6c Memo
PORT OF SEATTLE MEMORANDUM COMMISSION AGENDA Item No. 6c Date of Meeting December 7, 2010 DATE: December 1, 2010 TO: Tay Yoshitani, Chief Executive Officer FROM: Stephanie Jones Stebbins, Director, Seaport Environmental & Planning Elizabeth Leavitt, Director, Aviation Planning and Environmental Services SUBJECT: 2011-2015 Environmental Remediation Liability Program. Amount of This Request: $31,200,000 Source of Funds: Airport Airport Development Fund; Real Estate and Seaport Operating Funds and Tax Levy Est. State and Local Taxes: N/A Est. Jobs Generated: ACTIONS REQUESTED: Requst Commission authorization for: 1) spending $15,000,000 in 2011 for Environmental Remediation Liability. 2) obligating $16,200,000 in 2011 for work that will be performed in later years, and 3) Commission approval of the five-year spending plan of $67,960,000 for the Environmental Remediation Liability Program for Seaport, Real Estate and Airport for 2011 through 2015. SYNOPSIS: As a major industrial and commercial land owner, the Port has significant environmental cleanup liabilities due to historic contamination of its properties. Since 1993, the Port has booked liabilities to recognize these obligations. While Port environmental cleanup projects typically span several years, more complex projects have been active for over 10 years. This $15,000,000 authorization for 2011 will allow us to continue ongoing environmental testing, analysis, design, cleanup, and monitoring for our active sites and will initiate similar activities for new sites, as noted in this memorandum. The approval of the five year plan gives greater visibility to our projected upcoming environmental remediation liability spending. In addition, the authorization to enter multi-year contracts and service directives will allow us to more efficiently contract for work of multiyear duration. The actual funds in years beyond 2011 will not be spent until the spending is authorized by a future Commission action (i.e., next year's Environmental Remediation Liability spending authorization). COMMISSION AGENDA Tay Yoshitani, Chief Executive Officer December 1, 2010 Page 2 of 10 BACKGROUND: The Port has identified a number of contaminated sites on Seaport, Real Estate and Aviation properties that must be investigated and remediated in compliance with federal and state environmental laws and regulations. In some cases, the Port has been designated by the federal government as a "Potentially Responsible Party" (PRP), and/or by the state government as a "Potentially Liable Party" (PLP) for the investigation and cleanup of properties owned by the Port or where the Port may have contributed to site contamination. Although the Port may not bear ultimate liability for the contamination, under federal and state law, the Port is presumptively liable as the property owner, and it is often practically and financially beneficial for the Port to take initial responsibility to manage and pay for the cleanup. In many cases, the Port has successfully recovered and/or will seek recovery from other responsible parties for Port-incurred investigation and cleanup costs. The Port also has been successful in receiving Model Toxics Control Act (MTCA) grant funds to pay part of the cleanup costs. The Port's goals are to cost-effectively complete this environmentally responsible work and to maximize work accomplished by or paid for by the parties responsible for the conditions encountered (or others, such as insurance companies, who represent them). To mitigate such environmental expenditures, the Port also encourages, coordinates with, and oversees the investigation and cleanup of sites by other responsible parties, to assure that legal requirements are met and that Port liabilities are minimized. Regardless of whether the Port conducts the investigation and remediation directly, or oversees the proper performance of that work by other responsible parties, the Port provides a valuable public benefit by acting as a catalyst in expediting appropriate environmental management of these sites. Accounting rules require that the Port establish liabilities for environmental remediation when the Port's obligation meets specified definitions of certainty and the liability amount can be reasonably estimated. When an environmental remediation liability is booked means an expense is recorded in the current period for the future expenditures. The Port develops its environmental remediationliaibility forecasts in compliance with Government Accounting Standards Board (GASB) issued Statement No. 49 "Accounting and Financial Reporting for Pollution Remediation Obligations". Environmental liability expenditures are authorized in one of two ways. If the environmental costs are incurred in the course of or incidental to a construction project, then the Commission authorization occurs as part of the authorization for the overall construction project. Examples of this include asbestos removal, offsite soil disposal during construction, or upland dredge material disposal. If the environmental cost is not associated with a capital construction project or maintenance (including asbestos), but is a stand-alone pollution remediation project, then the expenditure is authorized through one annual action. Since 1993, the Commission has approved annual environmental expenditures. Consistent with past practices, the duration of the authorization continues to be an annual spending authorization. However, starting this year, it will also include a rolling five-year spending plan to reflect the level of resources expected to be required over the next five years. Executing contract obligations for a longer duration will minimize the need to rework all contract amendme nts and service COMMISSION AGENDA Tay Yoshitani, Chief Executive Officer December 1, 2010 Page 3 of 10 directives that are aligned with the endof-year authorization. It will also provide greater visibility of the environmental liability costs. BUSINESS PLAN OBJECTIVES: Environmental remediation projects define and minimize to acceptable levels threats to the environment caused by prior Port operations, prior tenant operations, and by the historical effects of industrial activity on properties acquired by the Port. Generally, the product of these efforts, as well as the attendant compliance with regulatory mandates, management of Port liabilities, and support of the local community, aligns with the goals and objectives of the Seaport, Aviation, and Real Estate Division Business Plans SCOPE OF WORK: The environmental investigation and remediation actions described in this Scope of Work section are required under federal and/or state law. Remedial actions continue to focus on cost-effective study, analysis, and implementation of cleanup actions; coordination with capital planning, design, and construction; and negotiation with agencies, tenants, other PRPs and insurance companies. Seaport Sites/Projects Lower Duwamish Waterway Superfund The Lower Duwamish Waterway is a Federal Superfund Site. The Lower Duwamish Work Group (LDWG), consisting of the Port, the City of Seattle, King County and Boeing, are conducting a Remedial Investigation and Feasibility Study (RI/FS) of the Waterway under an Administrative Order on Consent (AOC) with the Environmental Protection Agency (EPA) and the Department of Ecology (DOE). The Port is the contracting agent for the LDWG. A revised draft Feasibility Study (FS) was submitted to the agencies in October 2010. Public and agency comment will occur through December 23, 2010. EPA and DOE will use public input to finalize the FS and develop a Proposed Plan for remediation of the site. The Proposed Plan is scheduled to be issued for public review and comment early in 2012. Public comment on the Proposed Plan will be used by EPA to develop its Record of Decision for the final cleanup plan. EPA will issue the Record of Decision in 2013, after seeking concurrence from Ecology. Terminal 117 Sediments, Bank and Uplands As part of the Lower Duwamish Waterway Superfund effort, the LDWG identified several sediment hot spots that warranted early cleanup action, including this site, which is owned in part by the Port. In 2005, the Commission authorized the signing of an Administrative Settlement Agreement and Order on Consent (ASAOC) with EPA for the final design and construction of the sediment and bank cleanup. However, the extensive contamination discovered during the 2006 upland investigation necessitated a re-evaluation of the T117 Sediments and Bank Project, with the outcome being to combine the Terminal 117 Uplands Project with the T117 Sediments and Bank Project. The Port, along with the City of Seattle, signed a new Statement of Work (SOW) for the 2005 ASAOC, providing for the revision of the Engineering Evaluation and Cost Analysis (EE/CA). The final EE/CA was issued on June 3, followed by the Public Meeting on June 17, 2010. Based on these findings, the EPA issued an Action Memorandum which identified the EPA- selected cleanup action. The Port and City will begin negotiation of an amendment to the 2005 order, or a new order to perform the selected cleanup action. Cleanup design and contractor selection will occur through 2012. COMMISSION AGENDA Tay Yoshitani, Chief Executive Officer December 1, 2010 Page 4 of 10 Terminal 108 As mentioned above, LDWG is conducting the Lower Duwamish Remedial Investigation/Feasibility Study. As part of this work, the LDWG identified hot spots that may require early cleanup action, one of which is located in the sediments adjacent to Terminal 108. The DOE requested, and the Port voluntarily agreed, to perform additional investigation of the groundwater. The groundwater study determined that the groundwater is not a source of contaminants to the river. However, Ecology is requiring additional bank, shoreline, and upland assessment of potential river recontamination sources. Some engineered mitigation measures may be necessary to control potential recontamination sources. On October 13, 2009, Commission approved moving forward with this source control work as an independent action. Terminal 115 Contamination The Port is conducting a continuing program to remove small amounts of free product (petroleum) from groundwater caused by two leaking underground tanks that were removed from the southwest portion of the terminal. Investigative groundwater monitoring is also continuing. Soils are marginally contaminated at the tank sites but cleanup at this time is not required by regulatory agencies. Activities at this site also include coordination with DOE on source control efforts required as part of the LDW RI/FS process. The Port is currently developing an Environmental Conditions report for the entire property. This document will then be used to identify potential source control issues and associated actions needed to reduce recontamination potential to the larger sediment cleanup. T-5 DOE State Cleanup Sites In the past, as part of the T-5 site redevelopment, the Port completed remediation at four sites under three Consent Decrees with the DOE. Current obligations include an investigation and long term ground water monitoring program, on-going cap inspection and maintenance of the cap in the four areas. T-5 Pacific Sound Resources (PSR) EPA Superfund Site This site was cleaned up under an Agreement on Consent with EPA as part of the T5 Southwest Harbor redevelopment project, Ongoing obligations include continuing to perform required cap inspection and cap maintenance, product recovery activities and monitor EPA activities related to the groundwater and the off shore sediments. EPA recently performed a five year review for this site which identified the need to perform a vapor intrusion study and to reassess the cleanup levels. Harbor Island Superfund Site Soil and Groundwater Operable Unit Cleanup of this site was performed under a Consent Decree with EPA. Long term groundwater monitoring is being per formed by the group consultant under a PRP agreement. Long term cap maintenance and inspections have been initiated as required under the Record of Decision. EPA recently completed a 5 year review of this site which identified the need for additional groundwater monitoring, improved cap inspection reporting and follow up on institutional controls recording by the PRPs. Harbor Island Superfund Site East Waterway Sediments Operable Unit Sediment cleanup via dredging in the East Waterway navigational channel began in early January 2004, and was completed in March 2005. Some of the areas within the cleanup boundary required additional post-dredging capping due to deeper-level contamination. Post remediation sampling continues. In 2006, the Port signed an ASAOC with EPA for a final Supplemental Remedial Investigation and Feasibility Study (SRI/FS), and a Memorandum of Agreement with the City and the County to share costs and cooperate in the SRI/FS process. The Port is acting as the contracting agent for this work. A settlement agreement with Seattle Iron Metals was negotiated for their contribution to the SRI/FS costs. We are currently conducting the SRI/FS tasks identified in the ASAOC and subsequent work plans. COMMISSION AGENDA Tay Yoshitani, Chief Executive Officer December 1, 2010 Page 5 of 10 Terminal 18 Jet Fuel Pipeline This pipeline, which was owned by the Port and operated by Kinder Morgan, failed the tightness test in November 2003. A release of jet fuel to the soil has been documented. The area of the leak was identified and repaired and an investigation was performed to identify those areas that may require cleanup. Additional investigation is required to identify the need for additional cleanup. Terminal 30 Oil Cleanup This is the former Chevron site. The Port has removed significant amounts of free product and conducted an intensive groundwater-monitoring program. This project is currently being re-evaluated with DOE to determine steps needed to reach agreement on a closure plan and close out the existing Agreed Order. The Port is in the process of negotiating final site remedy and compliance monitoring for the site. Terminal 10 Lockheed Lockheed has performed the upland and sediment cleanup required at the site. The Port's continuing obligation is to maintain the upland cap and the habitat restoratio n area, manage any contaminated soil and groundwater encountered or removed during redevelopment or maintenance activities, and to protect Lockheed's groundwater monitoring wells. Under the Terminal 10 Uplands capital project, improvements are proposed to the site's storm water drainage and upland cap . T106 Warehouse Building The former warehouse building contains five underground storage tanks (USTs) and some cement kiln dusts (CKD) fill material. During future site development or improvements, UST decommissioning and limited soil remediation will be required. If site development encounters or disturbs underlying CKD fill, generated material will be profiled, handled, and disposed of offsite. Natural Resource Damages (NRD) Habitat Planning After the Record of Decision is complete, Superfund liability for LDW will also include injury to natural resources from contamination. The Port is negotiating with the NRD Trustees for a settlement of these liabilities that will likely include habitat restoration as a component. Settlement could take the form of either a final settlement or a credits agreement. The purpose of the credit agreement (if needed), is to allow creation of habitat now and to receive credit for the habitat when a settlement agreement is finalized. On May 13, 2008, the Commission approved signing a Credits Agreement MOA and execution of a professional service agreement for environmental review, permiting and preparation of plans and specifications for habitat design at T-117 under the MOA, for $210,000. A contract with a design consultant has been executed and predesign work has began but a final signed MOA has not yet been executed. At this point, the NRD Trustees have expressed a preference for a final settlement rather than a credits agreement. New Seaport Sites Terminal 115 North In late January 2009, the Port received from DOE a Notice of Potential MTCA Liability and a Notice of Intent to Conduct a Site Hazard Assessment. DOE identified this site as a result of their source control activities related to one of the high priority sediment sites (Glacier Bay) within the Lower Duwamish Superfund site. Glacier Bay is located north of Terminal 115. The Port conducted an initial assessment of the environmental contamination at the site. The Port recently negotiated an Agreed Order with Ecology, under which the Port will further characterize the site and develop a draft cleanup action plan. Authorization to enter into this Order was received at the November 2, 2010, Commission meeting. COMMISSION AGENDA Tay Yoshitani, Chief Executive Officer December 1, 2010 Page 6 of 10 Terminal 104 The Port will be conducting an initial assessment of the environmental contamination and potential future course of action for this site. The site has been identified by Ecology has having data gaps in relation to source control related to the Lower Duwamish Waterway Superfund site. Real Estate Sites Terminal 91 Cleanup Investigation and cleanup of this site is being administered by the DOE under a State Dangerous Waste Permit and an Agreed Order. The draft Feasibility Study (FS) went out for public comment last December and was finalized with no changes. A draft Cleanup Action Plan (CAP), which identifies the cleanup approach selected by DOE, and SEPA checklist are out for public comment. After public comment, a new Order or an amendment to the existing order will be negotiated for performance of the cleanup. Fishermen's Terminal The Porthas removed contaminated soils in the uplands, capped the uplands as a voluntary cleanup measure, and is conducting a continuing program of investigative groundwater monitoring at and near the Fishing Vessel Owners (FVO) tenant site. Some dredging of contaminated sediments occurred as part of the Docks 5-10 renewal and replacement and berth dredging project. T-5 DOE State Cleanup Sites (CEM) Site In addition to the 4 sites listed under Seaport sites, as part of the T-5 redevelopment, the Port purchased the old West Seattle Landfill and installed an environmental cap and a methane collection system. These systems require long term operation and maintenance, inspection and reporting which is continuing. Aviation Sites/Projects Aircraft Fuel Farms and Fueling Systems Five underground aircraft fueling systems were constructed and operated by individual airlines beginning in the early 1960s. As of January 2007, each of these systems has been decommissioned. Appropriate environmental cleanup has been achieved for three of the systems and is in progress for two others. Long-term monitoring continues as noted below: Investigation and remediation of an area impacted by operations of the former United Airlines and Continental Airlines fuel farms are anticipated to continue for an additional two to three years. The Port is a member of the PLP group for this multiple-source site. The Northwest Airlines and Pan Am Airlines systems have been appropriately remediated, but continue to require monitoring. In 2011-2015 the Port (as a result of Pan Am Airlines bankruptcy) and Delta Airlines (successor by merger to Northwest Airlines) will monitor the former Pan Am and Northwest systems in the context of the STIA Ground Water Study, described below STIA Ground Water Study In May 1999, the Port and the DOE executed a MTCA Agreed Order that required the Port to conduct a study of ground water conditions in the uppermost regional aquifer in the vicinity of the airport. The study has been completed. The results demonstrate that there is little potential for airport operations to impact ground water conditions beyond the airport boundary, and threaten local ground water receptors (public drinking water supplies, creeks, etc.). DOE has accepted the study findings and designated the Port's obligations under the Agreed Order as complete. DOE and the Port have agreed to a plan for long-term ground water monitoring to confirm the results of the models used in the study. Under the terms of a responsible party agreement, Delta Airlines will implement the monitoring program on behalf of the Port and several Rent-A-Car tenants. We anticipate completion of long term monitoring in 2016. COMMISSION AGENDA Tay Yoshitani, Chief Executive Officer December 1, 2010 Page 7 of 10 Lora Lake Apartments Under the terms of the agreement settling the King County Housing Authority condemnation of the Lora Lake Apartment complex, the Port retained responsibility for future contamination remediation of the property. On July 10, 2009, the Port and the DOE executed a MTCA Agreed Order that requires the Port to conduct a Remedial Investigation and Feasibility Study (RI/FS) for the cleanup of the Lora Lake Apartment Property. An RI/FS Work Plan for the apartment parcel was implemented this year. A work plan to investigate the sediments and upland areas of the Lora Lake parcel is being developed this year, with data collection beginning next spring. A report that presents the findings of both investigations and analysis of clean up alternatives will be submitted to DOE in late 2011 or early 2012. Actual clean up will be accomplished under a follow-on order negotiated after the completion of the RI/FS. SeaTac Fuel Facilities Fuel Farm Groundwater contamination was discovered at this facility, the former Olympic Fuel Farm, during an investigation to define post-construction conditions as required by the lease between the Port and the SeaTac Fuel Facilities LLC. The extent of the contamination has been determined, and pilot testing of remediation systems has been completed. Remediation, consisting of passive collection of free product and ground water monitoring, continues. FINANCIAL IMPLICATIONS: The following table summarizes 2011 through 2015 forecasted spending for environmental remediation projects. orecasted spending for "Booked Liabilities" reflects projects described in the Scope of Work. Five-Year Spending Plan $'s in Thousands 2011 2012 2013 2014 2015 2011-2015 Booked Liabilities Project Spending $15,000 $25,000 $17,600 $1,600 $500 $59,700 Cash from 3rd Parties (5,200) (6,800) (5,400) (200) (100) (17,700) $1,400 Port Share $9,800 $18,200 $12,200 $400 $42,000 Anticipated Future Liabilities Project Spending $1,880 $5,800 $6,200 $2,615 $9,465 $25,960 Total Forecasted Spending $11,680 $24,000 $18,400 $4,015 $9,865 $67,960 Note: Forecasted payments by potentially liable parties included only for booked liabilities. Amounts do not include estimates of possible recoveries from grants, insurance or litigation. Source of Funds Environmental cleanup projects have multiple funding sources: (1) Seaport non-operating projects and Real Estate operating and non-operating projects are funded by the Port's Tax Levy; (2) Seaport operating projects are funded by the General Fund; (3) Airport projects a re funded by the Airport Development Fund. In addition, there are supplementary outside sources of funding, including the following: Cost sharing agreements with other PLPs (or PRPs), wherein the Port functions as a funding conduit for the other PLPs and the Port holds contracts on behalf of these other PLPs Invoicing and payment directly from other PLPs, such as tenants COMMISSION AGENDA Tay Yoshitani, Chief Executive Officer December 1, 2010 Page 8 of 10 Litigation settlements with other PLPs Insurance recoveries from both the Port's insurers and other PLPs' insurers Grant funding from the Washington DOE and the U.S. Environmental Protection Agency The following projects received grant funding in 2010 for existing projects: T30 and the Lower Duwamish Superfund site including early action sites T117 and T108. New grants were received in 2009 for T91 and East Waterway Superfund sites. These grants are complete unitl Washington DOE provides additional grants. In August 2010 DOE awarded a fifty-percent matching grant in the amount of $1.5 million to support the Lora Lake Apartments RI/FS COMMUNITY / CUSTOMER / ORGANIZATION IMPACTS: Elimination of unacceptable levels of environmental risk caused by the presence of contaminants in upland soil, in marine sediments, and groundwater is not only required by state and federal law, it is the hallmark of responsible environmental stewardship, from the perspectives of both the surrounding residential and business communities and the customers that we serve. The environmental remediation authorization will fund a mix of Port staff and outside cons ultant services that maximizes the effectiveness of staff. PROJECT SCHEDULE: This authorization is for funds forecasted to be spent during 2011 to 2015. ALTERNATIVES CONSIDERED/RECOMMENDED ACTION: The following alternatives were considered for accomplishing the work described in the Scope of Work: Alternative 1 Do not complete the work. If the Port chose to not complete the work, federal and/or state regulatory agencies could mandate the work be accomplished, either by the Port under an enforcement or similar order, or by the agency. In many cases, such arrangements already exist between the Port and regulatory agencies. In either case, the Port would lose the opportunity to employ the flexibility contained in the controlling regulations, to define and direct the work, and to manage costs. Alternative 2 Complete the work using Port staff. Port staff is already heavily involved in project direction, legal analysis, and project management, and will continue to perform these services. The nature and extent of the technical and legal work required to complete this work is substantial, and would require a large number of additional staff with additional expertise. In addition contracts would still be required for such work as laboratory analysis. Alternative 3 Complete the work using outside consultants and contractors. Outside consultants and contractors have sufficient numbers and types of specialists necessary for timely and cost effective completion of this work; however the work would be more costly than if some Port staff were also involved. COMMISSION AGENDA Tay Yoshitani, Chief Executive Officer December 1, 2010 Page 9 of 10 Alternative 4 Complete the work using a combination of Port staff (Alternative 2) and outside consultants and contractors (Alternative 3) that maximizes the ability for the Port to direct cleanup efforts and maximize the effectiveness of staff. Alternative 4 is recommended. PREVIOUS COMMISSION ACTION: On July 13, 1993, the Commission approved the expenditure of $1,050,000 for eight projects during 1993. On March 8, 1994, the Commission approved the expenditure of $776,000 for eleven projects during 1994. On March 28, 1995, the Commission approved the expenditure of $1,875,000 for nine projects during 1995. On February 27, 1996, the Commission approved the expenditure of $2,325,000 for eleven projects during 1996. On February 25, 1997, the Commission approved the expenditure of $1,100,000 to conduct the STIA Ground Water Study required by a Washington DOE Model Toxics Control Act (MTCA) Agreed Order. On June 8, 1999, the Commission approved the expenditure of $300,000 to conduct the Industrial Waste System Hydrogeological Study required by the DOE as a performance condition of the 1998 National Pollution Discharge and Elimination System Permit. On August 24, 1999, the Commission approved the expenditure of $800,000 for environmental cleanup of Port property adjacent to the Malarkey Asphalt Co. site. On March 14, 2000, the Commission approved the expenditure of $1,000,000 for aquatic sediment management for participating in the development and implementation of federal and state laws and regulations relating to the disposition of contaminated aquatic sediments, and the expenditure of $2,000,000 for cleanup-related investigations at the former Chevron Oil Terminal site at Terminal 30. On July 10, 2001, the Commission approved the expenditure of $5,100,000 for nine Aviation projects and six Seaport projects during 2001. On June 11, 2002, the Commission approved the expenditure of $1,500,000 and contract amendments for the Environmental Protection Agency's (EPA) Order on Consent to continue work on the Lower Duwamish Sediments Superfund site and the East Waterway Sediment Operable Unit of the Harbor Island Superfund Site. On March 11, 2003, the Commission approved the project-wide authorization expenditure of $4,999,000 for environmental cleanup action on Port properties and for potential environmental liabilities during 2003. Actual expenditures for 2003 were ultimately limited to $2,459,870. On March 23, 2004, the Commission approved the project-wide authorization expenditure of $8,081,000, for environmental cleanup action on Port properties during 2004. Actual expenditures for 2004 were ultimately limited to $2,136,943. COMMISSION AGENDA Tay Yoshitani, Chief Executive Officer December 1, 2010 Page 10 of 10 On March 23, 2005, the Commission approved the project-wide authorization expenditure of $8,102,222, for environmental cleanup action on Port properties during 2005. Actual expenditures for 2005 were ultimately limited to $6,255,791. On December 13, 2005, the Commission approved the project-wide authorization expenditure of $8,705,760 for environmental cleanup action on Port properties during 2006. On June 27, 2006, the Commission approved an increase in the 2006 project-wide authorization for environmental cleanup action on Port properties, to increase the authorization in the amount of $6,000,000 to $14,705,760. Expenditures for 2006 were ultimately limited to $11,087,873.38. On December 12, 2006 the Commission approved the project-wide authorization expenditure of $7,756,549 for environmental cleanup action on Port properties during 2007. Expenditures for 2007 were ultimately limited to $7,537,286. On December 1, 2007 the Commission approved the project-wide authorization expenditure of $11,833,000 for environmental cleanup action on Port properties during 2008. Expenditures for 2008 were ultimately limited to $11,322,258. On December 9, 2008 the Commission approved the project-wide authorization expenditure of $10,396,000 for environmental cleanup action on Port properties during 2009. Expenditures for 2009 were ultimately limited to 7,455,000. On November 30, 2009 the Commission approved the project-wide authorization expenditure of $13,141,000 for environmental cleanup action on Port properties during 2010. Expenditures for 2010 - through September 30, 2010 were $6,523,000.
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