home from exterior sources (assumed to be
Dallas Avenue S road dust). However, WSDOH concluded that no apparent public
health hazard existeds for residents exposed to PCBs found in house dust along Dallas
Avenue S (WSDOH 2006). 
Although previous monitoring has not identified significant issues with regard to
dust, dust control and monitoring will be conducted during the removal action. 
Particular attention would will be given paid to controlling dust during excavation,
soil loading activities, and work during dry weather. Meteorological monitoring
would also be used as a tool for evaluating dust control needs. As was done for the
TCRA, dust management may include the wetting of excavation areas and stockpiles
with water, covering of trucks loaded with soil, covering of stockpiles that are not
18 The action level for PM10 particulates (as measured with DataRAM meters and TE-1000 polyurethane
foam cartridge samplers) was 105 g/m3 based on a 24-hour average, and the action level for PCB
concentrations was 0.11 g/m3 at the property perimeter. 
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being actively loaded or unloaded, and daily sweeping of onsite truck routes and soil
handling areas. Meteorological monitoring would also be used to evaluate dust
control needs. Odor was not an issue during the 2006 TCRA, but odor control foam
will be applied during the NTCRA if odor problems arise. The monitoring methods
will be developed in the NTCRA design phase. 
7.1.1.3   Construction mobilization 
Supporting site facilities, staging areas, drainage and erosion controls, dust
suppression equipment and effective decontamination facilities, including facilities for
truck wheel washing, would be installed or constructed prior to the initiation of the
removal action. Plans for site health and safety, drainage controls (Section 7.1.1.4),
construction scheduling, dust and track-out monitoring and control, in-water
monitoring (during dredging/capping) and other measures will need to be prepared
and fully implemented. Measures will also need to be in place to ensure that truck
loads are appropriately lined and covered and vehicles are decontaminated (i.e.,
wheels have been washed) and inspected prior to leaving the T-117 EAA and entering
public streets. 
7.1.1.4   Water control systems 
Collection, treatment, and disposal systems will be required to address surface runoff
coming into or originating from the removal areas. Engineered well-point systems
and/or subsurface barriers or interceptor systems would also likely be necessary to
limit the influx of groundwater into deeper upland excavations within the T-117
Upland Study Area. A shoreline barrier (i.e., sheet pile wall or soil berm) would be
employed as needed to limit tidal influence of groundwater and prevent tidal
inundation of upland soil removal areas. For the purpose of the EE/CA, it is assumed
that either an upgradient low-permeability cutoff wall (i.e., bentonite/ cement
slurry-filled trench) or a groundwater dewatering system would be used to limit
groundwater influx from upgradient areas prior to excavation below the water table.
Additional water extraction and treatment would likely be necessary for any water
that may collect within temporary shoreline/bank barriers (e.g., a sheetpile walls) and 
the deeper inland soil removal prisms in order to maintain desired work conditions,
prevent water intrusion, and facilitate backfilling. 
A construction site stormwater management plan would be prepared for the project
and would include soil staging areas, the location and design of water
storage/treatment facilities, and any associated sediment handling facilities. The plan 
would specify methods for intercepting, collecting, and managing stormwater, as
necessary. BMPs, including the covering of excavated materials, stormwater 
interception, and collection and treatment of water from excavation and staging areas, 
will be used to ensure that potential impacts to the adjacent river, properties, and
existing residential drainage systems are controlled. The City and County permitting
requirements for offsite disposal of collected and treated water will be considered in 
developing and implementing water management systems. 
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7.1.1.5   Staging areas 
Staging areas for excavated soil would be established within the T-117 EAA, as
necessary, to accommodate material storage and loading. Staging will have to be
carefully managed for the T-117 Upland Study Area excavation because available
space will be limited; the project design will need to consider off-site staging and the
direct loading of trucks. Bank soil and sediment excavated using land-based
equipment would also be staged and loaded for transport within the confines of the
T--117 Upland Study Area. Sediment removed using over- water dredging would be
transported to an appropriate shoreline transfer location at an existing dock along the
LDW or at a Port facility, depending on availability of suitable space. Another option
would be to transfer dredged sediment using a specially constructed temporary
transfer facility at the T-117 EAA. Safeguards to ensure the clean and safe transfer of
materials would be required for the sediment handling location. Temporary material
staging time frames for soil or sediment deemed to be hazardous waste would be
consistent with limits set forth under RCRA for remediation wastes (typically 90 days
unless additional time is authorized by EPA), and the staging location would comply
with staging pile rules (WAC 173-303-64690 and 40 CFR 264.554). Bank soil and
sediment will be excavated first and will be stored on the T-117 Upland Study Area, in
a soil-staging facility, which will be lined and bermed. As mentioned above, the
construction site stormwater management plan would include control measures for
soil/sediment staging areas and any associated sediment transfer facility. 
7.1.1.6   Demolition and removal or relocation of structures and utilities 
The T-117 Upland Study Area and Adjacent Streets are paved and include buried
slabs, utility corridors, storm drains, and other subsurface features. The north, central,
and south buildings at the T-117 EAA and associated shelters, loading docks, and
foundations would be demolished and removed during the initial stage of the
NTCRA. Closed-in-place USTs located within the projected excavations, the UST in
the vicinity of the southwest corner of the north building, and the septic tank that
serves the north building and most of the associated drain field to the south would be
removed as part of the NTCRA. The decision to remove any additional portions of the
septic drain that may be encountered beyond the planned limits of the T-117 Upland
Removal Area would be based on field observations and performance sampling
results at the time of the NTCRA. The Adjacent Streets would be closed in stages to
allow access to the T-117 Upland Study Area and to limit the disruption of residential
access. A portion of the Marina floating docks would be temporarily relocated out of
the T-117 sediment removal area to an alternate location based on timing and
availability of moorage space. This relocation will allow for access to sediment within
the northern end of the sediment removal boundary. The Adjacent Streets would be
temporarily vacated, as necessary, to allow for the removal of underlying soil. 

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7.1.1.7   Yard remediation 
The Residential Yards are not owned by the City or the Port; therefore, access
agreements would need to be established prior to the initiation of any remediation on
these private properties. Also, the Residential Yards are landscaped and include
fences, utilities, and other surface and subsurface features. These features would need
to be removed or worked around if they are located within the excavation prism.
Removal activities would be coordinated with property owners prior to initiation and
would be conducted in such a manner as to limit the disruption of residential access.
Specific procedures for coordination with affected property owners would be
developed with community input during the remedial design phase. Any landscaping
that is disturbed will be replaced and/or replanted, and surface drainage will be
maintained or improved as necessary. 
7.1.2  Soil removal 
The estimated boundary of the removal action in the T-117 Upland Study Area and
Adjacent Streets and Residential Yards Study Area is presented on Map 4-1. The
estimated extent of the removal action in the T-117 Upland Area and Adjacent Streets
is are presented in Maps 7-1 and 7-3. The spatial extent of the removal action is
designed to address COCs in the upland soil (see Section 4) and include the removal of
the berm of the shoreline bank. Figures 7-1 through 7-5 show the extent of the
proposed NTCRA in a series of cross sections. The T-117 Upland removal area is
composed of several excavation prisms with depths that range from 1 to 17 ft. The
Adjacent Streets and Residential Yards removal area is composed of several
excavation prisms that range in depth from 1 to 6 ft along portions of the Adjacent
Streets and up to 2 ft within specific Residential Yards. The locations and depths of
excavations may be expanded slightly during design to provide for equipment access,
slope stability, and sequencing of the excavation process. The modification of
excavation locations and depths may also be necessary to address unforeseen
conditions encountered during removal, including the presence of structures (e.g.,
underground utilities). As described in Section 9.3.3.2, final depths will be based on
confirmation sampling to ensure that the RvALs are attained. 





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Slipsheet for 11 x 17 

Figure 7-1. Cross section E1 for Alternative 2 
















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Slipsheet for 11 x 17 
Figure 7-2. Cross section E2 for Alternative 2 

















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Slipsheet for 11 x 17 
Figure 7-3. Cross section E3 for Alternative 2 

















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Slipsheet for 11 x 17 
Figure 7-4. Cross section E4 for Alternative 2 

















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Slipsheet for 11 x 17 
Figure 7-5. Cross section E5 for Alternative 2 

















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The yard and street DUs designated for removal are identified based on UCL
calculations from MIS sampling results (as detailed in Appendix L, and described in
Section 4.4.3).19 The Adjacent Streets and Residential Yards Study Area is composed of
several excavation prisms that range in depth from 1 to 6 ft along portions of the
Adjacent Streets and up to 2 ft within specific Residential Yards. Pre--removal
sampling is anticipated in Residential Yards as part of the design phase to pre-
determine the extent of soil removal from yards and at DU25 and DU35, where soils
adjacent to a DU designated for removal have not been characterized. The DUs
designated for removal and the locations for pre-removal sampling are shown on
Map 7-3. 
The approximate in-place (i.e., pre-excavated) volumes of soil anticipated to be 
removed from the T-117 Upland Study Area and Adjacent Streets and Residential
Yards Study Area are presented in Table 7-2. 
Table 7-2.  In-place volumes of soil and sediment to be removed and estimated 
sediment capping/backfilling volumes under Alternative 1 
a                       b
Study Area                Component         Quantity (cy)
non-TSCA soil                 33,100 
T-117 Upland Study Area 
TSCA-designated soil             3,900 
non-TSCA soil                 7,400 
Adjacent Streets 
TSCA-designated soil              900 
non-TSCA soil                 1,800 
Residential Yards 
TSCA-designated soil              0 
non-TSCA soil                 42,300 
Total soil to be removed 
TSCA-designated soil             4,800 
non-TSCA sediment             6,450 
Total T-117 Sediment Study Area 
TSCA-designated sediment          50 
Material required for capping/backfilling                                 8,000 
a
TSCA soil is defined as soil with total PCB concentrations  50 mg/kg. A portion of this volume, approximately
250 cy, is estimated to contain total PCBs at concentrations  500 mg/kg. According to TSCA, all soil
50 mg/kg is amenable for disposal in accordance with 40 CFR 761.61(a)(5)(iii): "Bulk PCB remediation 
wastes with a PCB concentration 50 ppm shall be disposed of in a hazardous waste landfill permitted by EPA
under section 3004 of RCRA, or by a State authorized under section 3006 of RCRA, or a PCB disposal facility
approved under this part." Final offsite disposal is subject to review by EPA and will be arranged in accordance
with the waste-acceptance policy of the approved disposal facility. 
b 
Total volumes include the complete removal of the asphalt and base course material, as necessary, within the
T-117 Upland Study Area and Adjacent Streets.
cy  cubic yard 
EPA  US Environmental Protection Agency 
PCB  polychlorinated biphenyl 
TSCA  Toxic Substances Control Act 

19 An option exists to collect additional replicate samples at DUs with only one MIS sample. Based on
additional sampling results and the recalculation of the UCL, the status of the corresponding DUs 
could change.
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Total volumes include the complete removal of the asphalt and base course material, 
as necessary, within the T-117 Upland Study Area and Adjacent Streets. As shown in 
Table 7-2, some of the soil from the T-117 Upland Study Area and Adjacent Streets and 
Residential Yards Study Area will be TSCA-regulated waste, requiring disposal at a
Subtitle C landfill. The majority of the volume will be suitable for disposal at a
Subtitle D landfill. 
Excavation stability, impacts to groundwater, stormwater controls, and tidal water
intrusion will be addressed in the design phase of the NTCRA. The design phase will 
also address proper sequencing and the selection of effective construction methods
(i.e., use of temporary shoreline soil berms, sheet piling, or other types of barriers) and
surface water and groundwater controls. The locations and depths of the soil removal
prisms will be refined during final design and execution based on site conditions. 
The majority of the soil within the T-117 Upland Study Area and Adjacent Streets and
Residential Yards Study Area consists of loose-to-medium-dense silty gravelly sand,
with deposits of sand and silt. Based on this soil type, excavation slopes of 2 horizontal
to 1 vertical (2H:1V) were assumed and included in the estimated upland soil
volumes. The refinement of excavation slopes and methods will be included in the
design phase of the NTCRA. Confirmation sampling in the T-117 Upland Study Area
will be conducted at the limits of excavated areas and compared to RvALs removal
action levels for target COCs. Confirmation sampling of the Adjacent Streets and
Residential Yard Study Area soils will include PCBs and dioxins/furans (see Section 
9.3.3.2). 
The removal of the shoreline berm material will be carried out as part of the removal
action in the T-117 Upland Study Area. The portion of the bank to be removed is
included within the T-117 Upland Study Area boundary (Map 4-1). All soil that may
remain beneath the re-established (i.e., new) bank portions of T-117 EAA completed
above +13.8 ft MLLW will meet the applicable soil RvALs to the compliance depth
(i.e., up to 15 ft below final ground surface) set forth in Section 4 and shown on
Figure 4-1. Most of the upper portion of the bank will be removed and replaced with
clean fill that will meet the sediment RvALs. In addition, these actions will ensure that
all bank soil that could become intertidal or subtidal sediment (i.e., upon completion
of the NTCRA) will meet the applicable sediment RvALs to the specified depth of
compliance, either through dredging or a combination of dredging and capping
depending upon the selected removal alternative. It is anticipated that some additional
bank removal (i.e., soils with COCs concentrations less than the RvALs) may need to
be undertaken at some locations to ensure the stability of completed (i.e., new)
shoreline banks and accommodate possible final site uses (e.g., aquatic habitat). 
7.1.3  Sediment removal and capping 
Alternative 1 includes the removal of sediment from the mudflat close to the bank and
above elevation 0 ft MLLW following the removal of the impacted bank material
(based on appropriate soil or sediment RvALs) and the dredging of impacted
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sediment from within the Marina (and also re-establishing navigable depths in
Marina). This would be followed by the capping of the mudflat and submerged areas
within the sediment removal boundary except within the Marina, which would be an
impediment to navigation. Removal will be accomplished by excavating a portion of
the contaminated sediment and debris from the mudflat (e.g., down to elevation 0 ft
MLLW). 
Capping designs prepared in accordance with USACE guidance (see Section 6.1.2.2) 
for PCB- contaminated sediment can include caps that range from 12 to 36 in. thick. 
The caps are often multi-layered to provide chemical isolation immediately over the
impacted sediment and include a sand and gravel/cobbles layer to prevent erosion
from waves and prop wash and a surficial habitat layer of sand and gravel. A robust
3-ft- thick cap configuration has been assumed for the EE/CA. The cap would consist
of three layers: a sandy material to provide primary physical and chemical
containment of the underlying sediment, an armored layer (cobbles) to protect against
erosion, and a surface layer of natural sand and gravel. The final cap design will be
based on a hydraulic evaluation to determine an acceptable river channel cross
section. The cap construction could also include the placement of a filter layer (fabric
in the intertidal zone and granular soil in the subtidal zone). 
A conceptual cap design for T-117 is shown on The portion of Alternative 1 that 
would be capped is shown on Map 7-23 (plan view) and Figure 7--6 (cross section). 
The sediment exposed by the mudflat excavation would be sampled and analyzed for
COCs and then capped as shown on Figure 7-6 unless post-removal testing showed
that COC concentrations in the exposed sediment were less than the RvALs, in which
case it would be backfilled using clean material. 








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Slipsheet (11x17) 
Figure 7-6. General sediment excavation and cap cross section 

















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Removal of sediment from within the T-117 Sediment Removal Area will likely be
performed after the T-117 Upland Study Area work, which will help ensure that work
in the T-117 Upland Study Area does not act as a source of recontamination to the 
sediment. For the purpose of meeting the RAOs for sediment (Section 4), once the
mudflat excavation is complete, the new mudflat surface and submerged portion of
the removal area will be capped. The volume of sediment to be removed under
Alternative 1 is summarized in Table 7-2. 
Sediment removal and capping in the intertidal mudflat area would be completed
using land-based excavators or dredges. Removal in the submerged portion of the
T-117 sediment removal area would be completed using dredges and barges, working
at higher tides as needed to provide the required draft for the barges. For the portion
of the T-117 sediment removal area that is within the Marina, the submerged-zone
impacted sediment will be removed and not capped or backfilled to re-establish
navigation depths. 
Engineering controls will be implemented to limit the resuspension of contaminated
sediment during removal. A primary method for minimizing sediment resuspension
during removal in the intertidal zone is to complete the work when the tides are out
while the sediment is exposed to the air. Using this approach, removal does not occur
in the water column, and resuspension is essentially eliminated. The excavation
process will occur over a few weeks' time, and portions of the excavation will be
inundated by the daily rising tides prior to the completion of the removal. Experience
with this method of excavation over multiple tidal cycles at the Hylebos Waterway,
part of the Commencement Bay Nearshore/Tideflats Superfund site, at several
locations (General Metals Graving Slip, J&G Marina, Dunlap log ramp, Arkema South
East Shoreline), demonstrated that the repeated inundation of the excavation area did
not adversely impact the cleanup (DOF 2009). 
Engineering controls to limit suspension during dredging include the use of enclosed
dredging buckets to limit wash out during retrieval of the bucket through the water
column, and the avoidance of overflow of turbid sediment from the sediment haul
barge during dredging. Other examples of engineering controls include using slower
cycling times and containment structures to catch bucket spillage and direct materials
into the receiving barge or platform. These techniques have been used at other
sediment remediation projects in the LDW and other waterways. 
The use of silt curtains at the T-117 Sediment Study Area is not considered practical
because of the varying river currents and tidal stages. Deploying, maintaining, and
working with a silt curtain within the intertidal portion of the T-117 Sediment Study
Area would be problematic, and the use of a silt curtain in the subtidal portion of the
study area could interfere with navigation in the channel. According to an evaluation
of resuspension controls for dredging (Bridges et al. 2008), the installation and
maintenance of silt curtains in "moderate- or high-energy areas" can be difficult, and
their effectiveness is questionable. Silt curtains that are not fastened to the bottom of
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the river, which would be extremely difficult to do at the T-117 Sediment Study Area,
can allow particles to escape beneath the skirt. 
Water quality will be periodically regularly monitored during dredging activities to
assess potential water quality impacts during project implementation. Water quality
conditions must be within the limits prescribed by EPA's 401 Water Quality
Certification. If necessary, appropriate adjustments to dredging activities, such as
those described above, will be made to maximize the protection of the environment. 
The mudflat excavation will start at the toe of the bank at an elevation of
approximately +5 ft MLLW. The mudflat will be removed to an elevation of 0 ft
MLLW and then extended horizontally to the existing 0 ft MLLW contour. By setting
the deepest extent of the mudflat excavation at 0 ft MLLW, all of the nearshore
excavation could be completed "in the dry" while the tides are out (< 0 ft MLLW). 
Typical sediment cap designs include layers of granular material designed to contain
the contaminated sediment, protect against disturbance, and provide surficial habitat.
The cap construction could include the placement of filter layer (fabric in the intertidal
zone and granular soil in the subtidal zone) followed by the placement of quarry
spalls and a surface layer of sand and gravel. The final cap configuration will include a
hydraulic evaluation to determine an acceptable river channel cross section during the
design phase of the NTCRA. A conceptual cap design for T-117 is shown on Map 7-2
(plan view) and Figure 7-6 (cross section). 
The duration of the marine construction for Alternative 1, for in-water dredging and 
capping, is estimated to be 20 to 25 working days. 
Institutional controls would be required for thea cap under Alternative 1 (to reduce
the potential for the disturbance of the cap. Furthermore these controls would and 
require monitoring and maintenance. The cap would be designed to withstand smallvessel
anchorage, fishing, or clamming activities. In addition, the institutional controls 
would be developed so as to not to affect tribal treaty fishing rights. Individual
institutional controls may have limited effectiveness, and thus multiple controls are
typically used to ensure long-term effectiveness. If Alternative 1 is implemented, then
the details of the institutional control elements would be developed in an institutional
controls implementation plan during design, and the controls would be anticipated to
include proprietary controls (i.e., restrictive covenants), enforcement tools (i.e., agency
orders requiring monitoring and maintenance), and informational devices (i.e., deed
notice and state registry) as described below: 
Restrictive covenants would include restrictions on the capped area(s), limited
by what is allowed due to the unique status of portions of the LDW as property
formerly under the jurisdiction of the KCCWD1. To the extent possible,
covenants would limit disturbance of the cap under Alternative 1. Actions such
as construction projects that could disturb the cap would require agency
approvals, management plans for controls, and restoration of the cap or
complete removal of the contaminated materials. Restrictive covenants or other
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agreements would also require agency notification of any pending sale of the
property or any use of the property that might affect the cap, and provide for
agency access. The restrictive covenants could "run with the land" and be
included in any lease, deed, license, easement, or other use authorization.
Specifically, City easements associated with the re-location of the power pole
and future stormwater discharge drainage/outfall areas would be subject to the
restrictive covenants placed on the upland property. 
Agency orders (an enforcement tool) would be an institutional control that is
anticipated to be implemented under Alternatives 1 and 2. The Port and City
would sign a CERCLA order with EPA that would require long-term
monitoring and maintenance of any capped areas, as applicable. The details of
the monitoring and maintenance requirements would be developed during
design in an Agency-approved OMMP. EPA would review the effectiveness of
the remedy, including monitoring results and institutional control 
implementation, no less frequently than once every 5 years, as required under
CERCLA. 

Informational devices would be an additional institutional control for any
capped areas under Alternatives 1 or 2. Deed notices describing the restrictions
on the property would be filed in the King County Recorder's Office. Placement
and maintenance of site information on the state registry (Ecology's Hazardous
Sites List  Site Register) would also provide informational tools regarding
restrictions on the property. 
7.1.4  Management of excavated and dredged materials 
Soil and sediment designated as a TSCA waste (i.e., with total PCB concentrations 
50 mg/kg) will be the first material to be removed from each study area and
disposed of at a Subtitle C landfill. Soil and sediment determined to be nonhazardous
/non-dangerous will be disposed of at a Subtitle D landfill. These landfills
have the ability to receive soil or wet dredged sediment delivered by rail. Both types of
facilities must have also received the required EPA approval for acceptance of
sediment and soil generated at CERCLA sites. EPA's approval takes into account the
facilities' compliance with TSCA and/or RCRA permits and governing regulations,
including the Off-Site Rule (40 CFR 200.440). 
The hauling of material from the T-117 EAA to the disposal site will result in increased
truck traffic on neighborhood streets for the duration of the removal phase. A traffic
routing plan will be developed during the NTCRA design phase with community
input, as discussed in Section 7.1.1.1. The approved routing plan, as well as
transportation and safety plans, will be developed by the contractor as part of the
removal action work plan documents. These plans will address hours of operations;
estimated numbers of trucks and barges required for soil and sediment hauling;
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anticipated transport routes; material spill prevention, containment, and response
plans; and other protective and mitigating elements. 
7.1.5  Completion of the removal action and coordination with future site uses 
A principal goal of the removal action is to complete the T-117 Upland Study Area and
T-117 Sediment Study Area in a manner that leaves them suitable for a range of final
site uses and redevelopment options. An evaluation of final site redevelopment
options is currently being performed by the Port and may be ready for
implementation concurrent with the completion of the NTCRA or at a date after the
NTCRA has been completed. Regardless, the NTCRA design measures will ensure
that following the completion of the removal action, the ongoing integrity of the
property will be maintained through slope stabilization, stormwater infrastructure,
and erosion control measures. 
Under Alternative 1, it is assumed that the T-117 Upland Study AreaEAA will be
restored to a baseline condition that has been backfilled and graded to a minimum
elevation of +14 ft MLLW. This completion condition (hereafter referred to as the
"baseline completion option") is assumed in this EE/CA was used here for costing
purposes, inasmuch as it represents a "mid-point" from which a range of final site
uses could be accommodated. These final site uses include future commercial uses that
could be accomplished through limited additional backfilling, or the creation of
intertidal habitat that could be accomplished through minimal backfill removal and
contouring. These completion options are discussed further in Section 7.3. If the Port is
able to identify a site redevelopment option in conjunction with community
involvement prior to or during the design phase of the NTCRA, the design of the
NTCRA completion would be coordinated with the final site use design. Restoration
of this area will trigger the County's requirements and standards for surface and
stormwater management (King County Ordinance 16264, 2009). 
The Adjacent Streets and Residential Yards Study Area will be restored to original 
grades and repaved and/or re-landscaped following the removal action. In addition,
the restoration of this area will trigger the stormwater requirements of SMC 22.800
and Development Director's Rules 2009-005 (SPU), 17-2009 (DPD) (City of Seattle
2009a). It is anticipated that stormwater will use one or a combination of possible
stormwater drainage, treatment, and potential discharge measures, including swales,
underground vault treatment, or catch basin inserts. 
The final configuration of the stormwater collection and treatment system will be
determined based on implementability, effectiveness, and cost and evaluated to
minimize negative impacts on the final site use. Because the final configuration of the
roadway stormwater improvements is an equal component of both Alternatives 1
and 2, it does not affect the comparison of alternatives for the NTCRA. 

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7.1.6  Summary of estimated costs 
The total estimated cost for Alternative 1 is approximately $31.70.4 million (Table 7-3),
which includes the present-worth cost for an assumed number of four cap-monitoring
events over 10 years. The actual frequency of monitoring will be determined later as
part of the post-NTCRA monitoring plan (Section 9.54) and may vary slightly from
this assumption. A detailed breakdown of the estimated direct capital costs, indirect
costs, long-term O&M costs and assumed contingencies is provided in Appendix J. 
Table 7-3.  Summary of estimated costs for Alternative 1 
a
Study Area                 Estimated Cost
T-117 Upland Study Area                         $20,100,000 
Adjacent Streets and Residential Yards Study Area          $76,6300,000 
T-117 Sediment Study Area                        $4,000,000 
Total estimated cost                              $310,7400,000 
a
Assumes baseline completion option for T-117 Upland Study Area with site restored to meet MTCA
unrestricted cleanup and habitat protection criteria. 
MTCA  Model Toxics Control Act 
O&M  operation and maintenance 
T-117  Terminal 117 
7.1.7  Evaluation of Alternative 1 
This section discusses the implementability and effectiveness of Alternative 1 and
provides a basis for the comparison of removal action alternatives presented in
Section 8. The assessment of implementability includes consideration of: 
Technical feasibility and availability of technologies 
Administrative feasibility 
Public acceptance 
Cost 
Criteria for assessing effectiveness considered here and in Section 8 include both shortterm
and long-term effectiveness. Long-term effectiveness includes consideration of: 
Overall protection of human health and the environment 
Ability to achieve RAOs 
Compliance with ARARs (including tribal treaty-protected resources) 
Reduction of contaminant toxicity, mobility, and volume 
7.1.7.1   Implementability 
The successful implementation of Alternative 1 will depend on effective planning and
the proper phasing of the work. The safe control of traffic and removal activities
within adjacent residential streets and the control of dust generation and offsite
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dispersion are examples of important factors to be considered. Soil excavation and
sediment removal will be implemented using established and proven technologies
that are readily available. The depth of soil removal in the upland portion will be
accomplished using appropriate dewatering, shoring, staging, and material handling
techniques. The alternative does not include any technologies that are experimental or
unproven. Nevertheless, the depth of soil excavation, presence of shallow
groundwater, and proximity of removal activities to the LDW can present challenges
for upland excavation that will have to be addressed through careful planning and
execution, including the potential use of physical barriers to control groundwater, a
well-point dewatering system, and an associated water treatment system. Sediment
removal will also need to be conducted in a highly controlled manner and with regard
for specific scheduling constraints (e.g., fish windows). 
An assessment of the administrative implementability of Alternative 1 must include
consideration of the multiple jurisdictions and regulations applicable to one or more of
the study area settings or particular features in which the action will be implemented
(i.e., the T-117 Upland Study Area, the Adjacent Streets and Residential Yards Study
Area, and the T-117 Sediment Study Area). Some of the site, for example, is located
within the County, and the remainder is within the City. The T-117 Sediment Study
Area is located within the sediment portion of the LDW; other areas are made up of
city street ROWs. As presented in Appendix G, there are a number of ARARs and
substantive requirements that include measures to safeguard aquatic resources that
must be considered prior to and during the removal action. Construction and 
permanent maintenance easements will also be required for the installation of a power
pole and associated power lines, and stormwater features on the T-117 Upland Study 
Area (see Section 7.3). Access agreements must also be established with those property
owners whose yards require remediation. 
7.1.7.2   Effectiveness 
Alternative 1 will be highly effective in terms of protecting human health and the
environment, complying with ARARs and achieving RAOs, including meeting criteria
for a broad range of possible future land uses and protection of terrestrial habitat,
where applicable. Contaminants that might otherwise migrate to the adjacent LDW
will be removed through the excavation of contaminated soil from the upland portions
of the T-117 EAA. Alternative 1 will remove source materialcontaminated soils,
including thatparticularly those in direct contact with groundwater and or that could
possibly come into contact with stormwater, as well as contaminated those present in
sediment. It will also include measures to address potential site recontamination. 
Short-term risks posed byin the proposed removal action exist because of the large
size and depth of the excavations. Engineering controls to prevent secondary impacts
of soil excavation and transport and sediment dredging and capping will be included
as part of the alternative. Special measures, including shoring, and dewatering will
likely be required to control groundwater influx that would otherwise occur in deep
excavations (i.e., those extending into the saturated groundwater zone). The removal
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of contaminated bank materials and upland soil in the vicinity of the bank will require
special safeguards to limit the potential for impacts on the adjacent LDW. These will
include working during low tides and the use of berms, temporary covers
(sand/fabrics), or sheet pile walls to isolate work areas. Other short-term risks include
the potential exposure of onsite workers and nearby neighbors to contaminants
through the ingestion of or dermal contact with soil or through the inhalation of
airborne dust. Proven safeguards are available to mitigate these risks and include the
use of protective clothing for workers and measures such as dust control and
monitoring and track-out prevention to protect the surrounding community. These
and other safeguards that will be set forth in a site-specific health and safety plan
developed concurrently with the NTCRA work plan. 
Of particular importance is the risk to public health and the environment that could 
result from air emissions (i.e., dust) during limited time periods. Dust could migrate
from T-117 to the surrounding community during grading activities. To mitigate 
potential dust risks, engineering controls such as water sprays will be employed, as
necessary, during construction to ensure that dust and particulates are within
acceptable regulatory levels. Perimeter air monitoring will be performed during the
removal action to monitor potential exposure to the public during excavation. Control
of odors that may be generated from the removal of the impacted soil will also be
addressed through the use of engineering controls similar to those used for dust.
These control measures, together with specific criteria for their application, will be
included in the NTCRA health and safety plans. 
The long-term effectiveness and permanence of Alternative 1 is expected to be
moderately high. Under this alternative, RAOs will be met even if sediment
concentrations at depth remain above SMS criteria because potential exposure will be
limited by clean backfill or capping. However, these materials could potentially
become exposed if overlying cover materials were inadvertently disturbed. 
Institutional controls would be required under Alternative 1 to reduce the potential for
the disturbance of the cap and require monitoring and maintenance. Caps would
likely include an armor layer that would be covered with a sediment layer designed to
withstand small- vessel anchorage, fishing, or clamming activities, with an
institutional control requiring cap monitoring and maintenance. Institutional controls
would be developed so as to not affect tribal treaty fishing rights. The details of
institutional controls would be set forth in an institutional controls implementation
plan, as described in Section 7.1.3. 
INSTITUTIONAL SAFEGUARDS TO PROTECT THE IN-WATER CAPS (I.E., RESTRICTIVE
COVENANTS AND MONITORING) WOULD BE NEEDED TO PROTECT AGAINST THE
POSSIBILITY OF CAP DISTURBANCE FROM ACTIVITIES SUCH AS BOAT
ANCHORING. THE CAP WILL INCLUDE AN ARMOR LAYER THAT WILL PROTECT IT
FROM DISTURBANCE BY TYPICAL BEACH USE, FISHING, AND CLAMMING THE
SELECTION OF SAFEGUARDS AIMED AT LIMITING CAP DISTURBANCE WOULD BE 
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DETERMINED BASED ON THE SPECIFIC ACTIVITIES THAT THEY SEEK TO
CONTROL, AND THE EFFECTIVENESS OF THESE SAFEGUARDS WOULD DEPEND
ON THE EXTENT TO WHICH THEY ARE ENFORCED. 7.2 ALTERNATIVE 2: 
UPLAND SOIL REMOVAL AND SEDIMENT EXCAVATION AND DREDGING 
As mentioned previously, Alternative 2 is the same as Alternative 1, except that
capping would not be used as an alternative sediment containment measure within
the T-117 Sediment Study Area for the purpose of meeting the prescribed sediment
RAOs. Instead, the RAOs would be met solely through a combination of sediment
excavation and dredging followed by backfilling with clean materials. Clean fill
materials will be used to restore the aquatic portions of the site to original grades
(except in the Marina), to backfill the T-117 Upland Study Area to an elevation of
approximately +14-ft MLLW, and to re-establish site grades in the Adjacent Streets
and Residential Yards Study Area. 
7.2.1  Site preparation 
The same preparation activities described for Alternative 1 would be required for 
Alternative 2. Areas for sediment handling and transfer equipment capacities might
need to be slightly larger to accommodate the increased material volumes from
dredging areas that would otherwise be capped in Alternative 1. 
7.2.2  T-117 Upland Study Area and Adjacent Streets and Residential Yards
Study Area removal activities 
The Alternative 2 removal activities for the T-117 Upland Study Area and Adjacent
Streets and Residential Yards Study Area are the same as those described for
Alternative 1. The approximate in-place volumes of soil anticipated to be excavated
from the T-117 Upland Study Area and Adjacent Streets and Residential Yards Study
Area are listed in Table 7-2. The estimated extent of the removal action in the T-117
Upland Study Area and Adjacent Streets is presented on Maps 7-2 and 7-3. 
7.2.3  T-117 Sediment Study Area removal activities 
Alternative 2 is the same as Alternative 1 regarding excavation and backfilling at the
T-117 Upland Study Area and adjacent shoreline bank as well as the Adjacent Streets
and Residential Yards. Alternative 2 only differs in the sediment removal area offshore
of the toe of the shoreline bank as shown on Maps 7-2 and 7-3. Alternative 2 requires
the dredging of contaminated sediment within the sediment boundary, including
dredging within the Marina to re-establish navigable depths within the Marina. The
dredged areas, except the Marina, will be backfilled with clean material to re-establish
site grades. A limited amount of sediment within the rock riprap along the toe of the
Marina shoreline contains elevated PCBs (i.e., samples Trans- A-sed, Trans- B-sed, 
and 99-G, as shown on Map 2-8). Rather than removing the riprap and undermining
the Marina shoreline, the sediment within the rip rap may be removed (manually at
low tide or by divers) or contained by a localized cover. The excavation and dredging
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contours for Alternative 2 are presented on Map 7-12 and shown on cross sections
presented as Figures 7-1 through 7-4. 
Dredging volumes under Alternative 2 will be greater than those for Alternative 1
because all of the subtidal area is dredged under Alternative 2. The dredged areas will
be backfilled to re-establish aquatic site grades so there is no net impact to aquatic
habitat elevations. The surface layer of backfill material will be imported, clean,
uncrushed sand and gravel of the appropriate size and composition to remain stable
under the range of LDW currents and maritime activities (e.g., boat wake, prop wash).
It is anticipated that the backfill would be placed with floating equipment, working at
higher tides, as necessary, to provide the needed draft for barges. The volume of
sediment to be removed and backfilled under Alternative 2 is summarized in
Table 7-4. 
Table 7-4.  In-place volumes of sediment to be removed and estimated sediment
backfill volumes under Alternative 2 
a
Study Area            Component       Quantity (cy) 
non-TSCA sediment      13,950 
T-117 Sediment Study Area 
TSCA sediment         50 
Total sediment to be removed                          14,000 
b
Material required for backfilling                             10,000
a
TSCA sediment is defined as sediment with total PCB concentrations  50 mg/kg. 
b
No backfilling in the Marina (approximately 4, 000 cy). 
cy  cubic yard 
PCB  polychlorinated biphenyl 
TSCA  Toxic Substances Control Act 
The duration of the marine construction for Alternative 2, for in-water dredging and 
backfilling, is estimated to be 30 to 35 working days. 
Dredging safeguards, material transfer, and monitoring would be the same as those
presented for Alternative 1. 
7.2.4  Landfill disposal of excavated and dredged materials 
Methods used for the management and disposal of excavated and dredged materials
under Alternative 2 are the same as those described for Alternative 1. The larger
volume of sediment removed under Alternative 2 will need to be considered in
specifying the operating parameters and sizes for the sediment handling and transfer 
areas. 
7.2.5  Site completion and coordination with future site uses 
As with Alternative 1, under Alternative 2, the T-117 Upland Study Area will be
backfilled to an elevation of at least +14 ft MLLW. However, final site design may 
change slightly depending on the timing of the ongoing evaluation and the selection of
the final site use (see Section 9.2). 
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7.2.6  Summary of estimated costs 
The total estimated cost for Alternative 2 is approximately $331.29 million (Table 7-65).
A detailed breakdown of the estimated costs and assumed contingencies is provided
in Appendix J. 
Table 7-65. Summary of estimated costs for Alternative 2 
a
Study Area                 Estimated Costs
T-117 Upland Study Area                      $20,100,000 
Adjacent Streets and Residential Yards Study Area       $76,6300,000 
T-117 Sediment Study Area                     $5,500,000 
Total estimated cost                            $331,2900,000 
a
Assumes baseline completion option for the T-117 Upland Study Area with the site restored to meet MTCA 
unrestricted criteria. 
EAA  early action area 
O&M  operation and maintenance 
T-117  Terminal 117 
7.2.7  Evaluation of Alternative 2 
This section discusses the implementability and effectiveness of Alternative 2 and
provides a basis for the comparison of removal action alternatives presented in
Section 8. 
7.2.7.1   Implementability 
The implementability of Alternative 2 is very similar to that of Alternative 1. The 
additional dredging of sediment associated with Alternative 2 will require some
additional in-water construction time (10 to 15 working days), which could extend the
duration of the removal action to accommodate seasonal restrictions on in-water work. 
7.2.7.2   Effectiveness 
The long-term effectiveness of this alternative is expected to be high. Sediment that
contains COCs above the action level will be removed, resulting in a higher degree of 
effectiveness and permanence than that for Alternative 1 (Section 7.1.7). 
7.3   PROJECT COMPLETION OPTIONS 
EPA has mandated site-specific goals for the removal action in the T-117 Upland 
Study Area. One of these goals is to develop removal alternatives that are consistent 
with a wide range of final site uses, not just those limited to industrial activities. The
Port is examining commercial development and habitat restoration alternatives for
Port property within the LDW, which includes the T-117 EAA, in coordination with
the appropriate agencies. 
This section describes two alternative site completion options (Options A and B) that
could be implemented following the NTCRA. These completion options could
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accommodate a variety of future uses and would replace the baseline completion
option that was included in the two removal action alternatives for costing purposes. 
The baseline completion option was assumed for the removal alternatives because it
represented a mid-point among the range of possible final site use configurations. The
two completion options presented here provide for a broad range of configurations
and topography to accommodate a wide variety of potential post-NTCRA
developments. It is expected that a final site use will be identified in time to be
incorporated into the NTCRA during the design phase. If this occurs, the baseline
completion option would not be implemented, and the final NTCRA design would
include restoration of the site to final grades appropriate to accommodate the selected
final site use. Soil excavation and sediment dredging or dredging/capping would still
be conducted to meet the RvALs within the removal areas and to the necessary
compliance depths relative to the completed (final) topography. The baseline
completion option described below and two alternative completion options would all
be protective and would meet the RAOs established for the T-117 removal action set
forth in this EE/CA. 
Option A, Restore the T-117 Upland Study Area to existing elevation  Under 
this option, removal excavations in the T-117 Upland Study Area would be
backfilled to achieve surface elevations similar to those of the existing T-117
Upland Study Area (elevation of approximately +18 to +21 ft MLLW). The 
shoreline bank below elevation +14 ft MLLW would be designed as described
in the removal action alternatives (with the same degree of improved aquatic
habitat), but the elevation of the bank and T-117 Upland Study Area would be
brought up to the final elevation of +18 to +21 ft MLLW. Restoring the T-117
Upland Study Area to the existing elevation would still meet the requirement
for "unrestricted land use" and could support use for commercial
redevelopment and/or public access. 
Option B, No backfilling of the T-117 Upland Study Area; transition directly to
habitat creation, among other site improvements  Under this option, a 
redevelopment project for the creation of aquatic habitat would be
implemented immediately following the removal action. Habitat creation 
would be coordinated with EPA and Ecology to ensure that any newly created
intertidal habitat (within the present T-117 Upland Study Area) would meet the
sediment RAOs at the appropriate point of compliance. The completion design
for Option B (as well as any later redevelopment action) would include
provisions for long-term site stability (i.e., protection against erosion and the
institution of protective covenants, as needed). The details on the design of the
restoration plan are still being developed; therefore, the final site configuration 
is unknown. As the restoration design progresses, it will be coordinated with
the NTCRA design to ensure that sediment and/or soil RvALs are being met. 
General cross sections of Options A and B are shown on Figure 7-7, along with the 
baseline completion approach, which was assumed for both removal action
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alternatives for costing purposes. All of the completion options (i.e., Options A and B
and the baseline completion option) will result in a site that is protective of human
health and the environment and will meet the established RAOs. The selection of the
appropriate completion option will be made at the time of remedial design based on
the results of site-use evaluations. 
















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Slipsheet (8-1/2 x 11) 

Figure 7-7. Upland completion options 
















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In the event that Option B is selected and can be integrated into the removal action
design, existing upland areas that would be converted into intertidal areas would be 
further evaluated as part of the redevelopment project and in accordance with the
sediment RAOsfor the sediment NTCRA. Upland soil that would underlie newly
created aquatic areas and be located within the applicable depth of compliance would, 
at a minimum, need to meet the sediment RvALs set forth in Section 4. The large
amount of excavation that will occur in the T-117 Upland Study Area under either
removal action alternative will remove contaminants to levels estimated to be below
the sediment RvALs at all upland locations, except one. This completion option would
change the location of the shoreline and could increase the salinity of groundwater
further inland. 
The large amount of excavation that will occur in the T-117 Upland Study Area under
either removal action alternative will remove contaminants to levels estimated to be
below the sediment RvALs at all upland locations, except one. A preliminary analysis
of contaminant distributions in the upland soil indicates that areas where soil 
contaminant concentrations after excavation will be below the upland soil RvAL but
not necessarily below sediment RvAL are limited to the area within the T-117 Upland 
Study Area on the west side near Dallas Avenue S. It is expected that this area would
remain as upland subsurface soil and would not transition to exposed sediment if a
habitat project were to be implemented. Furthermore, minor additional dredging
and/or capping would be performed, as necessary, during the redevelopment project
to ensure that soil beneath former upland areas that were newly converted to
intertidal areas would meet RAOs for sediment. 
Site completion under all options would include site grading and the installation of
stormwater features in the T-117 Upland Study Area and Adjacent Streets to facilitate
upland stormwater management. The installation of these features on the T-117
Upland Study Area would require an easement for construction as well as ongoing
maintenance. Furthermore, site completion under all options would provide for the
necessary easement to re-establish the LDW power pole crossing at the site. This
required easement is shown in a preliminary form in Figure 7-8Map 2-1. Final
easement requirements will be determined during the NTCRA design phase.
Regardless of how the removal action will be completed, the slope of the newly
established shoreline will be designed to improve on existing habitat conditions and
limit the potential for shoreline erosion. 
Either alternative or any completion option could influence the effectiveness of a
hypothetical monitored natural recovery regime for LDW sediment in the vicinity of
the T-117 EAA. These influences would be minimal because of the relatively small size 
of the T-117 Sediment Study Area (approximately 1.4 acres). 
The Alternative 1 baseline and completion option A would have little impact because 
these scenarios restore the shoreline and sediment to a topography similar to the
existing configuration. Alternative 2 with completion option As would also restore the
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shoreline topography. Although a cap would change the sediment grade, this would
have little effect because of the size of the projected cap area relative to the LDW. 
Completion option B with either alternative would have a relatively larger impact
because the shoreline and sediment grade would be changed. With this completion
option it is likely that the area would become more depositional because the
contouring for habitat would create depressions in the sediment and quiescent back 
water areas. 















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8    Comparative Analysis of Removal Action Alternatives 
This section presents a comparative analysis of the two removal alternatives based on
the criteria of implementability, effectiveness, and cost as defined in EPA's Guidance on
Conducting Non-Time-Critical Removal Actions Under CERCLA (1993). The primary
criteria to be considered are as follows: 
Implementability 
Technical feasibility and availability 
Administrative feasibility 
Effectiveness 
Overall protection of human health and the environment 
Achievement of RAOs 
Compliance with ARARs 
Reduction of toxicity, mobility, or volume through treatment 
Short-term effectiveness 
Long-term effectiveness and permanence 
Cost 
The discussion of removal action alternatives discussed in Section 7 serves as the basis 
for the comparative evaluation in this sSection. Throughout this discussion, the
specific elements that make each alternative unique are noted (see the discussions
entitled "Notable Differences"). As described in Section 7, both alternatives are
presumed to include similar completion approaches (i.e., to elevation +14 ft MLLW). 
8.1   IMPLEMENTABILITY 
This section discusses the three criteria that are important to the implementability of
the alternatives. The successful implementation of both Alternatives 1 and 2 will
depend to a large degree on the proper sequencing of removal work in the Adjacent
Streets and Residential Yards, T-117 Upland Study Area, and the T-117 Sediment 
Study Area. Sequencing is discussed in Section 9.3.1. 
8.1.1  Technical feasibility and availability 
8.1.1.1   T-117 Upland Study Area and Adjacent Streets and Residential Yards
Study Area 
Both alternatives are equal in terms of technical feasibility and availability for the
T-117 Upland Study Area and Adjacent Streets and Residential Yards Study Area.
Upland soil removal will be completed using commonly available construction 
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technologies and materials. Work in locations above the highest tide line in the LDW
can be completed at any time because it will not be impacted by tidal fluctuations in
the river. The upland work would preferably be conducted during the dry summer
months to avoid potential construction and runoff problems associated with excessive
rainfall. Excavated materials will be trucked offsite using conventional trucking
equipment. Bank removal will be completed from the upland when the tides are out or
with the use of an offshore barrier to isolate the inboard work area and facilitate access
throughout the range of tide stages. 
Notable Differences  None. 
8.1.1.2   T-117 Sediment Study Area 
In the intertidal mudflat, sediment removal for Alternative 2 and the partial sediment
removal and capping for Alternative 1 would be completed using commonly available
upland construction equipment and materials. Excavated materials would be trucked
offsite and imported material brought onsite using conventional trucking equipment.
The work for both alternatives can be completed when the tides are out and it would 
be possible to best control the work being completed. The work would ideally be
scheduled between May and August to maximize the number of days with the lowest 
tides. 
For submerged sediment within the removal boundary, the sediment removal for
Alternative 2 and the capping for Alternative 1 would be completed using commonly
available materials and floating construction equipment. Because of the relatively
short duration of the project (20 to 35 days), it is not anticipated that other sediment
cleanup projects being performed at the same time would have an adverse impact on
the availability of the equipment necessary to perform the work. 
Dredged materials could be readily moved offsite and imported material brought
onsite using conventional barges. The offloading of dredged sediment from barges to
trucks or railcars for landfill delivery could be completed at existing facilities (e.g.,
another Port terminal). The work for both Alternatives 1 and 2 would need to be
completed when tides are high to provide the needed draft for the floating equipment.
Further constraints on available work time could be imposed by seasonal prohibitions
on in-water work that have been established to protect certain fish species. The LDW
fish window is the period of time when in-water work can be conducted, and this
work must be coordinated with the tribes in advance. Typical fish windows for the
LDW occur from October 1 to February 15 but can vary from year to year depending
on the timing of the juvenile salmon out migration. Although in-water work can be
accomplished in a manner that will accommodate these constraints (as demonstrated
by other successful LDW projects), the overall project schedule may need to be
lengthened to account for these seasonal interruptions. Arrangements will need to be
made with the Marina to temporarily relocate some of the docks and floating
structures in the proximity of the sediment removal area. 

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Notable Differences  Alternative 1 will result in a reduction in the cross-sectional
channel area of the LDW, and a focused river hydraulics analysis will be needed to
establish the impact (if any) of the capping on the channel cross section in the LDW.
Alternative 1 would involve the removal of less sediment than would Alternative 2
and consequently would require 10 to 15 fewer low-tide days to complete. Both
alternatives would result in the placement of import material (cap material under
Alternative 1 and backfill under Alternative 2). This could affect the quality of clam
habitat, and this effect could be more significant under Alternative 1 which would
require erosion- resistant materials for the cap. For both alternatives, design details
would be developed with a goal of limiting possible habitat impacts and
accommodating fishing and clamming. The removal of less sediment under
Alternative 1 also decreases the potential forfrequency of exceeding turbidity limits, so
short-term risk is less for Alternative 1 than for Alternative 2. Map 7-3 shows the
differences in the removal and capping areas between the two alternatives. 
8.1.2  Administrative feasibility 
Administrative feasibility involves the activities needed to coordinate with other
offices and agencies (e.g., obtaining permits for offsite activities or ROWs for
construction). Very littleThe majority of the work for Alternatives 1 and 2 will be
completed on land owned or controlled by parties other than the City and the Port.,
including the Port-owned offshore area of the Marina. 
Administrative requirements will include the need for the CityThe City will need to
arrange for temporary road closures and/or special access arrangements within the
Adjacent Streets and Residential Yards Study Area when removal in that study area is
underway. Furthermore, access agreements will need to be established with property
owners whose yards require excavation. 
As described in Section 7, institutional controls would be required under Alternative 1 
to reduce the potential for the disturbance of the cap. These institutional controls
would also require monitoring and maintenance. The details of the institutional
controls would be developed in an institutional controls implementation plan during
design, and the institutional controls would likely include proprietary controls (i.e.,
restrictive covenants); enforcement tools (i.e., agency orders requiring monitoring and
maintenance); and informational devices (i.e., deed notice and state registry). Each of
these controls is considered administratively feasible. None of the institutional
controls would affect tribal treaty fishing rights. 
There are no apparent impediments to imposing restrictive covenants in order to
provide long-term protection of the sediment cap areas because all of the affected
tidelandInstitutional controls that would limit site disturbance of the sediment cap
under Alternative 1 would be developed as part of the design process. 

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The administrative feasibility of placing temporary barriers, such as berms or sheetpile
walls, at or immediately offshore of the T-117 shoreline to facilitate bank removal will 
be addressed during removal action planning. 
Notable Differences  Institutional controls (property deed restrictions, no-anchorage
areas) would be required for the sediment cap under Alternative 1. Overall reliance on
institutional controls, monitoring, and maintenance would be greater under
Alternative 1. 
8.1.3  Public involvement 
The Port, the City, and EPA will coordinate with the public on issues such as schedule,
transportation plans, monitoring plans, permitting, and BMPs. The Port and the City 
will coordinate with EPA and stakeholders to hold meetings or otherwise provide
information and receive input from stakeholders during the review of the EE/CA and
subsequent design and removal action work. These activities will focus on issues of
concern (e.g., truck traffic and control of the cleanup site, health and safety in the
project vicinity, and protection of natural resources). 
8.2   EFFECTIVENESS 
8.2.1  Overall protection of human health and the environment 
Alternatives 1 and 2 are identical for the upland portion of the T-117 EAA and
successfully meet the RvALs determined to be protective of human health and the
environment. The alternatives will reduce long-term risks to human health and the
environment by removing soil and sediment with COC concentrations greater than the
selected RvALs, or containing any remaining contaminated sediment with an
engineered aquatic cap. Both alternatives will achieve the RAOs and comply with all
ARARs (Section 4 and Appendix G, respectively). The alternatives rely on removal
and/or combined removal and /capping technologies, which are proven technologies
that have been used successfully. 
Notable Differences  Alternative 2 removes all of the sediment with COC
concentrations that exceed the RvALs within the mudflat and submerged portions of 
the T-117 Sediment Study Area, and thus does not include a cap. ; whereas In contrast,
Alternative 1 includes a combination of removal and capping, with the potential for
the subsequent disturbance of the cap, which could expose underlying contamination. 
8.2.2  Achievement of RAOs 
Both Alternatives 1 and 2 satisfy the RAOs for the T-117 EAA by creating a post 
removal condition that meets the site RvALs at the specified points of compliance. 
This is accomplished through the removal (Alternative 2) or a combination of the
removal and effective long-term containment of sediment (Alternative 1). 
Notable Differences  None. 
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8.2.3  Compliance with ARARs and other requirements 
ARARs were discussed in Section 4. Both alternatives will meet the substantive
requirements of ARARs. Both alternatives include the removal of contaminated soil to
allow for a broad range of future land uses, including potential redevelopment as
habitat, and are therefore equivalent in meeting ARARs pertaining to upland cleanup.
For the sediment removal, the SQS is applicable to the T-117 Sediment Study Area and
any areas where the cleanup or follow-on site development creates intertidal or
subtidal areas. Completion of either alternative will result in COC concentrations that
are well below the SQS because of the use of clean backfill or capping material. 
Compliance with the Endangered Species Act will be addressed in the biological
assessment to be completed during the design phase of the NTCRA. The removal
action is expected to be beneficial to threatened Chinook salmon because it greatly
reduced their potential exposure to PCBs and other COCs. Under the assumed
completion approach, the shoreline bank will be replaced at a grade that is less steep
(e.g., 3H:1V) than the existing grade and will provide both long-term stability and
improved habitat (i.e., natural sand and gravel substrate underlain by stabilizing layer
of quarry spalls) with a small net increase (less than 0.1 ac) in aquatic habitat
area.creage. 
Both alternatives will comply with TSCA because all soil and sediment with total PCB 
concentrations greater than 50 mg/kg will be designated for disposal at a TSCA
landfill, as described in Section 4.3.1.2. The extent to which the ARARs are met by each
alternative is summarized in Table 8-1. As presented in Table 8-1, the two alternatives
are similar and meet the same substantive requirements. 
Notable Differences  None. 







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Table 8-1.  Comparison of removal action alternatives relative to ARARs and other requirements TBC 
Compliance with ARARs and Other Requirements 
Regulatory Requirement                       Alternative 1                           Alternative 2 
ARARs 
The removal will comply with these requirements by meeting RvALs
Washington State Model Toxics Control
based on a broad range of possible future land uses and CULs protective Same as Alternative 1. 
Act (WAC 173-340-440) 
of upland terrestrial species in the upland areas 
Washington State Water Quality
The removal action will comply with these regulations through the
Standards for Surface Waters                                                         Same as Alternative 1. 
implementation of BMPs and a water quality monitoring program. 
(WAC 173-201A) 
Total PCB concentrations will be below the SQS for both alternatives    Total PCB concentrations will be below the
Washington State Sediment         because of the combined action of removal and the use of clean capping SQS for both alternatives because of the
Management Standards (WAC 173-204)  material. Restrictive covenants and monitoring will be required for     combined action of removal and the use of
sediment caps to ensure long-term compliance.                  clean backfill material. 
The removal action will comply with TSCA because all soil and sediment
Toxic Substances Control Act 
with total PCB concentrations greater than 50 mg/kg dw will be        Same as Alternative 1. 
(40 CFR 761) 
designated for disposal at a TSCA landfill. 
Other Requirements TBC 
Federal Water Pollution Control Act/
The removal action will comply with these regulations through the
Clean Water Act                                                                Same as Alternative 1. 
implementation of BMPs and a water quality monitoring program. 
(33 USC 1251-1376; 40 CFR 100-149) 
The removal action will comply with the substantive requirements of these
Construction in State Waters, Hydraulic
regulations by implementing BMPs for the protection of fish and shellfish, Same as Alternative 1. 
Code Rules (RCW 75.20; WAC 220-110) 
as recommended by the WDFW. 
Federal Endangered Species Act of
The removal action will comply with the substantive requirements of the
1973, 
act by implementing BMPs for the protection of fish and shellfish, as     Same as Alternative 1. 
16 USC 1531 et seq. 
recommended by NMFS and USFWS. 
(50 CFR 200; 50 CFR 402) 
Essential Fish Habitat provisions of the
The removal action will comply with the requirements of the act by
Magnuson-Stevens Fishery Conservation
implementing BMPs for the protection of EFH, as recommended by     Same as Alternative 1. 
and Management Act 
NMFS, and respond in writing to NMFS's recommendations. 
(50 CFR 600)

Table 8-1.   Comparison of removal action alternatives and ARARs (cont.) 
Compliance with ARARs and Other Requirements 
Regulatory Requirement                       Alternative 1                           Alternative 2 
These substantive permit requirements are
anticipated to be applicable to actions such
These substantive permit requirements are anticipated to be applicable to as dredging, which may affect the
Rivers and Harbors Appropriations Act    actions such as dredging, which may affect the navigable portions of the  navigable portions of the waterway.
(33 USC 403; 33 CFR 322)          waterway. Use of capping as a technology may require special review   Sediment removal and restoration to
and approval.                                        existing grade (except at the Marina, where
backfilling would not be done) is likely to
meet these requirements. 
Solid Waste Handling Standards 
The removal project will comply with these standards.               Same as Alternative 1. 
(WAC 173-350) 
Washington Dangerous Waste
The removal action will comply.                             Same as Alternative1. 
Regulations (WAC 173-303) 
Shorelines Management Act (KCC     The project will be planned and conducted to meet the substantive
Same as Alternative 1. 
Title 25)                           requirements for shoreline management. 
ARAR  applicable or relevant and appropriate      KCC  King County Code                     TSCA  Toxic Substances Control Act 
requirement                         NMFS  National Marine Fisheries Service          USC  US Code 
BMP  best management practice             PCB  polychlorinated biphenyl                USFWS  US Fish and Wildlife Service 
CFR  Code of Federal Regulations             RCW  Revised Code of Washington             WAC  Washington Administrative Code 
CUL  cleanup level                       RvAL  removal action level                    WDFW  Washington State Department of Fish
dw  dry weight                           SQS  sediment quality standards                   and Wildlife 
EFH  essential fish habitat                    TBC  to be considered 






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8.2.4  Reduction of toxicity, mobility, or volume through treatment 
Neither Alternative 1 nor Alternative 2 includes treatment technologies for reasons
detailed in Section 6. 
Notable Differences  None. 
8.2.5  Short-term effectiveness and implementation risk 
8.2.5.1   T-117 Upland Study Area and Adjacent Streets and Residential Yards
Study Area 
Short-term effectiveness includes an assessment of risks associated with the
implementation of the removal action (in contrast to long-term effectiveness, which
considers the effectiveness of the action after completion). Short-term effectiveness can
often be enhanced through the use of BMPs and appropriate planning, which will be
developed during the design phase. The removal of impacted soil from the T-117
Upland Study Area and Adjacent Streets and Residential Yards Study Area has the
potential for the short-term release of contaminated material to the river and
surrounding areas (e.g., adjacent properties) if not properly planned and controlled.
The highest concentrations of PCBs and other COCs are present in the upland soil, and
precautions will be taken during the removal action to ensure that the LDW and the
surrounding community will not be exposed to soil from the interior upland removal
areas. 
Runoff controls and other safeguards similar to those used during the TCRA (RETEC
2007b) will be implemented under both removal alternatives. Soil will be removed
from the shoreline bank under both alternatives, and safeguards will be used during
this phase of the work, including engineering controls (i.e., completing the excavation
during low tide, covering the excavated areas soon after they are exposed, and using
berms or sheetpile walls to isolate the work area from the river). Such measures will
greatly limit the potential for releases from the upland and upper shoreline work
zones. The completion of the upland/bank excavation from the top of the shoreline
berm to the intertidal area will ensure that any material released from the upper
reaches of the cut during excavation will be captured as part of the other removal
work in the lower portion of the bank (i.e., down to the intertidal mudflat elevation). 
Notable Differences  None, (because the same removal action is identified for both
Alternatives 1 and 2). 
8.2.5.2   T-117 Sediment Study Area 
The disturbance of impacted sediment within the removal area will likely result in
some short-term release of PCB-containing material to the immediate LDW vicinity of
the LDW. Engineering controls (i.e., completing the excavation in the mudflat when
the tide is low and covering the excavated face soon after it is exposed) may reduce the

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release potential from this portion of the sediment removal area. Experience at other
intertidal sediment remediation projects at the Hylebos Waterway (Section 7.1.3) has
shown that by completing the excavation during low tide, the excavated face does not
need to be covered soon after exposure in order to limit short- term releases. 
Scheduling the bank/mudflat soil removal during periods of very low tide during
May through August will allow for the greatest amount of work to take place during
days with very low tides, when the potential for sediment to be released as a result of
contact with the rising tide is lowest. 
Alternative 1 involves a partial removal, all above elevation 0 ft MLLW; whereas
Alternative 2 involves complete removal in the mudflat zone to a cut elevation as low
as -2 ft MLLW. Consequently, Alternative 2 has a slightly higher risk of release
because some of the excavation will may be completed in 1 to 2 ft of water near the
edge of the mudflat excavation if berms or sheet pile walls are not used for the
excavation. 
The removal of sediment from the submerged zone will be done using dredging
equipment rather than upland-based equipment. Engineering controls (i.e., dredging
and barge filling practices designed to limit turbidity) will limit the potential for
releases from the submerged zone to the extent reasonably possible. Water quality
monitoring will be conducted to verify that concentrations in the water column are
within acceptable limits. 
Notable Differences  Alternative 1 involves the capping of submerged sediment and
does not include dredging in the submerged portion of the sediment removal area;
Alternative 2 involves the complete removal in the submerged area. Thus,
Alternative 2 has a higher potential for release during implementation because of the
disturbance of submerged sediment by means ofduring dredging is typically greater
than that associated with controlled capping. Differences between the two alternatives
regarding the relative need for institutional controls is discussed in Section 8.2.6.2.
Alternative 1 would require institutional controls for the in-water cap. 
8.2.6  Long-term effectiveness and permanence 
8.2.6.1   T-117 Upland Study Area and Adjacent Streets and Residential Yards
Study Area 
Both Alternatives 1 and 2 involve the permanent removal of COC-contaminated
material from the T-117 Upland Study Area and Adjacent Streets and Residential
Yards Study Area to meet the specified RAOs. For these areas, both alternatives are
equivalent in terms of potential long-term effectiveness and permanence. 
Notable Differences  None. 


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8.2.6.2   T-117 Sediment Study Area 
Alternative 1 relies on the long-term effectiveness of sediment capping at locations
where this technology is used. Removal provides the greatest long-term reliability
because contaminated sediment is removed and thus not available for potential release
to LDW sediment in the future. Alternative 2 does not involve any significant in-water
capping. However, under Alterative 2, a limited amount of sediment within the rock
riprap along the toe of the Marina shoreline contains elevated PCBs (i.e., samples
Trans- A-sed, Trans- B-sed, and 99-G, as shown on Map 2-8). Rather than removing
the riprap and undermining the Marina shoreline, the sediment within the riprap may
be removed (manually at low tide or by divers) or contained by a localized cover. 
The cap proposed for Alternative 1 would be designed to remain stable and provide
long-term containment of the remaining impacted material beneath the capped areas.
The T-117 Sediment Study Areacap would be located outside of the fFederally
authorized navigation channel, which is is generally the area outside of areas of
activity where ship traffic or prop wash could cause damage. However, vessel traffic 
outside of the navigation channel is not uncommon and could result in the
disturbance of the cap. 
The long-term reliability of sediment caps would be augmented with institutional
controls as described in Section 7, can be maintained that wouldincluding restrictive
covenants and informational devices to limit the potential for cap disturbance, along
with enforcement tools and enhanced through the implementation of in an operation,
maintenance, and monitoring plan (OMMP) that would require periodic monitoring
and maintenancerepair of the cap as well as adaptive management, if necessary. The 
cap's performance would be monitored to ensure long-term containment and the
protection of human health and the environment. EPA typically requires that a cap's
performance be assessed at least once every 5 years for as long as deemed necessary 
Monitoring a cap's performance will be regularly required as specified in an EPA-
approved OMMP to ensure the long-term containment of contaminants beneath the
cap. to ensure the long-term containment of contaminated sediment remaining on site 
beneath the cap. Ecology has similar monitoring and periodic review requirements set
forth under MTCA (WAC 173-340-410 and 420) that must be considered as an ARAR
for Alternative 1. Additional discussion of long-term cap monitoring is included in
Section 9.3.3. 
Notable Differences  The lLong-term effectiveness and permanence reliability of
Alternative 1 depends on continued integrity and performance of the sediment cap,
which would also require institutional control to ensure long-term effectiveness and
permanence. Alternative 2 does not include capping, so it has a greater degree of
permanence and long-term effectiveness without reliance on institutional controls. 
Thus, Alternative 1 has a higher potential of future release of COCs as compared to
Alternative 2. This potential is associated with the possibility of disturbance of the
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cap. However, this potential is considered small for Alternative 1 and would be
minimized and managed through cap design elements, institutional controls,
monitoring, and maintenance as needed. Finally, Alternative 2 also allows for
maximum design flexibility in that the final site contours can be designed without the
need to accommodate permanent intertidal cap structures. This will be particularly
advantageous in locations where habitat redevelopment or other final site uses will be 
selected and implemented in cooperation with the South Park Community. 
8.2.6.3   Magnitude of risk 
Upon completion, Alternative 1 would have a slightly higher magnitude of risk than
would Alternative 2. This higher risk is associated with the relatively large portion of
contaminated sediment that would remain in place, isolated beneath the sediment cap,
in the T-117 Sediment Study Area. Applicable design guidance would be used in the
design of the cap if Alternative 1 were to be selected, but the cap would need to be
closely monitored to ensure its integrity and performance. Cap integrity and
maintenance would also need to rely, in part, on the institutional controls that have
been described previously in this EE/CA. The extent to which some of these controls
are implemented and maintained, and their effectiveness over the life of the remedy, 
could contribute to the relative future risk associated with the capping option. In
contrast, Alternative 2 will have a slightly lower magnitude of risk because all of the
contaminated sediments will be removed and a cap will not be needed to isolate
material that would otherwise remain in place. Both alternatives have the same
estimated magnitude of risk for the upland areas of the T-117 EAA because the
removal actions proposed for those areas will be the same. 
Notable Differences  The relative magnitude of risk associated with Alternative 2 is
slightly higher than that for Alternative 1. This is higher risk would result from
contaminants and residuals that would still remain beneath the sediment cap located
within the LDW after completion of the NTCRA. 
8.3   COST 
The estimated costs for Alternatives 1 and 2 are summarized in Table 8-2. These costs
are based on present value20 and include long-term monitoring and maintenance
costs.21 When long-term monitoring and maintenance costs are considered, the cost
difference between Alternatives 1 and 2 is $1.5 million. 


20 Present net worth analysis based on 2008 year 0, and 5% net discount rate. 
21 Long-term monitoring costs based on four events over 10 years. Maintenance costs were assumed to
have a present value of one-fourth the construction cost of the cap. 
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Table 8-2.  Comparison of costs for Alternatives 1 and 2 
a
Estimated Cost
Component                Alternative 1       Alternative 2 
Capital costs                                     $14,790173,000      $15,236860,000 
Contingencies, design, management and oversight          $14,016620,000     $154,280679,000 
Long-term monitoring and maintenance                     $430,000          $100,000 
Sales tax                                        $1,89031,000      $1,910854,000 
Total estimated cost (rounded)                         $310,7400,000      $331,2900,000 
a
Present net worth analysis based on 2008 year 0, and 5% net discount rate. 
8.4   SUMMARY OF COMPARATIVE ANALYSIS 
In summary, Alternatives 1 and 2 are similar in their implementability and
effectiveness. The estimated cost for Alternative 1 is slightly less than that for
Alternative 2, although the c.osts for both alternatives are considered to be relatively
high relative to other sites where less-restrictive RAOs are required and a broader
range of lower-cost alternatives are considered appropriate. Alternative 2 offers the
advantage of the increased removal of COCs from the T-117 Sediment Study Area
without reliance on capping, but has slightly more significant short-term water quality
impacts during excavation and dredging and a slightly higher overall cost than does
Alternative 1. Alternative 1 offers the advantage of a lower potential for short-term
releases because of the lower volume of sediment removed, less reliance on over-water
dredging, and lower initial cost. However, Alternative 1 also has a slightly higher
potential of long-term contaminant release from the capped areas and higher longterm
costs associated with cap monitoring and adaptive management, if necessary.
Table 8-3 provides a summary comparison of the two removal action alternatives.
Removal volumes are listed, together with summary comments on the comparative
criteria discussed in Section 8.2. 






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Table 8-3.  Summary of comparative analysis 
Ability to Meet RAOs 
Component                   Alternative 1                            Alternative 2 
Protection of human health
Alternative is protective.                                Alternative is protective. 
and the environment 
a                                                     a
Achievement of RAOs       RAOs  are achieved.                            RAOs  are achieved. 
ARARs             Alternative complies with ARARs.                 Alternative complies with ARARs. 
Effectiveness 
Alternative is effective and permanent. 
Alternative is effective and permanent. 
Long-term effectiveness and   Removes contaminated soil from the T-117 Upland Study Area
permanence            and Adjacent Streets and Residential Yards Study Area.       Removes contaminated soil from the T-117 Upland Study Area
and Adjacent Streets and Residential Yards Study Area. 
Sediment cap requires long-term monitoring and maintenance. 
Upland removal: Contaminated soil excavated under tightly
controlled conditions, greatly reducing the short-term potential    Upland removal: Contaminated soil excavated under tightly
for release to surrounding areas or the LDW.               controlled conditions, greatly reducing the short-term potential
Sediment removal: Completed from upland during low tides as   for release to surrounding areas or the LDW. 
feasible to reduce risk of COC releases to LDW. Alternative     Sediment removal: Completed from upland during low tides to
does not involve excavation in water because upland excavation  reduce risk of COC releases to LDW. Alternative involves some
Short-term effectiveness 
will not go deeper than 0 ft MLLW contour.                 upland-based excavation in the water close to the existing 0 ft
Alternative 1 involves dredging of about 35% of the dredged     MLLW contour. 
volume estimated for Alternative 2. Short-term impacts to water   Alternative 2 involves more extensive submerged zone dredging
quality will be of slightly shorter duration as compared with those  than does Alternative 1. Short-term impacts to water quality will
for Alternative 2. Short-term impacts to water quality will be      be managed through engineering controls and BMPs. 
managed through engineering controls and BMPs. 
Implementability 
Upland soil removal under both alternatives can be readily      Upland soil removal under both alternatives can be readily
implemented with proper site preparation and water          implemented with proper site preparation and water
management measures in place. Shoring and barriers will need  management measures in place. Shoring and barriers will need
Upland removal 
to be included in the removal design to ensure upland         to be included in the removal design to ensure upland
remediation areas are not inundated by the river and deeper     remediation areas are not inundated by the river and deeper
excavations can be completed with stable side walls.          excavations can be completed with stable side walls. 


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Ability to Meet RAOs 
Component                   Alternative 1                            Alternative 2 
Intertidal bank and mudflat work is best completed in May
through August when very low tides occur. 
Alternative 1 does not involve any upland-based sediment
Intertidal bank and /mudflat work is best completed in May
removal below elevation 0 ft MLLW and is easier to implement
through August when very low tides occur. 
than Alternative 2. 
Alternative 2 involves some upland-based sediment excavation
Work is completed with conventional upland and waterwayin
the water at the existing 0 ft MLLW contour (2 ft deep to
based equipment. 
Sediment removal                                                  elevation -2 ft MLLW) and is more difficult to implement than
Alternative 1 involves mudflat and submerged zone capping that  Alternative 1. 
will result in a slight decrease of the cross-sectional area of the
Work is completed with conventional upland and waterway-
LDW. 
based equipment. 
Work will be completed on land owned or controlled by the Port. 
Work will be completed on land owned or controlled by the Port. 
There are no apparent impediments to imposing restrictive
covenants to provide long-term protection of the capped area
because all of the affected land is controlled by the Port. 
b
Cost                              $310,7400,000                              $331,2900,000 
a
RAOs: 
Human health  seafood consumption. Reduce human health risks associated with the consumption of resident LDW fish and shellfish by reducing
sediment and surface water COC concentrations to protective levels. 
Human health  direct contact. Reduce human health risks associated with exposure to COCs through direct contact with sediments and incidental
sediment ingestion by reducing sediment concentrations of COCs to protective levels. 
Ecological health  benthic. Reduce toxicity to benthic invertebrates by reducing sediment COC concentrations to comply with SMS. 
Ecological health  seafood consumption. Reduce risks to crabs, fish, birds, and mammals from exposure to COCs by reducing concentrations of COCs in
sediment and surface water to protective levels. 
Sediment Protection. Reduce PCB concentrations in upland soils to ensure protection of sediments. 
a 
Volumes of PCBs removed are estimates. 
b
Includes the baseline completion approach. Costs are life- cycle costs. For details see Appendix J. 
ARAR  applicable or relevant and appropriate requirement                  PCB  polychlorinated biphenyl 
BMP  best management practice                                Port  Port of Seattle 
COC  contaminant of concern                                  RAO  removal action objective 
LDW  Lower Duwamish Waterway                             SMS  Washington State Sediment Management Standards 
MLLW  mean lower low water                                 T-117  Terminal 11-7 

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9    Recommended Removal Action Alternatives and
Implementation 
This section presents the conclusions for the EE/CA and discusses: 
The recommended removal action alternative  The EE/CA recommends
Alternative 2 for the T-117 NTCRA. 
Removal action sequencing and schedule  The sequencing, which is
proposed to start in the Sediment Study Area and progress upland, finishing
with the cleanup of the Adjacent Streets and Residential Yards. The cleanup
implementation is anticipated to begin in 2012. 
NTCRA work plan development  The work plan will be provided as part of
the T-117 NTCRA design. 
Long-term operation, maintenance, and monitoring planOMMP  The OMMP
will be developed during the T-117 NTCRA design. 
9.1   RECOMMENDED REMOVAL ACTION ALTERNATIVE 
The recommended alternative for the T-117 NTCRA is Alternative 2. The key
advantage of Alternative 2 is that it provides for maximum long-term effectiveness
and permanence. Although Alternative 2 would cost slightly more to implement
because of the added quantity of dredged material, this addition cost will be offset in
part by the elimination of lower post-NTCRA cap monitoring and performance review 
costs that would be required under Alternative 1. 
Both alternatives have the potential for short-term impacts associated with the release
of COCs from the disturbance of contaminated sediment during either dredging or
capping. Alternative 2 also has the greater potential for the disturbance of
contaminated sediment because it involves more dredging, which increases greater 
short-term impacts, associated with additional dredging, ande dredging disturbs more
sediment than does capping. In either case, but these short-term impacts of capping
and dredging can be reducedmitigated through the use of proper BMPsdredging
project design and controls. 
Because Alternative 2 does not involve capping, it does not require institutional
controls to protect the sediment. Institutional controls would be required under
Alternative 1 to reduce the potential disturbance of the cap. These institutional
controls would also require monitoring and maintenance. While Alternative 1 has a
higher potential for the future release of COCs compared with Alternative 2, this
potential is considered small and would be limited and managed through appropriate
cap design, institutional controls, monitoring, and maintenance, if needed. 

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Alternative 2 also allows for maximum design flexibility because final site contours
can be designed without the need to accommodate permanent intertidal cap , which 
structures. This will be particularly advantageous in locations where habitat
redevelopment or other final site uses areto be selected and implemented in
cooperation with the South Park Community. Final site contours can be designed
without the need to accommodate permanent intertidal cap structures. Under
Alternative 2, A limited amount of sediment located within the spaces between the
rock riprap along the toe of the Marina shoreline contains elevated concentrations of
PCBs. Rather than removing the rip rap and undermining the Marina shoreline, the
sediment within the rip rap may be removed and/or contained by a localized cover. 
capping would be limited to only those locations where dredging is not feasible (e.g.,
around the base of intertidal structures). Alternative 2: 
Is protective of human health and the environment 
Achieves the site-specific RAOs 
Complies with ARARs 
Provides long-term effectiveness through the removal of the majority of
contaminant mass at the site 
Is feasible and relies on technologies that are readily available 
Monitoring and maintenance of the T-117 Sediment Study Area will be a part of the
post-NTCRA activities. 
9.2   REMOVAL ACTION SEQUENCING AND SCHEDULE 
9.2.1  Sequencing 
The successful implementation of the removal action will depend to a large degree on
the sequencing of removal work in the T-117 Upland Study Area, the Adjacent Streets
and Residential Yards Study Area, and the T-117 Sediment Study Area. An example of
project sequencing is provided in Table 9-1. Other sequencing approaches that do not
require a barrier wall may be considered during the design stage of the project.
Sequencing within the T-117 Upland Study Area and Adjacent Streets and Residential
Yards Study Area will take into consideration access logistics, potential traffic impacts
on the surrounding community, and the limited availability of soil and sediment
staging areas. Remedy implementation and the scheduling of in-water construction
activities will be coordinated with the tribes to minimize impacts on tribal fishing. 
Proper sequencing within the T-117 Sediment Study Area will involve the removal of
the most highly contaminated sediment first in order to eliminate the potential for
recontamination of the remaining sediment areas. 


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Table 9-1.  Example NTCRA sequencing overview for primary construction
tasks 
Step      Task                  Benefits                       Issues 
No aquatic impacts to be mitigated No in-
May require pre-excavation as a
water work permit required 
result of the presence of debris 
Install barrier wall   No in-water work window schedule
Will likely require steel Z-piles 
1    in vicinity of top      constraints 
of bank                                             Will likely require interim
No net loss of aquatic habitat 
groundwater control, treatment,
Ability to control groundwater discharge
and discharge 
during upland activities 
No aquatic impacts to be mitigated No in-
water work permit required 
No in-water work window schedule         Capping of sediment under
Excavate bank
constraints                            Alternative 1 should immediately
and intertidal
2                   Bank excavation before sediment dredging      follow the bank/mudflat
mudflat from
greatly reduces sediment recontamination      excavation (e.g., same tidal
upland at low tide 
potential                               cycle). 
Excavation allows for better removal along
piles than dredging 
Dredging sediment prior to upland
excavation means upland is still in place to
provide a location for sediment staging, if      Capping of sediment under
needed                         Alternative 1 2 should
Upland source controlled by piles,           immediately follow the
3    Dredge sediment 
groundwater control                     bank/mudflat excavation or
May be able to use groundwater treatment     dredging (e.g., same tidal
system for dewatering sediment, if required      cycle).. 
Limits amount of work under in-water work
window 
Control of upland impacts Removal of
contaminants and physical
containmentControl orf upland control of
contaminant pathways to sediment allows
Will require appropriate security
schedule flexibility so the upland cleanup
and access control if upland left
can be coordinated with and habitat
as an open excavation behind
restoration to be coordinated if appropriate
Excavate T-117                                  the sheetpile wall or similar
mitigation agreements are in place 
4    Upland Removal                                         barrier 
Sheetpile wall or similar barrier may be left in
Area                                             Groundwater control, treatment
place after cleanup without creating net loss
and discharge may continue to
of aquatic habitat 
be required until piles are
Habitat design flexibility is maintained by
removed 
allowing re-grading behind sheetpile wall or
similar barrier 
Barrier wall limits potential for releases
during construction 





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Step      Task                  Benefits                       Issues 
Existing stormwater controls could stay in
place until all sediment and upland
excavation is complete 
Dallas Avenue S excavation could be
coordinated with the adjacent excavation in
the T-117 Upland Study Area 
Requires stormwater controls to
Excavate       Adjacent Streets excavation could be
be implemented during the
Adjacent Streets     coordinated with soil removal if required in
5                                                         excavation of the Adjacent
and Residential     the Residential Yards 
Streets and Residential Yards
Yards Study Area   Stormwater drainage could be incorporated
Study Area 
into the final completion of the T-117 Upland
Study Area 
Because this study area has less
contaminated material, it will be cleaned up
last to prevent recontamination from the
cleanup activities at other study areas 
T-117  Terminal 117 
The following is a detailed example of how the project work could progress and
demonstrates how the actions could be implemented in phases. It is assumed that the
work would progress according to the general order of primary construction tasks
outlined in Table 9-1. 
1.  Relocate marina docks as needed to allow access for sediment removal and
undertake environmental surveys of T-117 EAA study area buildings (for
asbestos and lead paint) as may be needed prior to demolition. 
2.  Establish traffic control measures within the site and for safe access to and from 
the site. 
3.  Abandon all onsite wells located within the study areas. 
4.  Construct temporary decontamination and work areas for demolition of T-117 
EAA structures. 
5.  Establish and monitor perimeter controls. 
6.  Protect catch basin inlets and provide drainage control as needed for
demolition. 
7.  Demolish and remove T-117 EAA buildings and other above-ground structures
to prepare for soil removal. 
8.  Re-establish work and decontamination areas, as necessary, to make effective
use of new areas within the T-117 Upland Study Area formerly occupied by
buildings. 
9.  Remove known subsurface features within the T-117 Upland Study Area as
needed to facilitate subsequent large-scale soil removal (e.g., USTs, remnant
utility corridors, and building foundations and floor slabs from removed

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structures) and re-stabilize removal areas using temporary backfill, paving, or
other appropriate measures. 
10. Re-evaluate site drainage and enhance as needed to ensure proper controls and
treatment. 
11. Construct soil and sediment staging areas and establish surface drainage
controls (i.e., stormwater diversion, interception, and treatment) for the first
stage of soil removal. 
12. Establish vehicle loading and wheel wash facilities. Implement monitoring
required for soil removal activities. 
13. Install sheetpile wall, as needed, along the top of the shoreline bank. Install
barriers and groundwater controls (dewatering or subsurface barriers) as
needed to protect the LDW and limit or divert groundwater influx during bank
and sediment removal work. 
14. Excavate soil from the bank and adjacent intertidal mudflat. Load soil into haul
trucks for offsite disposal at Subtitle D or C landfill in stages in order to ensure
a controlled and manageable removal process. 
15. Adjust and relocate site controls, drainage collection and treatment facilities,
and staging areas for next phase of soil and sediment removal. 
16. Implement additional measures as needed to ensure stability and proper
drainage controls within the T-117 Upland Study Area (grading, planting, and
paving). 
17. Construct temporary sediment receiving and staging facilities for in-water
dredging operations, if needed. Dredge sediment within the T-117 Sediment
Study Area and backfill as required. Conduct monitoring as required during
dredging to ensure compliance with specified water quality parameters and
proper positioning of the dredge. Transport dredged sediment directly to the
upland area or transport sediment by barge to an onsite or offsite
transfer/loading facility for subsequent loading into haul trucks or rail cars for
disposal at Subtitle D or C landfill. Dismantle and restore upland sediment
staging areas and associated facilities upon completion of dredging. 
18. Install subsurface soil dewatering systems (e.g., hydraulic barriers, well-point
system) in close proximity of deep inland (non-shoreline) soil removal prisms
for the removal of groundwater, establish onsite storage and treatment for
extracted groundwater, and dewater the excavated areas (details regarding the
extent to which these prisms are dewatered and excavated at once or in stages
will be set forth in the detailed project plans). 
19. Excavate soil from removal prisms located above the water table in phases.
Load soil into haul trucks for offsite disposal at Subtitle D or C landfill, and
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grade and/or provide temporary covers and drainage controls (as needed) to
stabilize removal areas, particularly those located along the shoreline bank.
Adjust staging areas and drainage controls as needed to accommodate 
subsequent soil removal phases and ensure continued control of site runoff. 
20. Excavate deep inland soil removal prisms and backfill to above the water table
as necessary to provide proper drainage, allow continued site access, and
reduce the accumulation of rainwater in isolated removal prisms. Load soil into
haul trucks for offsite disposal at Subtitle D or C landfill. 
21. Conduct soil removal in Adjacent Streets and Residential Yards in stages and in
accordance with detailed project plans and with agreements with affected
property owners. Modify street access controls as removal progresses within
the street alignments to limit the impacts on residential access. 
22. Construct new stormwater infrastructure. 
23. Conduct monitoring and control dust and runoff during soil removal to ensure
protection of the public and prevent recontamination of adjacent areas. Restore
streets and yards and install improved drainage collection and treatment
facilities. 
24. Install long-term monitoring wells as needed to monitor post-removal
performance. 
For this example, it was assumed that the T-117 Upland Study Area would be
completed to a minimum elevation at or above +14 MLLW in accordance with the
baseline completion option. Alternate completion options, such as those described in
Section 7.3 and Figure 7-7, could require slightly different phasing and backfilling
approaches for the upland soil and near-shore sediment removal activities. 
9.2.2  Schedule 
The following schedule elements are based on the T-117 EE/CA SOW: 
2010 
EE/CA is approved, and EPA issues an amended Action Memorandum. 
NTCRA design process is initiated. 
2011 
Consent Order issued to respondents. 
2012 to 2013 
NTCRA design and work plans are completed. 
NTCRA is implemented. 

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2013 to 2014 
Site re-development (e.g., habitat restoration) is initiated. 
The This draft final final EE/CA will be submittedis for public comment. within
30 days of receipt of EPA comments on the interim draft final EE/CA. The public
comment period is 60 days. The final EE/CA will be published within 30 days after 
EPA's EPA will prepare publication of their a responsiveness summary based on
public comments and issue an amended Action Memorandum for the T-117 EAA
NTCRA, which will replace the Action Memorandum issued on July 22, 2005. This
Action Memorandum will be issued no later than September 30, 2010. 
The initial NTCRA design package will be prepared and submitted to EPA within 1 
year (2011) after EPA issues an the amended Action Memorandum. based on an 
approved EE/CA (i.e., sometime in 2011) and will likely be finalized sometime in
2012. The implementation of the NTCRA will begin the following year (20132012) after
EPA has approved the design package. Timing of the EE/CA, the design phase, and
NTCRA implementation may be adjusted, if necessary, to accommodate a selected site
completion option (see Section 7.3). External factors, such as coordination with other
LDW projects, the South Park Bridge replacement, weather, and salmon migration
may also affect the NTCRA implementation schedule. Typical fish windows for the
LDW occur from October 1 to February 15 but can vary from year to year depending
on the timing of the juvenile salmon out- migration. Activities that occur after
completion of the EE/CA are not part of the current ASAOC and are subject to
revision in accordance with the negotiated Consent Order with EPAnext agreement. 
9.3   NTCRA WORK PLAN DEVELOPMENT 
The work plan for the 2006 TCRA (RETEC 2006) will serve as a starting point for the
NTCRA work plan and will be modified and augmented as needed to address the
requirements set forth in the eventual NTCRA SOW. The TCRA work plan included
health and safety procedures; routine inspection, maintenance, and monitoring tasks,
such as cap inspection and maintenance, stormwater system maintenance, soil
handling procedures, notification requirements, groundwater monitoring procedures
and other performance standards directly applicable to the T-117 EAA and the
NTCRA project. Several of the key elements of the NTCRA work plan are discussed in
the following subsections. 
9.3.1  Health and Safety 
A detailed HSP will be prepared for the NTCRA and will be applicable to all site
workers, as well as those providing oversight. The plan will also address controls and
safety measures designed to protect personnel and nearby residents. 

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9.3.2  Site Controls 
The NTCRA work plan will specify temporary erosion and sediment controls for all
aspects of the construction work, including excavation, and soil or sediment
stockpiling in the truck loading areas. Erosion control measures and controls for
stormwater will be developed according to guidance contained in Ecology's
Stormwater Management Manual for Western Washington (Ecology 2005b) and the King
County, Washington, Surface Water Design Manual (King County 2009). Particular 
emphasis will be placed on control measures that prevent the offsite transport of
contaminated materials (e.g., truck wheel washes, stormwater controls, and dust
controls). The NTCRA work plan will include a schedule for the inspection and
maintenance of these controls during all applicable phases of the project. 
Noise monitoring and abatement criteria and procedures will also be specified. The
NTCRA work plan will also include procedures for air quality and meteorological 
monitoring similar to those used for the TCRA to ensure that potential airborne
contaminants are monitored so that they can be sufficiently controlled. Excavation,
grading, and capping activities will be carried out in a manner that minimizes dust
and the emission of odor (i.e., fugitive emissions). Stockpiles will be covered when
there is no loading or unloading activityto the extent practicable to further minimize
dust during construction. Water trucks will be used to control site dust, as necessary. 
9.3.3  Performance mMonitoring 
The NTCRA remedial design work plan will include, but not be limited to, a sampling
and analysis plan that specifies the sampling objectives and methods to be used for
verification that soil and sediment above the RvALs have been removed. The plan will
include a schedule of samples to be obtained, as well as a map indicating appropriate
sampling locations within the T-117 EAA study areas. 
9.3.3.1   Post-dredging verification sampling 
Post-dredging verification sampling will be performed at locations where sediment
has been removed as part of the NTCRA. The purpose of this sampling will be to
augment existing data and document that sufficient sediment has been removed to
meet RvALs where no capping or fill is anticipated. Sampling will include surface
samples to document that acceptable target COC concentrations have been achieved
throughout the depth of compliance. At locations where capping or filling is
anticipated, surface sediment samples will be collected prior to the placement of new
material in order to establish pre-cap placement COC concentrations. These data will
be used to evaluate the results of subsequent long-term cap/removal area
recontamination monitoring. 


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9.3.3.2   Soil excavation and sidewall verification sampling 
Verification sampling of excavation sidewalls and bottoms will be performed as part
of the NTCRA to confirm that the COC concentrations that remain at the boundary of
the removal areas are below the soil RvALs. It is anticipated that for the T-117 Upland 
Study Area excavation samples will consist primarily of composites from each
sidewall and bottom of pre-designated removal areas. 
Verification sampling in the Adjacent Streets and Residential Yards Study Area will be
limited to bottom samples because horizontal boundaries have been set by the MIS
sampling method per agreement with EPA. In some cases, additional sampling of
adjoining areas (e.g., un-sampled portions of yards adjacent to portions of yards being
excavated) may be required. If sampling results indicate that soil at the vertical limit of
excavation contains PCBs and dioxins and furans at concentrations that exceed their
respective RvALs, additional excavation will be performed up to the full depth of
compliance (i.e., 15 ft). At locations where removal did not extend to the full depth of
compliance , additional excavation may be performed if the verification sampling
results indicate that remaining soil contains PCBs and dioxins and furans target COCs
at concentrations that exceed their respective RvALs. 
9.3.3.3   Material specifications and construction QA/QC 
The NTCRA work plan will include detailed specifications for all material placed
onsite, including imported structural fill; seed beds; gravel; material placed under
asphalt, concrete, or roads; backfill for yards or upland soil or sediment landscaped
areas with no structural featuresnon-structural areas; and sediment cap materials. 
There will be no caps in the Adjacent Streets and Residential Yards, caps will be use 
only in the sediment areas or upland areas that may become sediment. Specifications
will include compaction rates, material size, and specific product types. A construction
QA/QC plan that describes how construction procedures and material specifications
will be verified, as well as any material testing that may be required following
placement of construction components will be prepared for the T-117 NTCRA. 
9.3.3.4   Monitoring of dredging activities 
Monitoring will be conducted during dredging activities and will include periodic
turbidity measurements at upstream and down-current locations required by the
water quality certification, as well as visual observations for floating debris and
sheens. Periodic depth soundings will be conducted to ensure that the dredging is
removing the designated material without excessive over-dredging. Response actions
will be described in the NTCRA project plans. 
9.45  ADDITIONAL INFORMATION NEEDS 
This section identifies additional data and information needss to be considered before
implementation of the removal action. These additional needs are summarized in

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Table 9-2. This information will be ,evaluated during the design phase, and
incorporated in the design report. Activities needed to ensure that the removal action
is being conducted in accordance with the removal action work plans and design and
that the sRAOs are being met were described in Section 9.3. Post-removal action
monitoring to evaluate the long-term effectiveness of the removal action and inspect 
for potential recontamination is described in Section 9.5.
Table 9-21.  Supplementary information needed to support the removal action
design 
Information Need                           Rationale 
Design 
Additional Streets and Yards Study Area Information 
Assess groundwater quality in portions of the Adjacent Streets and
Additional gGroundwater quality data 
Yards Study Area and provide better hydraulic gradient information 
Determine horizontal extent of removal areas at some yard
Soil conditions 
locations. Determine vertical extent of soil removal in yards. 
Additional RAA Information 
Further assess recontamination potential to post-removal
Additional groundwater monitoring 
downgradient areas 
Storm solids quality in the Marina catch
Further assess recontamination potential. 
basins 
Marina NPDES stormwater discharge data  Further assess recontamination potential. 
Map of Marina stormwater system and
Further assess recontamination potential. 
drainage basins 
Additional Groundwater and Geotechnical Information 
Additional hydraulic conductivity and pump  Needed for dewatering system design, if necessary, and posttest
data                           removal recontamination assessment. 
Additional groundwater monitoringd and   As needed to support design and post-NTCRA sediment
horizontal and vertical gradient information   recontamination evaluations 
Limited pre-design tidal study            As needed to supplement existing tidal study data 
Geotechnical boring datas             As needed to support design 
Sources of shoreline seeps and possible
As needed to address active seeps in the removal action design 
control options, if needed 
Refinement of excavation prism 
Identify potential locations for supplementary pre-design sampling, 
Excavation prism data 
as needed. 
Site Preparation and Constraints 
Hazardous materials assessment 
Needed prior to demolition of T-117 Upland buildings. 
(e.g., lead paint and asbestos survey) 
Mapping of subsurface debris and       Determine locations of former foundations, buried concrete, septic
/obstructions                       tank, and backfill areas that might hinder excavation. 
Utility locate                          Identify current utility information. 
SCL tower location and /design          Integrate with removal action activities and site completion design. 
SPU sStormwater discharge location and
Integrate with removal action activities and site com pletion design. 
design 
Marina dock design                 To facilitate temporary relocation during sediment removal action. 

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Information Need                           Rationale 
Coordination of Final Grade for Site Restoration TransitionHabitat 
Conceptual restoration grading plan       Integration of final land use (e.g., habitat) with removal action 
Community 
Development of community protective     Minimize exposure of residents. 
measures 
NPDES  National Pollutant Discharge Elimination System 
NTCRA  non-time-critical removal action 
RAA  recontamination assessment area 
SCL  Seattle City Light 
SPU  Seattle Public Utilities 
T-117  Terminal 117 
9.4.1  Additional Streets and Yards Study Area iInformation 
Additional information regarding groundwater beneath the Adjacent Streets and
Residential Yards is needed in order to better assess groundwater quality and provide
a baseline understanding of the hydraulic gradients and groundwater flow directions 
in portions of the Streets and Yards Study Area. The number and location of
additional pre-design groundwater monitoring wells to be installed and monitoring to 
be conducted to verify that groundwater beneath this study area is not impacted will
be evaluated in the design phase. 
Additional soil sampling in yards will be conducted during the design phase. Some
yard areas that have not been sampled and are adjacent to DUs identified for removal
will be sampled to define the extent of removal. Sampling to determine the vertical
extent of removal in yards is also anticipated prior to removal. 
9.4.2  Additional RAA iInformation 
Additional groundwater monitoring is planned in order to further assess the potential
for groundwater from these two properties to contribute to recontamination. Data
necessary to assess some of the pathways are limited. The adequacy of the upgradient
and downgradient monitoring well network in the vicinity of the Basin Oil property
will be reviewed and, if necessary, an additional well will be installed to evaluate
groundwater quality associated with that EAA. Additional monitoring wells may also
be needed to assess groundwater flow directions near the boundary between T-117
Upland Study Area and the Marina. This is primarily a post- NTCRA consideration,
but monitoring wells can be installed during the design phase to provide useful
information. 
Section 5.2.1.3 described the need for additional information regarding the Marina 
storm drain system in order to fully evaluate the potential for sediment
recontamination. A map of the Marina storm drain system and a new outfall to the
LDW were identified during a recent site visit. This additional information will be

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used to assess the potential for the transport of COCs from the Marina to the T-117
Sediment Study Area. If it is concluded that the stormwater pathway poses a risk of
sediment recontamination, then additional stormwater controls and/or monitoring
will be required. These will be developed in cooperation with the Marina owner and
in consultation with Ecology. 
9.4.3  Additional gGroundwater and gGeotechnical iInformation 
Groundwater monitoring to date has focused on groundwater quality, observations of
non-aqueous-phase liquid and calculations of groundwater flow direction. Prior to the
design of the removal action, pump tests will likely be performed in select wells in
order to estimate hydraulic conductivity. This information could be useful in the
design of dewatering systems asthat may be needed to allow for deep excavation
during soil removal. 
Several additional pairs of groundwater monitoring wells may be installed to measure 
vertical groundwater gradients at select locations within the site. These well pairs
include one deep well and one shallow well. The difference in observed water levels in
each well provides an indication of upward or downward groundwater gradients
between the two depths at which the wells are screened. 
The methods and results of tidal studies already completed at the site will be reviewed
to determine the extent to which they meet data needs for the removal action design. 
If data gaps that cannot be addressed by the above-described pump tests, are noted, a 
limited pre-design tidal study will be performed using select wells within the
expanded monitoring well network to supplement the understanding of hydraulic
conductivity across portions of the site. The methods and data quality objectives for
the study will be included in a work plan to be submitted to EPA for approval prior to
implementation. 
The removal action designers may require additional geotechnical information to
assess soil conditions relative to excavation, shoring, or final site grades. Should this
need arise, geotechnical borings will be advanced at locations within the EAA, either
as a stand-alone field task or in coordination with the installation of monitoring wells 
or other subsurface work (e.g., additional soil sampling). The possible sources and, if
needed, control methods for shoreline seeps will also be addressed during the
remedial design phase. 
9.4.4  Refinement of eExcavation pPrisms 
The proposed T-117 Upland Study Area soil removal prisms are discussed and
presented in Section 7.1.2. As noted therein, the locations and depths of these prisms
will be refined during final design and execution The existing removal prisms will be
reviewed during the removal action design to identify locations where there may be
uncertainty regarding the required extent of removal. Those locations where
additional pre-design sampling is needed to refine the depth and/or lateral extent of
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soil removal will be identified. A work plan for addressing soil removal data gaps will
be prepared and submitted to EPA for review prior to implementation. 
9.4.5  Site pPreparation and cConstraints 
Table 9-2 identifies a number of information needs necessary to provide the level of
detail needed for final removal action design. Remaining structures within the T-117
Upland Study Area will need to be demolished and removed prior to excavation. A
hazardous materials assessment will be needed to ensure that this work includes the 
abatement of any hazardous materials that may be present in these structures (e.g.,
asbestos or lead paint). Known subsurface structures and utilities will also need to be
identified and shown on project drawings. These include the former utility corridors,
underground tanks, septic tank, former building foundations, backfill areas, gas and
water lines, electrical lines, and other features and utilities that may need to be
protected or will require special methods for removal and disposal. 
Several design constraints will need to be addressed in the removal action and site
completion designs. The first is the foundation and easement for restoration and
maintenance of the western tower of Seattle City Light's high- voltage cable span
across the LDW. The required easement and tower location and design will need to be
identified so they can be integrated into the overall removal action design. The other
design constraint involves SPU's plans to restore stormwater discharge to the LDW 
from a limited portion of the Streets and Yards Study Area through an outfall to be
located somewhere within the T-117 EAA shoreline. The outfall location will need to
be specified together with the appropriate outfall design in coordination with the
eventual site completion design., This will ensure that the outfall can be integrated
into the overall removal action and site completion. Information on the Marina's dock
design and an access agreement with the Marina will also be needed to facilitate the
planning for temporary dock relocation and subsequent restoration before and after 
sediment removal in the marina vicinity. 
9.4.6  Coordination of final grade for site restoration transitionhabitat 
The NTCRA will be coordinated with known future site use concepts for the
restoration of the T-117 EAA after completion of the soil and sediment removal
activities. Available information on the final site configurations will be considered in
the development of final site grades. If no site configuration is selected in time for the
removal action design, then the site will be restored to the baseline completion grade. 
9.54 LONG-TERM OPERATION, MAINTENANCE, AND MONITORING PLAN 
Post-NTCRA conditions at the T-117 EAA will be monitored and maintained to ensure
that the RAOs and RvALs are being met, there is compliance with ARARs, and the
remedy continues to be protective of human health and the environment. A long-term
OMMP will be prepared in accordance with appropriate guidance documents WAC
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173-340-410 during the design phase of the NTCRA and will address the final site
configuration, site uses, caps, drainage systems, habitat areas, and additional
redevelopment details. The post-NTCRA OMMP is envisioned to be a single
document prepared with EPA, and Ecology, and with stakeholder review and input.
The OMMP will include sampling and analysis plans as appendices, as well as a
schedule for implementation. Each section of the plan will address each of the
principal study areas, groundwater monitoring, and the monitoring and maintenance
requirements for storm drainage systems serving the upland portions of the EAA.
upland habitat resources. The post-removal monitoring plan will be designed to
evaluate the effectiveness of source controls measures put in place. These source
controls will include periodic comprehensive review of SPU and Port stormwater data
for discharges, acquisition of Marina discharges data for sediment COCs, and
monitoring of groundwater to establish baseline conditions and changes to flow and
character that may occur after the NTCRA. Elements addressed in the OMMP will
include, but not necessarily be limited to, the following: 
Post-removal site conditions and property uses 
Utility locations 
Site controls, institutional controls, and access restrictions 
Perimeter security fencing and on-site buildings 
Inspection and maintenance of upland caps and coversareas 
T-117 EAA inspection, monitoring, and maintenance 
Groundwater and seep monitoring 
Stormwater system descriptions, operation, maintenance, and storm solids 
monitoring 
Erosion and sediment controls 
Stormwater systems 
Documentation and reporting 
Health and safety and waste management for routine and non-routine
maintenance 
The OMMP will also address procedures for managing underlying site soil that may
be encountered at depth during any future during post-NTCRA construction within
the upland portions of the T-117 EAA (i.e., after completion of the removal action and
restoration work done as part of the NTCRA). These procedures will include making
necessary notifications, implementing health and safety measures, using appropriate
methods for soil stockpiling, performing analytical testing, and pursuing options for
soil reuse or disposal at the offsite waste management facility. Additional discussion
of the OMMP elements for each T-117 EAA study area is provided in the following
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subsections. A summary of subjects and activities to be addressed in the OMMP is
presented in Table 9-3. 
Table 9-3.  Subjects and activities to be addressed in the T-117 OMMP 
Subject or Activity                             Rationale 
Post Removal Action Conditions and Facilities 
Site features                        Document final locations 
Stormwater drainage and treatment
Document final locations 
systems 
Informational signage                Document locations and address maintenance 
Utility locations                        Document final locations 
Stormwater 
Ongoing assessment of recontamination potential in the EAA and
Stormwater monitoring 
the RAAs 
Stormwater system maintenance        Preventative measure for recontamination, source control 
Stormwater treatment system operation    Preventative measure for recontamination, source control 
Groundwater and Geotechnical Information 
Development of post-removal groundwater  Necessary to conduct post- removal action groundwater monitoring 
monitoring network                 and tidal study 
Groundwater monitoring              Verify that post- removal groundwater RvALs are being met 
To determine how the removal action alters groundwater flow,
Post- removal tidal study 
particularly at the south end of the Marina 
Sediment Removal Area Monitoring 
Sediment area reconnaissance         Performance monitoring of sediment backfill/cap areas, if necessary 
Sediment sampling                Assessment of recontamination 
Requirements for Upland Subsurface Construction 
To ensure that Port and City control post-removal activities as
Notifications prior to construction 
appropriate within the EAA 
To ensure that drainage, backfill areas, and erosion control
Construction restrictions 
measures are not compromised 
Soil handling, disposal, and backfill       To ensure safe handling and proper disposal and that final site
procedures                      conditions are properly maintained 
Site restoration                      To ensure future construction area(s) are properly restored 
Upland Area Inspections 
Performance of erosion control measures
(pavements, backfill, planted areas,       Source control measure for preventing recontamination. 
BMPs) 
Response Actions and Adaptive Management Strategies 
Groundwater                   Identify process if post- removal- action groundwater exceed RvALs. 
Identify process if post- removal- action stormwater solids exceed
Stormwater 
sediment RvALs. 
Identify process if post- removal- action soil becomes
Upland areas 
recontaminated and exceeds RvALs. 
Identify process if post- removal- action sediment becomes
Sediment area 
recontaminated and exceeds RvALs. 

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Page 266

BMP  best management practice 
EAA  early action area 
OMMP  operation, maintenance, and monitoring plan 
RvAL  removal action level 
9.54.1 T-117 Sediment Study Area 
Long-term monitoring of sediment removal areas will include both physical and
chemical monitoring to assess site integrity and potential recontamination. Although
the intent of the selected alternative is to not rely on capping, if any limited areas are
capped (e.g., immediately around in-water structures where dredging might not be
feasible), then physical monitoring would be conducted in those areas to evaluate the
physical stability of the cap. This would include measurements to evaluate cap
thickness and sediment particle size and bathymetric measurements to evaluate
evidence of scour from vessel movement or from high-flow events. The Port intends to
monitor sediment quality within the T-117 Sediment Study Area, particularly near
outfall and seep locations, to determine if recontamination is occurring. Chemical
testing will be used following the NTCRA to evaluate ensure that RAOs RvALs,
ARARs, and removal objectives are being met, the NTCRA is protective of human
health and the environment, and source control continues to be assessedcontinue to be
met and assess source control progress with respect to potential recontamination. 
9.54.2 T-117 Upland Study Area 
Post-NTCRA operation, maintenance, and monitoring activities for the T-117 Upland
Study Area will depend to a large degree on the final site use of this area. Special
controls and mMaintenance procedures and periodic monitoring will be required to 
maintain ensure that and protect any future habitat resources as that may be
established meet their respective performance criteria. If the site is redeveloped for 
tenant use, then measures will be needed to make sure tenant activities do not
compromise the performance of the NTCRA or pose a threat of recontamination to the
T-117 Sediment Study Area. 
The TCRA work plan that was completed for the T-117 Upland Study Area in 2006
(RETEC 2006) provides a good model for post-removal O&M activities, including the
monitoring and maintenance of stormwater conveyances and erosion and stormwater
controls, inspection and repair of paved areas, and procedures for documenting O&M
activities. In addition to these elements, the OMMP will also include prescribed
adaptive management procedures to be followed in the event that inspection and
monitoring activities detect potential soil erosion and/or recontamination of the T-117
Sediment Study Area originating from the T-117 Upland Study Area. 
Long-term O&M The OMMP will also include a description of necessary will also
discuss (if necessary) procedures for any future post-site development or construction
work. These will include notifications prior to construction to ensure that the Port and

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Page 267

City are made aware of work plans and that appropriate measures are in place to
preserve site drainage controls, backfill, and other key structures. Procedures for
proper site restoration will also be specified and followed. penetration of the capped
areas or excavation at depths that might encounter underlying site soils or sediment.
These procedures would include health and safety standards, issues associated with
soil stockpiling or analytical testing, and soil reuse or disposal options at the disposal
facility. In accordance with the above documents, soil will need to be handled and
managed in a manner that is protective of human health and the environment. Site
maintenance staff and contractors will be required to follow the relevant OMMP the
same procedures as those outlined in the future NTCRA work plan when when
performing any post-removal maintenance and construction activities at the T-117
EAA. These procedures will include notification requirements (including
contingencies for any activities beyond the planned scope), soil handling procedures,
waste management plans and procedures, and required measures for site restoration. 
Groundwater monitoring will also be required to check for the potential
recontamination of the T-117 Upland Study Area and the T-117 Sediment Study Area.
Groundwater monitoring points will be located along the future shoreline and Dallas
Avenue S.will be located upgradient of the zone of impacted groundwater (i.e., in the
vicinity of the boundary between theT-117 Upland Study Area and Dallas Avenue S),
with selected wells monitored periodically to confirm stable or decreasing COC
concentrations. A full tidal study will be undertaken using monitoring wells within
the T-117 upland areas to evaluate the post-removal groundwater regime and how the
modified shoreline and site grade has influenced groundwater flow patterns. 
Monitoring well installation, development, gGroundwater sampling and tidal studies 
will be completed in accordance with an approved field sampling plan (FSP) and
quality assurance project plan (QAPP) to be developed in conjunction with the
OMMP. The FSP will include details on sampling methods and frequency, including a
long-term monitoring schedule. The QAPP will include project organization,
objectives, activities, and quality procedure to be implemented during the compliance
monitoring actions. 
9.54.3 Adjacent Streets and Residential Yards Study Area 
As discussed in Section 5.2, since the cessation of asphalt manufacturing facility
operations in the mid-1990s, the potential for the recontamination of soils has largely
been restricted to the redistribution of existing contaminants. The NTCRA is expected 
NTCRAs are expected to eliminate the potential for recontamination to T-117 Upland
Study Area and Adjacent Streets and Residential Yards Study Area soils from this
historical source. 
9.54.3.1  Stormwater 
Stormwater runoff from the Adjacent Streets and Residential Yards Study Area is
currently collected in two separate systems that can be roughly divided into areas
Lower Duwamish Waterway Superfund Site:                              Revised EE/CA 
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Page 268

west and east of 17th Avenue S (see Map 2-2). To the west, runoff is currently
discharged to the CSS. The cleanup of both of these areas will trigger the stormwater
requirements of SMC 22.800 and Directors' Rule 2009-005 (SPU), 17-2009 (DPD) (City
of Seattle 2009a). Cleanup west of 17th Avenue S will likely consist of upgrading streets
and curbing to current codes, with continued discharge to the CSS. Cleanup options
for the area east of 17th Avenue S will include the installation of a permanent
stormwater collection/treatment system in accordance with the City and County
stormwater codes with discharge to the LDW. The final configuration will be
determined in the design phase of the NTCRA and coordinated with the final
completion of the T-117 Upland Study Area (e.g., matching drainage and grades with
topography of final upland configuration). The method of treating runoff from the
adjacent streets will be determined during design. Options include biofiltration
swales, filter strips, bioretention cells, wet vaults, and media filtration. The treatment
system will be operated and maintained in accordance with SPU protocols. SPU
employs standard protocols, which define procedures for inspecting and maintaining
the treatment system and associated structures, for each type of system to ensure that
these systems remain functional. 
Stormwater solids monitoring will continue to be performed in accordance with the
City's source-tracing program, which is administered by the LDW SCWG. This
monitoring will be coordinated with Ecology and EPA to verify that the stormwater
solids are not a recontamination concern for LDW sediments. 
After completion of the NTCRA and implementation of stormwater treatment
measures, SPU will monitor the drainage system to evaluate the effectiveness of the
removal action and treatment system in controlling PCBs and other contaminants in
the runoff from this area. A detailed post-NTCRA monitoring program will be
developed during project design;, however, it is anticipated that storm drain
monitoring will be conducted by the City and in conjunction with the larger LDW
source control program. As currently envisioned, drainage system monitoring will
focus on evaluating the chemical characteristics of solids present in this system.
Samples of storm solids have proven to be an effective means for identifying pollutant
sources and have been used as a benchmark in the assessment of the potential for
stormwater solids to recontaminate LDW sediment. Stormwater solids results will be
compared with SMS, and threshold concentrations will be identified, which, if 
exceeded, will trigger additional source investigations. Currently, CSL concentrations
are used as a benchmark for triggering source tracing. An adaptive management
strategy that will phase in increasingly more aggressive source investigations until the
source(s) of any future contamination is identified and controlled will be developed.
The adaptive management plan would specify the following: 
Continued monitoring of solids as may accumulate in stormwater structures
(e.g., traps, catch basins, manholes) for the presence and concentration of COCs. 

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If concentrations of COCs approach some source control reference levels in
storm solids samples, the City will determine the source and any additional
controls that may be warranted, in which case, storm solids will continue to be
monitored once the new/additional control is in -place. 
If additional control of COC sources is not feasible, then additional stormwater
treatment will be evaluated. 
9.54.3.2  Groundwater 
Section 2.3 discusses groundwater conditions beneath the Residential Sstreets and
Adjacent Yyards Study Area. Available data indicate that groundwater beneath
Residential Streets and Adjacent Yards Study Area has not been impacted. Based on
the depth to groundwater (approximately 12 ft) and generally shallow depth of soil
removal prism (anticipated to be no greater than 6 ft bgs), it is anticipated that
groundwater will not be impacted by the NTCRA. Nevertheless, a pre- and post-
NTCRA groundwater monitoring program is necessary, and a groundwater
monitoring program for the Adjacent Streets and Residential Yards Study Area will be
implemented. The need for and design of a pre- and post-NTCRA groundwater
monitoring is anticipated, and a program for Adjacent Streets and Residential Yards
Study Area will be evaluated during the design phase of the NTCRA. 
9.5.4   Long-term OMMP summary 
The post-removal monitoring plan will be designed to evaluate the long-term
effectiveness of the NTCRA in the three T-117 EAA study areas, including compliance
with RAOs and RvALs, effectiveness of source control and other recontamination 
prevention efforts. The plan will also include procedures for identifying any
recontamination effects on the post-NTCRA site and appropriate responses. This may
involve strategic sediment sampling (i.e., sampling focused on potential source
discharge areas, such as outfalls and seeps) within the T-117 Sediment Study Area,
periodic comprehensive review of SPU stormwater data for discharges, the collection
of data from Marina discharges for sediment COCs and monitoring of groundwater to
establish a groundwater baseline conditions and changes to flow and characteristics 
that occur as a result ofbecause of the NTCRA. 




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Page 270

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