6a - T-91 permit renewal

TERMINAL 91 TANK FARM 
RCRA PERMIT RENEWAL APPLICATION 









August 2019

TERMINAL 91 TANK FARM 
RCRA PERMIT RENEWAL APPLICATION 

Prepared for: 
Port of Seattle 
PO Box 1209 
Pier 69 
Seattle, WA 98111 
(206) 728-3000 
www.portseattle.org 


Prepared by: 
Pacific Groundwater Group 
2377 Eastlake Avenue East, Suite 200 
Seattle, Washington 98102 
206.329.0141 
www.pgwg.com 


August 23, 2019 
JG1601 
T91RCRAPermitv8-23-19.docx

TABLE OF CONTENTS 
A.   PART A OF THE RCRA PERMIT APPLICATION ...................................................................................... 5 
B.    FACILITY DESCRIPTION AND GENERAL PROVISIONS ...................................................................... 6 
B.1     GENERAL FACILITY DESCRIPTION ................................................................................................................ 6 
B.1.1   Facility Owner/Operator ......................................................................................................................... 7 
B.1.2   Terminal 91 History ................................................................................................................................. 7 
B.1.3   Materials Historically Handled at the Facility ........................................................................................ 9 
B.1.4   Plant Management ................................................................................................................................... 9 
B.1.5   Summary of Waste Types Listed in the Part A ......................................................................................... 9 
B.1.6   Tank Storage and Treatment Operations ................................................................................................. 9 
B.1.7   Detailed Process/Activity Descriptions ................................................................................................... 9 
B.2     SEISMIC CONSIDERATION ........................................................................................................................... 10 
B.3     TRAFFIC INFORMATION ............................................................................................................................... 10 
B.4     TOPOGRAPHIC MAPS ................................................................................................................................... 10 
C.   WASTE CHARACTERISTICS ...................................................................................................................... 11 
D.   PROCESS INFORMATION ........................................................................................................................... 12 
E.    RELEASES FROM SOLID WASTE MANAGEMENT UNITS .................................................................. 13 
E.1     RELEASES ................................................................................................................................................... 13 
E.2     STATUS OF CORRECTIVE ACTIONS .............................................................................................................. 13 
E.2.1   Summary of Corrective Action Activities Under Agreed Order ............................................................. 14 
F.    PROCEDURES TO PREVENT HAZARDS .................................................................................................. 15 
F.1     SECURITY.................................................................................................................................................... 15 
F.1.1   Security Procedures and Equipment ...................................................................................................... 15 
F.1.2   Waiver .................................................................................................................................................... 15 
F.2     INSPECTION PLAN ....................................................................................................................................... 15 
F.3     PREPAREDNESS AND PREVENTION REQUIREMENTS .................................................................................... 15 
F.4     PREVENTIVE PROCEDURES, STRUCTURES, AND EQUIPMENT ....................................................................... 15 
F.5     PREVENT REACTION OF IGNITABLE, REACTIVE, AND/OR INCOMPATIBLE WASTES ..................................... 15 
G.   CONTINGENCY PLAN .................................................................................................................................. 16 
H.   SECTION H TRAINING PLAN ..................................................................................................................... 17 
I.    SECTION I CLOSURE PLAN AND CLOSURE COST ESTIMATES ...................................................... 18 
I.1   CLOSURE ......................................................................................................................................................... 18 
I.2   CLOSURE COST ESTIMATE .............................................................................................................................. 18 
I.3   NOTICE IN DEED OF ALREADY CLOSED DISPOSAL UNITS ............................................................................... 18 
I.4   POST-CLOSURE PLAN ...................................................................................................................................... 18 
I.5   LIABILITY REQUIREMENTS .............................................................................................................................. 18 
J.    OTHER FEDERAL AND STATE LAWS ...................................................................................................... 19 
J.1      FEDERAL REQUIREMENTS ........................................................................................................................... 19 
J.1.1    Wild and Scenic Rivers Act .................................................................................................................... 19 
J.1.2    National Historic Preservation Act of 1966 .......................................................................................... 19 
J.1.3    Endangered Species Act ......................................................................................................................... 19 
J.1.4    Coastal Zone Management Act .............................................................................................................. 19 
J.1.5    Fish and Wildlife Coordination Act ....................................................................................................... 19 
J.1.6    RCRA Corrective Action Program ......................................................................................................... 20 

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J.2      STATE REQUIREMENTS ............................................................................................................................... 20 
J.2.1    National Emission Standard for Asbestos .............................................................................................. 20 
J.2.2    State Water Pollution Control Standards .............................................................................................. 20 
J.2.3    Minimum Functional Standards for Solid Waste Handling ................................................................... 20 
J.2.4    State Environmental Policy Act ............................................................................................................. 21 
J.2.5    Puget Sound Clean Air Act .................................................................................................................... 21 
J.2.6    Model Toxics Control Act ...................................................................................................................... 21 
J.3      LIST OF PERMITS ........................................................................................................................................ 21 
K.   CERTIFICATION ............................................................................................................................................ 22 


















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FIGURES 
Part A 
Figure A1:  Vicinity Map 
Figure A2:  Aerial Photograph and Existing Facility 
Figure A3:  Site Photograph and Existing Facility 
Part B 
Figure B1:   Vicinity Map 
Figure B2:  Location of Terminal 91 Tank Farm Lease Parcel 
Figure B3:   Adjacent Land Use 
Figure B4:   TFLP Former Operational Areas 
Figure B5:  Traffic Flow Patterns 
Figure B6:   Local Wind Patterns 
Figure B7:   On Site Storm Water Drainage Patterns 
Figure B8:   100 Year Flood Plain 

ATTACHMENTS 
Attachment 1: Agreed Orders DE8938 and DE24768 
Attachment 2: Completed AOCs and SWMUs Requiring Corrective Action 









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ACRONYMS 
AO          Agreed Order 
AOC        Area of Concern 
CMP        Compliance Monitoring Plan 
OMP        Operations and Maintenance Plan 
EPA         Environmental Protection Agency 
HAZWOPER  Hazardous Waste Operations and Emergency Response 
LNAPL      Light Non-Aqueous Phase Liquid 
MTCA      Model Toxics Control Act 
PSCAA      Puget Sound Clean Air Agency 
RCRA       Resource Conservation and Recovery Act 
RFA         RCRA Facility Assessment 
RI              Remedial Investigation 
SEPA        State Environmental Policy Act 
SWMU      Solid Waste Management Unit 
TFAA       Tank Farm Affected Area 
TFLP          Tank Farm Lease Parcel 
WAC        Washington Administrative Code 










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A. PART A OF THE RCRA PERMIT APPLICATION 
All information submitted in Part A of this Permit Renewal Application is solely for the
purpose of renewing and extending the Part B Permit for corrective action activities. 
The Resource Conservation and Recovery Act (RCRA) permit for Terminal 91 was originally
associated with an active dangerous waste treatment and storage facility operated by
Burlington Environmental Inc. (Burlington) at the Tank Farm Lease Parcel (TFLP). Burlington
operated the TFLP under lease from the Port of Seattle (Port), the past and current
owner. Burlington submitted the final documentation certifying above-ground closure of
the Final Status (Part B) portions of the TFLP to the Washington Department of Ecology
(Ecology) on March 3, 1997. Ongoing corrective actions at the Terminal 91 facility are
being conducted by the Port under agreed orders (AOs) with Ecology. Copies of AOs
DE8938 and DE24768 are Attachment 1. Proposed AO DE24768 is being reviewed concurrent
with this permit application, AO DE8938 is already being implemented. Because
the TFLP dangerous waste operations have been closed and the only ongoing operations
at the facility are related to corrective actions, much of the information typically required
in Part A and Part B permit applications is not pertinent to this application. For Part A: 
Process codes are not listed in Sections XII and XIII because there are no active pro-
cesses at the facility. 
Dangerous wastes are not listed in Section XIV because dangerous wastes are no longer
accepted at the facility. 
Figures referenced in the Part A form are included as Figures A1 through A3. 










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B. FACILITY DESCRIPTION AND GENERAL PROVISIONS 
B.1   GENERAL FACILITY DESCRIPTION 
The Port is the current Site Owner and Site Operator for the purposes of this application. 
The USEPA/Ecology Facility Identification Number for the site is WAD980982706. 
Contact information for the Port is: 
Port of Seattle 
PO Box 1209 
Pier 69 
Seattle, WA 98111 
(206) 728-3000 
The Terminal 91 facility is located at 2001 West Garfield Street in Seattle, King County,
Washington. Refer to Figures B1 and B2 for vicinity and facility maps. Land use at Terminal
91 is zoned by the City of Seattle as General Industrial. Figure B3 shows the land
use and zoning categories for the area surrounding the Terminal 91 facility. 
Terminal 91 covers approximately 210.6 acres owned by the Port. The property consists
of an upland area, two piers (Piers 90 and 91), and about 35 acres of submerged lands
around the piers referred to as the submerged lands area. Previous reports and documents,
including AO DE8938, divide the facility into the upland, the tank farm lease parcel
(TFLP), tank farm affected area (TFAA), and submerged lands area. 
The facility is regulated under RCRA due to historic hazardous waste operations at the
TFLP. That former facility's regulatory status subjects all contiguous Port-owned property
comprising Terminal 91 to corrective action requirements. The hazardous waste operations
were conducted by Chemical Processors, which was also named Burlington Environmental
Inc, Philip Environmental, and Philips Services Corporation. Those operations
were associated with RCRA hazardous waste permit number WAD000812917. The
Port was the owner of the TFLP formerly leased and operated by Burlington, which
leased property that consisted of three tank yards and associated buildings located on approximately
four acres within the 216-acre Terminal 91 facility (Figure B4). Burlington
and the Port terminated the lease for the TFLP and Burlington completed the closure of
above-ground treatment and storage units at its permitted operations in approximately
1997. Hazardous waste ID WAD000812917 was withdrawn effective December 31, 2003
under agreement with the Port and Ecology. 
A remedial action was completed at the TFLP under AO DE8938. This remedial action
included removal of contaminated soils, installation of a slurry wall, installation of a protective
asphalt cover, and implementation of an operations and maintenance plan and a
compliance monitoring plan. Groundwater sampling and product recovery (if required
based on field criteria) produce less than 100 gallons of contaminated groundwater per
year.
The TFLP historical operations are discussed in Section B.1.2. Historical releases at the
TFLP and other portions of the facility are discussed in Part E of this application. 

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B.1.1   Facility Owner/Operator 
The Port is the current owner and operator of the Terminal 91 facility. 
B.1.2   Terminal 91 History 
A tank farm was built on the TFLP in or about 1926. The TFLP was operated by various
oil companies until December 1941 when the United States Navy took possession of the
entire Terminal 91 Facility through condemnation. In about 1972, the Navy declared the
facility as surplus. The Port began managing the Terminal 91 and, in 1976, the Port acquired
the facility. Terminal 91 is under the Port's management and ownership at the present
time. 
Ecology employs Model Toxics Control Act (MTCA) (Washington Administrative Code
[WAC] 173-340) authority to implement RCRA corrective action requirements at Terminal
91. Ecology and the Port have conducted investigations and cleanups under a series of
AOs since Ecology assumed RCRA corrective action oversight for Terminal 91 from the
US Environmental Protection Agency (EPA) in 1998. These AOs and their associated
actions are summarized below. 
1998 AO (DE98HW-N108) Tank Farm Affected Area (TFAA) and Voluntary Cleanup
Program Work (Discrete Units). The first AO for Terminal 91 was signed in 1998 (Ecology
1998). It required the Port and other parties to conduct a remedial investigation (RI)
and feasibility study (FS) for the former Burlington dangerous waste treatment and storage
facility, commonly referred to as the Tank Farm Lease Parcel (TFLP). The investigation
area extended beyond the 4-acre TFLP boundaries to include any area determined
to have been affected by releases from the Tank Farm. This area is identified as
the TFAA.  Investigations conducted since 1998 have determined the extent of the
TFAA. Generally, the TFAA extends southward from the Tank Farm onto Piers 90 and
91, but it does not include the adjacent Port-owned marine sediment (submerged lands
area) (Figures B2 and B4). 
Separately from the 1998 AO, the Port undertook investigations and cleanups at other
known or suspected release areas on Terminal 91 that were not within the TFAA. There
were approximately 38 of these separate units, referred to as Discrete Units. Most of
the Discrete Units had been identified by EPA as a result of a RCRA Facility Assessment
(RFA) in 1994. The purpose of the RFA was to identify all areas at Terminal 91
affected by hazardous substances releases. Based on Port records regarding management
of Terminal 91, the Port identified additional Discrete Units in 1997. None of the
Discrete Units were located within the submerged lands area. All were located within
the upland area, so the Port's corrective actions to address the Discrete Units involved
only the upland area. Ecology and the Port addressed the Discrete Units under Ecology
's Voluntary Cleanup Program. The Port removed all of the tanks and a number of 
buildings at the TFLP as part of a MTCA interim remedial action reported in October
2005. 
2010 Agreed Order (DE7321). Ecology and the Port entered a replacement AO in 2010.
The 2010 AO required the Port to complete the required work under the 1998 AO, including
the developing a draft cleanup action plan (CAP) for the TFAA. It also extended
the facility to include the rest of the contiguously owned Port property (i.e., all 216 acres
of Terminal 91) in order to align with the RCRA requirement calling for corrective

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action with respect to the entire "facility," defined as including the former Tank Farm
dangerous waste facility and all contiguously owned property. The 2010 AO also listed
all previously identified Discrete Units for Terminal 91 and set requirements for the
Port to address them. Although the 2010 AO included the submerged lands area, no
Discrete Units were located there; accordingly, the 2010 AO deferred the need to consider
investigation or remediation of the submerged lands area. Meanwhile, investigations
of subsurface contamination from the Tank Farm and Discrete Units revealed no
evidence that such contamination had migrated to or otherwise affected the submerged
lands area. 
2012 Agreed Order (DE8938). In 2012, the Port and Ecology signed a new AO, which
required the Port to perform the cleanup action per the CAP for the TFAA and an adjacent
Discrete Unit (Solid Waste Management Unit [SWMU 30]), and to continue work
on the remaining Discrete Units. By 2015, the Port had completed active work (i.e.,
construction of the remedial features) at the TFAA and SWMU 30. By 2018, Ecology
had approved all Discrete Units as having been adequately addressed (Attachment 2).
Monitoring and operations and maintenance for the TFLP and TFAA are ongoing as
required by the AO and associated compliance monitoring plan and operations and
maintenance plan. 
2013 Agreed Order Amendment (DE8938). The West Yard area was removed from the
permit following the sale of that portion of the Terminal 91 facility. This removal reduced
the facility size from 216 acres to 210 acres. 
2016 Agreed Order Amendment. In January 2016, Ecology and the Port entered an
Amendment to the 2012 AO (First Amendment), which required the Port to conduct
two new, separate actions: 
Action 1 Regrade Project  Regrade the accumulated shoal material along the
southeast portion of Pier 91 in the submerged lands area. This task, known as the
Regrade Project, was completed in April 2016. 
Action 2 Submerged Lands Preliminary Investigation  Conduct a preliminary in-
vestigation in the Submerged Lands Area. This investigation was completed, and
the final report approved by Ecology in September 2018. The preliminary investigation
indicated that an RI was warranted for the Submerged Lands portion of
Terminal 91. 
Proposed 2019 Agreed Order (DE24768). Following the submerged lands preliminary
investigation, the Port and Ecology prepared an AO for completion of an RI of the Submerged
Lands portion of Terminal 91. AO DE24768 is being reviewed concurrent with
this application. 
Work performed by Burlington and the Port under oversight by EPA and then by Ecology
is summarized in the following table of key reports. 
Key Reports Prepared Under Agency Oversight                         Year   Agency
RCRA Facility Investigation (RFI)                                           1995     EPA 
Draft Remedial Investigation/Data Evaluation Report                          1999    Ecology 
Final Bridge Document Report 1                                            2001    Ecology 
Draft Bridge Document Report 2                                            2003    Ecology 

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Final Remedial Investigation Summary Report Terminal 91 Tank Farm Site    2007    Ecology 
Final Draft Feasibility Study Report, Terminal 91 Site                          2009    Ecology 
Final Cleanup Action Plan                                                   2010    Ecology 
Operation and Maintenance Plan, Terminal 91 Tank Farm Cleanup            2013    Ecology 
Compliance Monitoring Plan, Terminal 91 Tank Farm Cleanup               2013    Ecology 
Engineering Design Report, Terminal 91 Tank Farm Cleanup                 2013    Ecology 
T-91 Historical Review Report                                               2017    Ecology 
Terminal 91: Submerged Lands Area Preliminary Investigation Sampling
and Analysis Plan                                                            2017    Ecology 
Construction Report, Terminal 91 Tank Farm Affected Area Cleanup Action
2017    Ecology 
Terminal 91: Submerged Lands Area Preliminary Investigation Surface
Sediment Characterization Results                                            2018    Ecology 
Terminal 91: Submerged Lands Area Preliminary Investigation Phase 2:
Surface and Subsurface Sediment Characterization Results                     2018    Ecology 
B.1.3   Materials Historically Handled at the Facility 
This section has been omitted from the application as the information requested is no
longer applicable. 
B.1.4   Plant Management 
This section has been omitted from the application as the information requested is no
longer applicable. 
B.1.5   Summary of Waste Types Listed in the Part A 
This section has been omitted from the application as the information requested is no
longer applicable. 
B.1.6   Tank Storage and Treatment Operations 
This section has been omitted from the application as the information requested is no
longer applicable. 
B.1.7   Detailed Process/Activity Descriptions 
Dangerous waste operations are no longer conducted at Terminal 91 and no processes are
described. 
The only other activity description at the facility relative to this application is traffic. In
order to perform corrective actions at the facility, field teams perform quarterly gauging
at a passive free-product recovery system and semi-annual or annual groundwater monitoring.
General driving routes used during these activities are shown in Figure B5. Traffic
is generally discussed in Section B.3. 


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B.2   SEISMIC CONSIDERATION 
Not applicable. Terminal 91 is not a new facility nor is there a proposed expansion of an
existing facility relevant to this application. 
B.3    TRAFFIC INFORMATION 
Traffic access to Terminal 91 is controlled by a security gate at the main entrance on the
eastern side of the facility. The main gate is staffed by security guards. Additional traffic
may enter from the Magnolia Bridge with access limited to the cruise parking area. The
entire north end of the facility is surrounded by a chain link fence. Tenants access the facility
through the main gate. Cruise terminal passenger vehicle access is routed through
controlled lanes to Pier 91. 
The south end of the facility including Piers 90 and 91 is bounded by Elliott Bay. Ship
moorage at Piers 90 and 91 must be arranged in advance and the facility does not function
as a public marina. 
Despite its proximity, the Magnolia Bridge is not a part of the Terminal 91 facility and is
therefore not discussed in this application. 
B.4   TOPOGRAPHIC MAPS 
The following figures referenced in this section describe Terminal 91's topographic features
as of August 2019. Individual figures were provided to reduce the amount of overlapping
information. Each figure in this section highlights certain features as follows: 
Figure B1 shows the location of the Terminal 91 facility, in relation to the greater Seattle
area and topographic features. 
Figure B2 shows the legal boundaries of Terminal 91, the TFLP, the Upland and Sub-
merged Lands portions, and security gates. 
Figure B3 shows the adjacent land use. 
Figure B4 shows the former TFLP operational areas. 
Figure B5 shows the traffic patterns at the facility related to corrective action activities 
(monitoring and LNAPL gauging). 
Figure B6 shows the wind patterns including a wind rose of the facility's vicinity. 
Figure B7 shows the Terminal 91 surface water flow or drainage patterns. 
Figure B8 shows the 100 Year Floodplain in relation to Terminal 91. 





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C. WASTE CHARACTERISTICS 
This section has been omitted from the application as the information requested is no
longer applicable. 


















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D. PROCESS INFORMATION 
This section has been omitted from the application as there is no longer any active dangerous
waste processing at the TFLP and no such activities are planned elsewhere at Terminal
91. 
Dangerous wastes have not been generated during ongoing investigative activities. Light 
non-aqueous-phase liquid (LNAPL) containing polychlorinated biphenyls (PCBs) that is
generated from specific monitoring wells is handled and disposed in accordance with the 
Toxic Substances Control Act (40 CFR 761. 60) and Dangerous Waste Regulations
(WAC 173-303). Wastes are generated during compliance monitoring. Those wastes are 
handled in accordance with the Dangerous Waste Regulations. 















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E. RELEASES FROM SOLID WASTE MANAGEMENT UNITS 
Much of the information typically required for this section has been omitted from the application
because SWMUs have been closed and corrective actions at the SWMUs have
been addressed under the referenced AOs. Releases at the facility and the progression of
corrective actions are discussed in Section B.1. 
The RFA that was prepared by the EPA in 1994 identified SWMUs and areas of concern 
(AOCs) at Terminal 91. Subsequent investigation and corrective actions have addressed
all AOCs and SWMUs. Attachment 2 lists Terminal 91 AOCs and SWMUs along with
the date of completion. 
The facility is currently under Agreed Order (DE8938) to conduct compliance monitoring
and operations and maintenance of the TFLP. The AO includes a contingency plan to be
followed if new releases are discovered. 
E.1   RELEASES 
This section has been omitted from the application. This information is provided in other
sections of this application and the Agreed Orders in Attachment 1. 
All information relating to the locations where solid wastes have been stored or managed
on the TFLP was provided in the Solid Waste Management Report (EPA 1988), which is
the equivalent to an RFA. Locations where dangerous wastes were stored at the TFLP 
are shown in Figure B4. 
E.2   STATUS OF CORRECTIVE ACTIONS 
Upland corrective actions are currently being conducted under AO DE8938 (signed in
2012). TFLP investigations and corrective actions have been ongoing since 1994, beginning
with an RFA completed by EPA. The RFA was part of the RCRA process for implementing
corrective action at the dangerous waste treatment and storage facility located at
the TFLP. The RFA was expanded to include 124 acres of upland property at Terminal
91 owned by the Port, including the TFLP. That upland property, excluding the Tank
Farm, is the upland portion of Terminal 91. The upland portion of Terminal 91 was included
in the RFA because the regulatory definition of facility for the purposes of corrective
action includes contiguous property under control of the owner or operator of the
dangerous waste treatment and storage facility. The RFA identified and labeled a number 
of AOCs and SWMUs in the upland and TFLP portions of Terminal 91 during a 1992 
EPA inspection. These AOCs and SWMUs have been addressed by subsequent corrective
actions (Attachment 2). 
Corrective action at the TFLP was completed under a cleanup action plan and included
removal of contaminated soils, installation of a bentonite slurry wall around the former
tank farm, installation of a protective cover layer, installation of a passive product recovery
system, and implementation of a groundwater compliance monitoring plan and operations
and maintenance plan. 

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AO DE 8938 includes a contingency action section that provides standardized operating
procedures to follow in the event of newly discovered contaminated areas at Terminal 91. 
AO DE24768 includes an RI in the submerged lands area. AO DE24768 is being reviewed
concurrent with this application. 
E.2.1   Summary of Corrective Action Activities Under Agreed Order 
Substantial corrective actions have been completed at the TFLP. All above ground tanks
and piping were removed in 2005 after the aboveground closure was approved. A protective
cover layer, perimeter bentonite slurry wall, and passive product recovery system
were installed with construction completion in 2015. Following construction completion, 
the TFLP and TFAA moved into a compliance monitoring and operations and maintenance
phase, which is being conducted under AO DE8938. AO DE8938 requires quarterly
and annual progress reporting to Ecology. 














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F. PROCEDURES TO PREVENT HAZARDS 
This section is not applicable as there is currently no storage, treatment, or loading/unloading
of dangerous wastes at Terminal 91. However, basic security measures are taken
as described below. 
F.1   SECURITY 
F.1.1    Security Procedures and Equipment 
Dangerous waste operations no longer occur at Terminal 91, except as required by the
AO for corrective action. The Port provides 24-hour controlled access to the facility. All
entrances are manned by guards that also periodically patrol the area. 
F.1.2    Waiver 
Not applicable. No waiver is requested. 
F.2   INSPECTION PLAN 
This section is not applicable. Terminal 91 currently has no active collection, consolidation
, storage, treatment, and/or preparation for shipment of dangerous waste. Corrective
actions prevent contact with contamination. 
F.3   PREPAREDNESS AND PREVENTION REQUIREMENTS 
This section is not applicable. Terminal 91 currently has no active collection, consolidation
, storage, treatment, and/or preparation for shipment of dangerous waste. Corrective
actions prevent contact with contamination. 
F.4   PREVENTIVE PROCEDURES, STRUCTURES, AND EQUIPMENT 
This section is not applicable. Terminal 91 currently has no active collection, consolidation
, storage, treatment, and/or preparation for shipment of dangerous waste. 
Investigation derived wastes generated during sampling or product recovery are stored in
labeled drums on secondary containment pallets. Drums and contents are disposed of
consistent with applicable regulations. 
F.5   PREVENT REACTION OF IGNITABLE, REACTIVE, AND/OR INCOMPATIBLE 
WASTES 
This section is not applicable. Terminal 91 currently has no active collection, consolidation
, storage, treatment, and/or preparation for shipment of dangerous waste. 


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G. CONTINGENCY PLAN 
All dangerous waste facilities have ceased operations at the Terminal 91, except as required
by Ecology under AO for corrective actions, and, therefore, the information requested
in this section of the application is no longer applicable. 


















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H. SECTION H TRAINING PLAN 
All dangerous waste facilities have ceased operations, except as required by Ecology under
AO for corrective actions, and, therefore, the information requested in this section of
the application is no longer applicable. Environmental field staff working on corrective
actions are required to have 40-hour Hazardous Waste Operations and Emergency Response
(HAZWOPER) training. 

















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I.   SECTION I CLOSURE PLAN AND CLOSURE COST ESTIMATES 
This section of the permit application describes actions to be taken to achieve clean closure
after operations cease at the facility. The former dangerous waste management facility
operated at the TFLP has been closed. Therefore, Section I is not applicable with the
exception of Sections I.1 and I.3. 
I.1     CLOSURE 
Burlington Environmental submitted the final documentation certifying above-ground 
closure of the Final Status (Part B) portions of the TFLP to Ecology on March 3, 1997. 
The required closure activities were completed from February 4 through 13, 1997 in accordance
with the August 1996 Closure Plan and Closure Cost Estimates as approved by
Ecology on October 29, 1996, following public comment regarding the Plan submitted as
Part B Permit Modification Request PRMOD8-2. The Dangerous Waste ID associated
with the TFLP (WAD000812917) was withdrawn effective December 31, 2003. 
I.2     CLOSURE COST ESTIMATE 
The former dangerous waste management facility operated at the TFLP has been closed.
Therefore, with the exception of Section I.1, Section I is not applicable. Financial assurance
for additional corrective actions completed under MTCA are addressed through the
financial assurance of the associated AOs (see Attachment 1 and Section J.2.6). 
I.3     NOTICE IN DEED OF ALREADY CLOSED DISPOSAL UNITS 
This section is not applicable; the facility did not operate disposal units. 
I.4     POST-CLOSURE PLAN 
All tanks and process systems at the TFLP have been closed. Post closure plans are required
for any area that cannot be cleaned up to meet closure standards. Soil and groundwater
at the TFLP currently exceed cleanup levels in some areas of the TFAA. Post closure
is addressed through AO DE8938 (Attachment 1), which provides for long term
compliance monitoring and contingency action, if necessary. 
I.5     LIABILITY REQUIREMENTS 
Liability insurance is not required for this application because operations at the facility
have been discontinued. 



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J. OTHER FEDERAL AND STATE LAWS 
J.1   FEDERAL REQUIREMENTS 
Regulations require that EPA follow the procedures under certain federal laws before
granting or denying a RCRA permit. The discussion that follows provides a description
of how these laws currently apply to existing corrective action conducted at Terminal 91. 
J.1.1    Wild and Scenic Rivers Act 
Not applicable. The facility does not affect any rivers designated under the Wild and Scenic
Rivers Act. 
J.1.2    National Historic Preservation Act of 1966 
Not applicable. The facility is not listed or eligible for listing on the national or local
Registers of Historic Places. 
J.1.3    Endangered Species Act 
Threatened or endangered species known to exist on- or in areas adjacent to the facility 
include bald eagles, killer whales (orcas), Chinook salmon, and bull trout. Ongoing corrective
action activities are not expected to affect critical habitat areas where endangered 
species might be present. As discussed in Section J.2.4, future corrective actions, which
have not been defined at this time, may trigger review of impacts associated with those
future actions. 
J.1.4    Coastal Zone Management Act 
The State of Washington Shoreline Management Act (SMA) of 1971, under the jurisdiction
of Ecology, is the approved implementation vehicle for the Coastal Zone Management
Act. The SMA is implemented at the local level by individual shoreline master programs
, which are prepared by local agencies and approved by Ecology. 
Terminal 91 is located in or near a designated shoreline area as defined in the City of Seattle
Shoreline Master Program. Smith Cove and Smith Cove Waterway (east slip, center
slip, and west slip) are located immediately west of Terminal 91 (Figure B1). These surface
waters are used for industrial and maritime activities and provide access to Elliott
Bay and Puget Sound. 
J.1.5    Fish and Wildlife Coordination Act 
Not applicable. There are no current plans to impound, divert, control, or modify any
body of water in the vicinity of the facility as part of planned corrective action pursuant
to the AO or applicable requirements. 



TERMINAL 91 RCRA PERMIT RENEWAL APPLICATION      19 
AUGUST 2019

J.1.6    RCRA Corrective Action Program 
The Corrective Action Program requires corrective action for all releases of hazardous 
waste or constituents from hazardous waste treatment, storage, or disposal facilities,
where necessary to protect human health and the environment. 
A summary of the corrective actions conducted to date by the Port and facility operators 
is presented in Section E of this application. 
J.2   STATE REQUIREMENTS 
Ecology regulations require that a facility that stores or handles dangerous waste comply
with all applicable federal, state, and local environmental protection laws and regulations.
Following closure of the TFLP dangerous waste facility in 1997, no regulated wastes 
have been managed at Terminal 91 outside of corrective action activities. As such, the
majority of state and local regulations described below no longer apply. A discussion of
each regulation is included below. 
J.2.1    National Emission Standard for Asbestos 
Ecology regulations [WAC 173-303-395(3)] require that all waste material containing
asbestos be disposed at a facility operated in accordance with 40 CFR Part 61 Subpart M,
National Emission Standard for Asbestos. Except to comply with requirements of the
Agreed Order, Burlington no longer conducts operations at the TFLP. Therefore, this requirement
is not applicable. 
J.2.2    State Water Pollution Control Standards 
The Revised Code of Washington (RCW) Chapter 90.48 designates Ecology as the State
Water Pollution Control Agency for the purposes of the Federal Clean Water Act to establish
and administer state programs for water pollution control. No industrial or sanitary
wastewater is discharged from Terminal 91 under the Permit; therefore, this regulation
is not applicable. 
Stormwater and run-off from paved and unpaved areas at Terminal 91 are managed by a
stormwater management system operated by the Port under a municipal NPDES permit. 
J.2.3    Minimum Functional Standards for Solid Waste Handling 
Regulations contained in WAC 173-304 and 173-350 establish minimum functional performance
standards for solid waste handling and operation of solid waste handling facilities.
The facility was formerly operated as a dangerous waste management facility, and
investigations associated with its former use continue to be addressed through ongoing
compliance monitoring. Any non-dangerous wastes managed as part of corrective action
will be handled in compliance with these regulations. 



TERMINAL 91 RCRA PERMIT RENEWAL APPLICATION      20 
AUGUST 2019

J.2.4    State Environmental Policy Act 
This application does not propose any new dangerous waste activities at the facility and
dangerous waste operations have not occurred at the facility since 1997 beyond management
of investigation and remediation derived waste. The application is being submitted
to allow for continuation of ongoing corrective action activities that are required by AO 
under MTCA. Those activities will not require a State Environmental Policy Act (SEPA) 
checklist for this permit application. WAC 197-11-250 describes the integration of
MTCA and SEPA processes. WAC 197-11-800 (17) categorically exempts basic information
collection from the requirements for threshold determination. At present, the AO 
that will be reviewed concurrent with this RCRA permit renewal application includes
only RI activities for the submerged lands area. If necessary, remedial actions will be developed
in a subsequent feasibility and cleanup action plan later in the process. Consistent
with WAC 197-11-265, SEPA review would be initiated for future corrective/remedial
actions as appropriate. 
J.2.5    Puget Sound Clean Air Act 
Not applicable. The Washington Clean Air Act and the Federal Clean Air Act are implemented
by the Puget Sound Clean Air Agency (PSCAA). Currently, no activities proposed
under the corrective action procedures of the Part B Permit are subject to PSCAA
regulations. 
J.2.6    Model Toxics Control Act 
Relevant portions of MTCA will be applied to cleanup activities at the TFLP and any
other RIs conducted under AO (Attachment 2). 
J.3    LIST OF PERMITS 
With the exception of the necessary RCRA Permit for ongoing corrective action activities
, no other permits, including those subject to state and/or local regulatory authority,
are held pursuant to the dangerous waste activities formerly conducted at the TFLP. Additional
permits and registrations will be obtained as needed for activities such as construction
or remediation. 






TERMINAL 91 RCRA PERMIT RENEWAL APPLICATION      21 
AUGUST 2019

K. CERTIFICATION 
In accordance with 40 CFR 270.11 (d) and Washington State Dangerous Waste Regulations
, Chapter 173-303 WAC, paragraph 173-303-810 (13), the following certification is
made in reference to August 2019 Part B Application for Terminal 91 Facility located in
Seattle, Washington. 
"I certify under penalty of law that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry
of the person or persons who manage the system, or those persons directly responsible
for gathering the information, the information submitted is, to the best of my
knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and imprisonment
for knowing violations." 


_____________________________    ______________ 
Signature                               Date 
Stephen Metruck 
Chief Executive Officer 
Port of Seattle 










TERMINAL 91 RCRA PERMIT RENEWAL APPLICATION      22 
AUGUST 2019

ATTACHMENT 1 
AGREED ORDERS DE8938 AND DE24768 













PORT OF SEATTLE TERMINAL 91                       A-1

ATTACHMENT 2 
COMPLETED AOCS AND SWMUS REQUIRING CORRECTIVE ACTION 












PORT OF SEATTLE TERMINAL 91                       A-2

TERMINAL 91 
COMPLETED AOCS AND SWMUS REQUIRING CORRECTIVE ACTION AND COMPLETION
DATES 
Discrete    SWMU, AOC, or Other              Description                          Status 
Unit                Area 
A.1.       AOC 2                        USTs and UST Releases on Termi-   Complete with recording of renal
91 PremisesTanks A-G        strictive environmental covenant
8/30/17. 
B.1.        SWMU 32                    Oil Blending Station                  Complete; Ecology letter 4/20/05 
B.2.        SWMU 33                    Solid Waste Yard                     Complete; Ecology letter 4/20/05 
B.3.        SWMU 35                    Storage Area Outside Building W-    Complete; Ecology letter 4/20/05 
47 
B.4.        SWMU 36                    Storage Inside Building W-47         Complete; Ecology letter 4/20/05 
B.5.        SWMU 37                    Car Wash Station                     Complete; Ecology letter 4/20/05 
B.6.        SWMU 38                    Paint and Motor Oil Waste Build-     Complete; Ecology letter 4/20/05 
ing C-154 
B.7.        SWMU 39                    Paint Filter Waste Storage Area       Complete; Ecology letter 4/20/05 
B.8.        SWMU 40                    Short Fill                             Complete after restrictive covenant
; Ecology letter 4/20/05 
B.9.        SWMU 43                    Berth Stations and Valve Vaults       Complete; Ecology letter 4/20/05 
B.10.      SWMU 44                    Waste Oil Storage Shed               Complete; Ecology letter 4/20/05 
B.11.      SWMU 45                    Storm Drain at North End of Ter-     Complete; Ecology letter 4/20/05 
minal 91 
B.12.      SWMU 46                    Two Storm Drains at Center of       Complete; Ecology letter 4/20/05 
Terminal 91 
B.13.      SWMU 47                    Abandoned Oil/Water Separator      Complete; Ecology letter 4/20/05 
B.14.      SWMU 48                    Transfer Piping                       Complete; Ecology letter 4/20/05 
B.15.      AOC 2                       USTs and UST Releases on Termi-   Complete; Ecology letter 4/20/05 
nal 91 PremisesTanks H and I 
B.16.      AOC 2                       USTs and UST Releases on Termi-   Complete; Ecology letter 4/20/05 
nal 91 PremisesTank J 
B.17.      AOC 2                       USTs and UST Releases on Termi-   Complete; Ecology letter 4/20/05 
nal 91 PremisesTank K 
B.18.      AOC 2                       USTs and UST Releases on Termi-   Complete; Ecology letter
nal 91 PremisesTank T             11/16/11 
B.19.      AOC 2                       USTs and UST Releases on Termi-   Complete; Ecology letter 4/20/05 
nal 91 PremisesTank Z 
B.20.      AOC 4                       Leaking Motor                       Complete; Ecology letter 4/20/05 
B.21.      AOC 5                       PCB Transformer Pad                Complete; Ecology letter 4/20/05 
B.22.      AOC 7--Pier 90 Area          Concrete Aprons                     Complete; Ecology letter
11/16/11 
AOC 7--Pier 91 Area         Concrete Aprons (see also 1991      Complete; Ecology email
Soil Investigation for Pier 91 Chill    10/9/12 
Facility) 
B.23.      AOC 16                      Inactive Transformers                Complete; Ecology letter 4/20/05 
B.24.      Other Area (from Baseline    1990 PNO Pipeline Break South of   Complete after restrictive cove-
Report)                       Building T-38, Pier 91                nant; Ecology letter 4/20/05 

PORT OF SEATTLE TERMINAL 91                       A-3

B.25.      Other Area (from Baseline    1991 PNO Pipeline Break at South   Complete; Ecology letter 4/20/05 
Report)                       End of Pier 91 
B.26.      Other Area (from Baseline    1994 Transformer Pad                Complete; Ecology letter 4/20/05 
Report) 
B.27.      Other Area (from Baseline    1994 DAS Building Site Investiga-   Complete; Ecology letter 4/20/05 
Report)                       tion 
B.28.      Other Area (from Baseline    1991 Soil Investigation for Pier 91    Complete; Ecology letter
Report)--Pier 90 Area         Chill Facility--Pier 90 Area (see      11/16/11 
also AOC 7) 
B.29.      Other Area (from Baseline    1996 PNO Pipeline Alignment Soil   Complete; Ecology letter
Report)                       Remediation, Pier 90                 11/16/11 
B.30.      Other Area (from Baseline    1996 PNO Pipeline Break, Pier 91    Complete; Ecology email
Report)                                                            10/9/12 
B.31.      Other Area (from Baseline    1994 DAS Utility Trench Investi-     Complete; Ecology letter
Report)                       gation                                11/16/11 
B.32.      Other Area (Independent      1999 PNO Pipeline Release on Pier   Complete; Ecology email
Cleanup)                    90                                  3/16/12 
B.33.      Other Area (Independent      Pier 91 Pipeline Decommissioning    Complete; Ecology email
Cleanup)                    and Historic Pipeline Releases in     10/9/12 
the Vicinity of the Carnitech Building
B.34.      Other Area (Independent      Pier 91 Pipeline Decommissioning    Complete; Ecology email
Cleanup)                    and Historic Pipeline Releases in     10/9/12 
the Vicinity of the Cruise Ship Terminal
B.35.      Other Area (Independent      Pier 91 Historic Pipeline Releases     Areas B & C--Complete; Ecol-
Cleanup)                                                        ogy emails 2/3/12 and 3/16/12 
Area D--Complete; Ecology
email 7/17/13 
B.36.      Other Area (Brownfields      Building 136                         Complete; Ecology memo
Investigation)                                                        emailed 12/23/13 
Building 136 Hydraulic Lifts          Complete; Ecology letter
10/31/18 
B.37.      Other Area (Brownfields      Locomotive Fueling Area             Complete; Ecology email 8/4/16 
Investigation) 
B.38.      Other Area (Brownfields      Incinerator UST Area                 Complete; Ecology email 8/4/16 
Investigation) 
B.39.      Tank Farm Affected Area     Stormwater Sump Bottom Filling     Complete; Ecology letter 12/7/11 
Interim Action                Interim Remedial Action 
Notes: 
AOC is Area of Concern 
SWMU is Solid Waste Management Unit 





PORT OF SEATTLE TERMINAL 91                       A-4

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