EPA/ROD/R10-94/099
February 1995
EPA Superfund
Record of Decision:
Harbor Island (Lead)
(O.U. 3), Seattle, WA
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RECORD OF DECISION
DECLARATION, DECISION SUMMARY,
AND RESPONSIVENESS SUMMARY
FOR
LOCKHEED SHIPYARD FACILITY, HARBOR ISLAND
SEATTLE, WASHINGTON
JUNE. 1994
UNITED
STATES EHVIROHHENTAL PROTBCTION AGENC~
REGION 10
1200 SIXTH AVENUE
SEATTLE, WASHINGTON
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DECLARATION
SITE NAME AND LOCATION
Lockheed S...ipyard Facility, Harbor I land
Seattle, King County, Washington
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STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected final remedial
action, for soil and. groundwater, for the Lockheed Shipyard
.facility operable unit on the Harbor Island site in Seattle, King
County, Washington. This remedy was chosen in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) (42 U.S.C. ~~ 9601-96), as amended, and, to the
extent practicable, the National Contingency Plan (NCP). This
decision is based on the Administrative Record for the Lockheed
facility which is available in EPA's Record Center, 7th Floor,
1200 Sixth Avenue, Seattle, Washington, 98101.
The Washington state Department of Ecology (Ecology) concurs with
... the selected remedy given the specifics found at the LOckheed
facii1ity.. . . . . . .
The U.S. Environmental Protection Ag~ncy (EPA) has divided the
Harbor Island site into four operable units: 1) the petroleum
storage tank facilities (ARCa, Shell and Texaco) operable unit,
2) the marine sediment operable unit, 3) "soil and groundwater"
operable unit, and 4) the Lockheed Shipyard facility.operable
unit. EPA is the lead agency for the Lockheed, marine sediments,
and soil and groundwater units. A cleanup action was selected
for the soil and groundwater operable unit in a Record of
Decision issued in september ,1993. EPA has designated the .
Washingtor Department of. Ecology (Ecology) as the lead agency for
the petroleum storage tank operable anit because the primary
contaminant there.is petroleum, which is excluded from the
federal Superfund statute but is regulated under the State's
Model Toxic Control Act (MTCA). A cleanup decision for the
petroleum storage tank operable unit is expected to be made by
Ecology in early 1995. The marine sediment operable unit will be
addressed in a Record of Decision which EPA intends to issue in
1995. This decision document addresses only the Lockheed
.Shipyard facility.. .
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ASSESSMENT OF THE FACILITY AND ADJACENT AREAS OF CONTAMINATION
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare
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TABLE OF CONTENTS
Section
............
........
I.
Declaration
II. Decision Summary
A.
Introduction
. . . . .
.......
. . . .
. . . . .
B.
site Name, Location and Description.
. . .
. . . . .
c.
site History and Enforcement Activities.
. . . . . .
D.
Highlights of Community
Participation
.......
E.
Scope and Role of Respons~ Action.
Summary of Site Characteristics
. . .
. . . . .
. . . .
. . . . .
F.
G.
Summary of Site Risks. ...
. . . . .
. . .
. . . .
H.
Re~edial Actiqn Objectives
.' .' . . .
. . . .
I.
Description of Alternatives. .
. . . . .
. . . .
J.
Summary of the Comparative Analysis of Alternatives
K.
The Selected Remedy. . .
. . . . .
. . . . .
L.
Statutory Determinations
. . . . .
. . . .
. . . .
M.
Documentation of Significant Changes
. . .
. . . .
Appendices
Appendix A: Responsiveness Summary
_paqe
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3
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12
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22
29
33
37
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Appendix B: Method for Determining Hot spot Treatment Level
Appendi~ C:Exposure Estimate for Thermal Desorption.
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List of Figures
Figure 1: Harbor Island Location Map
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Figure /.: Lockheed Shipyard Locat.on on Harbor Island
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Figure 3: Areas Exceeding Cleanup Goals
. . .
. . .
Figure 4: Soil Petroleum Hot Spots
. . . . . .
. . .
List of Tables
Table 1: Remedial Action Objectives and Cleanup Goals
Table 2: Selected Soil Remedy Costs
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Table 3: Selected Groundwater Remedy Costs
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2
4
20
21
\,.
.18
38
39
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DESCRIPTION OF THE SELECTED REMEDY
The remedial action described in this Record of Decision
represents a final remedy for treatment of the Lockheed Facility
soil and groundwater operable unit. The remedial action
presented in this ROD addresses the risks to 'human health and the
environment by:
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"1) Excavate and treat soil con~aining the highest levels of
petroleum contamination ("hotspots"). The petroleum hot spots
are defined as those areas with concentrations of Total
Petroleum Hydrocarbons (TPH) greater than 10,000 mg/kg. The
TPH hot spot soil will be treated on-site by a thermal '
desorption system with an afterburner, instead of condensate
coilection as identified in the preferred alternative.
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2) contain exposed contaminated soil exceeding inorganic and
organic cleanup goals. Containment woulc. be achieved with a,
three inch asphalt cap designed to reduce infiltration of
rainwater and reduce contaminant migration into the
environment~ Existing asphalt and concrete surfaces which are
damaged in areas exceeding cleanup goals would either be
replaced or repaired. Maintenance of new and existing caps
would also be required under a Consent Decree for the settling
PRPs as long they own the Lockheed facility.
3) Invoke institutional controls which would 'warn future
'property owners of remaining contamination'contained under
capped areas on this property, require future owners and
operators to maintain these caps, and specify procedures for
handling and disposal of ~xcavated contaminated soil from
beneath the capped areas if excavation is necessary in the
future.
4) Monitor groundwater quality semi-annually for 30 years, or
until it has been demonstrated that groundwater contaminants
will not reach the shoreline in concentrations exceeding
cleanup goals.. ,Thegroundwater'quality data will' be reviewed
at a minimum of every ij ./e years to assess the effectiveness
of the selected remedy to meet ~ater quality cleanup goals at
the shoreline. This periodic data review will be conducted by
EPA a~d Ecology and will coincide with the groundwater data
review for the soil and. groundwater operable unit. If
groundwater data indicates that contaminants are likely to
exceed cleanup goals at the shoreline, additional soil and/or
groundwater remedial actions may be required in the future.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with state and federal requirements that
are legally applicable or relevant and appropriate to the
remedial actions, and is cost effective. This remedy uses
permanent solutions and treatment technologies to the maximum
extent practicable for this site by treating the most highly
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remedy satisfies the statutory pr~~ference for remedial actions
that employ treatment to reduce toxicity, mobility and volume.
Because this remedy will leave some hazardous substances on site
above clea~up goals, a review of the site and its remedy will be
conducted within fi~e years after initiation of the remedial
action to ensure the remedy continues to provide adequate
protection of human health and the environment.
~~
Chuck Clarke
Regional Administrator, Region 10
U.S. Environmental Protection Agency
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CONCURRENCE
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DECISION SUMMARY
LOCKHEED SHIPYARD, HARBOR ISLAND,
SEATTLE, WASHINGTON
A. INTRODUCTION
'"
The Lockheed Shipyard is an operable unit within the Harbor
Island Superfund Site (Site), located in Seattle, King County,
Washington. The site was listed on the National Priorities List
(NPL) in 1983 due to elevated lead concentrations in the soil
from a lead smelter on the island, as well as elevated
concentrations of other hazardous substances. A site assessment
was performed by the United states Environmental Protection
Agency (EPA) in 1985, pursuant to section 105 of the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, 42 U.S.C. ~ 9605, as amended, (CERCLA). The Lockheed
Shipyard facility contains no wetlands, floodplains, rare or .
endangered species, historical sites or structures.
The site has been divided into four operable units: 1) the
petroleum storage tank facilities (ARCa, Shell and Texaco), 2)
the marine sediments, 3) "soil and g'roundwater" unit, .and 4) the
. Lockheed Shipyard facility. EPA is the lead agency for the'
Lockheed, marine sediments, and soil and groundwater units. A
cleanup action was selected for ~he E::>il and groundwater unit in
a Record of Decision issued in September 1993. EPA has
designated the Washington Department of Ecology (Ecology) as the
lead agency for the petroleum storage tank unit because the
prima'ry contaminant there is petroleum, which is excluded from
the federal Superfund statute but is regulated under the State's
Model Toxic Control Act (MTCA). A cleanup decision for the
petroleum storage tank unit is expected to be made by Ecology in
early 1995. The marine sediments unit will be addressed in a
Record of Decision 'which EPA intends to issue in 1995.
Pursuant to Executive Order 12580 (Superfund. Implementation) and
the National oil and Hazardous Substances Pollution Contingency
Plan (NCP), 40 C.F.R. Part 300, Lockheed completed a Remedial
Investigation/Feasibility study (RI/FS) under a Consent Order
issued by EPA. EPA issued a Proposed Plan for the Lockheed
facility in April, 1994.
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B. SITE NAME, LOCATION, AND DESCRIPTI.ON
Harbor Island is located approximately one mile southwest of
downtown Seattle, in King County, Washington, and lies at the
mouth of the Duwamish River on the southern edge of Elliott Bay.
The island is approximately 430 acres in size and is bordered by
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Harbor Island Location
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From 1903 to 1905, Harbor Island was created from marine
sediments dredged from the Duwamish River. Dredged sediment was
placed across the Duwamish tidelands to form a fairly homogeneous
sandy fill which is now Harbor Island. Since construction,
Harbor Islanq has been used for commercial and industrial
activities including shipping, railroad trapsportation, bulk fuel
storage and transfer, secondary lead smelting, lead fabrication,
shipbuildin'J, and metal plating. War! :houses, laboratori~s, and
office buildings have also been located on the island.
..
"
The Lockheed Shipyard facility is located at 2929 16th Avenue
S.W. on Harbor Island. The site occupies approximately 18.5
acres on the west side of Harbor Island and is adjacent to the
West Waterway (Figure 2). Shipbuilding activities had been
conducted on the site since the mid-1930s and the site was used
by Lockheed to build and refurbish ships from 1959 to 1986. . .
Shipbuilding activities included metal fabrication, pipefitting,
electrical wiring, sandblasting and painting. The facility has
been inactive since 1986, except for limited material storage.
Approximately 35 buildings are located on the site and several
buildings are constructed on wooden piers. Two shipways slope
from. above the ground surface into the west waterway. Over 90% of
surface area of the shipyard is currently paved.
c. SITE HISTORY AND ENFORCEMENT ACTIVITIES
. .
Prior to '1885,' the area which is currently Harbor Island'
consisted of tide flats and a river mouth delta with some piling-
supported structures. Initial constrL~tion of the island began
between 1903 and 1905 when' dredging of the East and West
waterways and the main navigational channel of the. Duwamish Riv~r
occurred. Dredged sediment was spread across the present island
area to form a fill 5 to 15 feet thick. This dredged 'sediment was
later covered with soil and demolition debris from Seattle
regrade projects. Since its construction, the island has been
used for commercial and indu~trial activities. Major activities
. have included ocean and rail transport operations, bulk fuel
'storage anr transfer, secondary lead smelting, lead fabrication,
shipbuilding, and metal plating. Warahouses, laboratories, and
office buildings also have been located on the island. The
secondary lead smelter was originally constructed on Harbor
Island in 1937 and was located near the center of the island.
. u
Concern over the levels of lead in the air, due to the operation
of the lead smelter, prompted several air monitoring studies
during the 1970s. A study conducted in 1979 by the Puget Sound.
Air Pollution Control Agency (PSAPCA) showed that the quarterly
average amJ::.ient air concentration of lead exceeded the f.edero'-
standard for lead of 1.5 ~g/m3 95% of the time. Subsequently, a
site inspection conducted by EPA in 1982 identified a significant
volume of lead contaminated soil at the lead smelter facility. As
a result of this site inspection, the island was listed on the
NPL in 1983.
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Figure 2
Lockheed Shipv~rd Loc:"'tion on Harbor Island
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The lead smelter ~eased operatio~ in 1984, but the facility later
was subject to a RCRA enforcement action in conjunction with the
closure of a surface impoundment. As part of this action,
groundwater monitoring wells were installed and soil borings were
taken to determine soil quality. In 1985, the Department of
Ecology performed a preliminary investigation of the site to
further define the nature and extent of contaminat~on on the
island. This investigation, and subsequent investigations,
revealed numerous other types of cont~minants in addition to
lead, in..luding: cadmium, chromium, asenic, copper, zinc,
mercury, polycyclic aromatic hydrocar~ons (PAHs), polychlorinated
biphenyls (PCBs), and petroleum products.
'u
In 1986, approximately 220 parties associated with the Site were
sent 104('e) information request letters by EPA. Based on the
responses received, a Potentially Responsible Party (PRP) search
was completed for Harbor Island in 1987. Since many of the
facilities on the island had multiple owners and operators, the'
search identified approximately 150 PRPs. These PRPs were
subsequently sent "general notice" letters. As a result of
further evaluation of the information gathered on these PRPs, EPA
removed 48 parties from the PRP list in 1989, and removed an
additional 38 parties in 1994, bringing the current total of PRPs
to 55. Evidence to be submitted by some of the remaining PRPs
regarding their involvement at the site may lead to a few more
parties being removed from the PR~ list.
In 1987, EPA .plan~ed a Phase. I RI which included only areas on .
the island. where there had been a release of hazardous substances.
from past 'operations. In an attempt' to' have this work performed
by the PRPs, EPA sent "special notice" letters to 13 PRPs stating
that EPA intended to conduct a remedial investigation unless the
PRPs agreed to perform the work. EPA subsequently elected to
perform the work with federal funds because EPA could not reach
an agreement with these 13 PRPs. The Phase I investigation was
initiated in 1988 and completed in 1990 at an approximate cost of
$800,000.
. u
During implementation of the Phase I RI, EPA negotiated a Consent
Order'with the city of Seattle. Under: the terms of' this Order,
the City of Seattle cleaned cQntaminated sediments from its storm
drain system on Harbor Island. These storm drains' were considered
a major pathway for contaminants entering the surrounding waters.
and marine sediments. The work under this Order was core~leted in
the Spring of 1990 and the City is now periodical~y monitoring
the discharge from' these stormdrains to ensure that they meet
water quality standards. In a separate enforcement action, EPA
negotiated a 'Consent Order for a removal with the owner of the
Value Metal Plating facility in January, 1991. This Order
required the removal and off-site disposal of about 80 drums of
sr~nt electroplating solution. The wo:"k under this Order was
completed in December, 1992.
Before proceeding with the next phase of the RIfFS, EPA noticed
PRPs associated with several large facilities to allow the~ an
opportunity to conduct an RIfFS on their facilities. Initially,
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four facilities were identified as potential PRP lead operable
units: the petroleum storage tank facilities, Todd Shipyard,
Lockheed Shipyard, and Terminal 18 (Port of Seattle). Todd
Shipyard and Lockheed Shipyard were sent special notice letters
requesting that they conduct an RI/FS on their facilities in
June, 1990. In September, 1990, Lockheed agreed to conduct an
RI/FS for the shipyard facility under a Consent Order to EPA.
Negotiations were terminated with Todd due to submission of an
inadequate good faith offer. An RI/FS special notice letter was
sent to the Port of Seattle for Terminal 18 in January, 1991, but
negotiations were terminated after the Port decided not to
conduct the work., Both the Todd Shipyard and Terminal 18
facilities were then added to the soil and groundwater operable
unit being conducted by EPA.
,"
o.
The petroleum tank storage unit consists of three storage tank
facilities owned by Shell; ,ARCO, and Texaco. Since petroleum is
excluded from the definition of "hazardous substance" under'
CERCLA, but is a hazardous substance under MTCA, EPA and Ecology
signed a memorandum of agreement 'which gives Ecology the lead in,
undertaking enforcement action for these three tank farms.
Agreements between Ecology and the tank farm owners to conduct
RI/FSs ~ere finalized in early 1993 and the selection of remedial
actions is scheduled for early 1995. EPA elected to conduct the
RI/FS on the marine sediment operable unit and the soil and
groundwater operable unit.
The RI field wQrk for the soil 'and groundwater unit began in May,'
1991; .and the field work for the marine sediment unit was' ,
initiated in September, 1991. The marine sediment operable unit
RI/FS reports and Proposed Plan are scheduled to be completed at
the end of 1994. The ROD for the marine sediment unit is
. scheduled for 1995.
D. HIGHLIGHTS OF COMMUNITY PARTICIPATION
CERCLA requirements for public participation include releasing
,the Remedial Investigatiop arid Feasibility Study Reports. a~d the
Proposed Plan to the public and providing a public comment period
on the Feasibility Study and Proposed Plan. EPA met these
requirements in March 1994, by placing both Remedial
Investigation and Feasibility Study Reports in the public
information repositories for the site. EPA mailed copies of the
Proposed Plan on April 22, 1994 to individuals on the mailing
list. EPA published a notice of the release of the RI/FS and
proposed plan in the Seattle Times in the morning edition on
April 25, 1994. Notice of the 30 day public comment period and
the public meeting discussing the proposed plan were included in
the newspaper notice. The public meeting was held on May 11,
1994, at the EPA Region 10 Headquarters on sixth Avenue in
Seattle. Public comments received are located in the
Responsiveness Summary section of the ROD.
o .
To date, the following community relations activities have been
conducted by EPA at the Harbor Island site:
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March 1988- EPA updated the 1985 Community Relations Plan.
April 1988- EPA released a fact sheet explaining the
environmental problems at the site. .
December 1988- EPA released a fact sheet announcing the beginning
of the Remedial Investigation. .
June 1989- ~PA mailed an update on tl ~ work at the site.
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November 1989- A fact sheet is released explaining the work being
conducted by the City of Seattle to clean and sample the storm
drain system on the island. .
June 1990- EPA releases an update of the activities at. the site'.
January 1991- EPA releases a fact sheet announcing plans to
remove approximately 80 drums and sqme miscellaneous containers
at the Value Metal Plating facility.
April 1991- EPA announces the availability of the Phase I report
and the beginning of the Phase II, investigation.
September 1992- EPA releases an update of the activities at the
site.
June 23, 1993- Ad runs in the Seattle Times announcing the public
comment period and the date and. time o~ the soil 'groundwater
public meeting.
June 23, 1993- EPA releases the ~ropcsed Plan for the cleanup of
soil & groundwater.
July 9, 1993- EPA releases a notice of the extension to the
public comment period.
August 23, 1993-'The public comment period on soil & groundwater
closes.
November 3, 1993- EPA announces cleanup decision for soil and
groundwater.
April 22, 1994- EPA releases a Proposed Plan summary fact sheet
and the Proposed Plan for cleanup of the Lockheed Shipyard
facility.
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April 25, 1994- Ad runs in the Seattle Times announcing the
public comment period on the Lockheed Shipyard Facility.
May 11, 199A- Public Meeting on the Inckheed Shipyard Proposed
Plan.
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E. SCOPE AND ROLE OF RESPONSE ACTION WITHIN THE REMEDIAL STRATEGY
contaminated media at Harbor Island consists
and sediments. The overall remedial strategy
to initiate cleanup of contaminated soil and
because they pose a risk to ~:wnan health and
contamination to the marine sediments.
of soil, groundwater
for Harbor Island is
groundwater first
act as source,s of
The remedia1 action selected in this {ecord of Decision addresses
all contaminated soil and groundwater on the Lockheed facility
property and is the second action selected for the Site. Remedial
actions for the petroleum storage tank unit will selected by
Ecology. It is intended that these actions will be compatible
with the remedial actions selected for the Lockheed and soil and
groundwater units.
.
u'
Sediments at Harbor Island have been contaminated by direct
runoff from contaminated surface soil, indirect runof'f, through
storm sewer systems, and groundwater contaminant loading.
Contamination by direct and indirect runoff will be controlled by
the selected remedy for the Lockheed unit through: 1) excavating
and treating petroleum "hot spots" soil, and 2) capping all areas
where contaminants exceed cleanup goals.
F. SUMMARY OF SITE CHARACTERISTICS
General Characteristics
, "
Harbor' Island is situated in a geographic area k'nown as the puget '
Lowlands, a trough characterized by low relief, with glacially
shaped bluffs and low rising hi~ls, a,d a vast area of intertidal
and tidal flats. puget Sound, in which Harbor Island is located,
is an inland marine waterway formed through continental'
glaciation. Harbor Island is located on the former delta of the
Duwamish River, which flows into Elliott Bay and Puget Sound from
the Duwamish-Green River valley.
The island, including the Lockheed facility, is composed largely
of native fluvial sand dredged from the surrounding areas. ..
Dredged sediment was placed across the Duwamish tidelands to form
'a fairly homogeneous sandy fill which is now Harbor Island. This
fine-grained fill consists primarily of poorly graded, very dark
gray, fine to medium, damp to wet, loose sand. The fine-grained
fill thickness ranges from 3 to 15 feet. Alluvial deltaic
deposits, consisting of unconsolidated, fine to coarse-grained
sand, underlie the fill material. Overlying the fine-grained fill
is a layer of coarse-grained fill which is from Seattle regrade
projec~s conducted in the early 1900's. This coarse-grained fill
consists of gravelly' sand to coarse sand, dark grayish brown,
poorly graded, loose, dry to moist. The thickness of the coarse-
grained fil~ ranges from 0 to 7 feet. .
"
"
Adjacent Land Use
Harbor Island is currently used for industrial and commercial
purposes. Immediately ,north of the Lockheed Shipyard is the ARca
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petroleum storage tank facility, to the east are several
industrial/commercial businesses, to the south is the Fisher
Mills facility, and to the west lies the West Waterway of the
Duwamish River. .
Use of Natural Resources
"0
Surface wai:er runoff is collected ar'l drained from Harbor Island
via a city owned storm drain system i,;onsisting of catch -basins,
outfalls, and drainage manholes throughout the island. This
system discharges at 11 outfalls around the perimeter of Harbor
Island and into the East and West waterways. The Lockheed
facility has its own storm drain system which collects surface.
runoff and drains into the West Waterway. The west Waterway is
used primarily for commercial shipping. There are no natural
ponds on Harbor I s.1 and .
There are no drinking water wells in use on Harbor Island.
Harbor Island groundwater is not currently used for drinking
water and all water users on the island are serviced by the city
of Seattle water system. Groundwater at a depth of approximately
40 feet is natlirally brac)dsh and not potable. Groundwater at
Harbor Island is not considered to. be a future drinking water
source. .
Groundwater Resources
Groundwater at . Harbor Island,. including the Lockheed facility,
occurs as shallow, unconfined groundwater within the fill and
deltaic sejiment. The depth to the groundwater is shallow and
ranges from 2.5 feet to 11 feet below ground surrace (bgs).
This groundwater occurs as freshwater and becomes brackish at
depths of 45 feet near the shoreline, and deeper at inland
locations. The water bearing stratigraphic column behaves as a
single hydrostatigraphic unit.
Groundwat~r recharge occurs through infiltration of .
precipitation. The groundwater level is highest in. the no~hern
half of the island, where recharge is greatest. Groundwater
elevation distribution indicates a radial flow condition with
discharge to the adjacent waterways. Groundwater surface
elevation decreases from the north central portion of the island
to the southern portion because a greater percent of the southern
portion is paved, preventing recharge through infiltration. The
groundwater also responds to tidal forces within the adjacent
marine estuary.
Known or Suspected Sources of contamination
y
Since construction, the island has been used for commercial and
industrial activities. Major activities include shipping,
railroad transportation, bulk fuel storage and transfer,
secondary lead smelting, lead fabrication, shipbuilding, and
metal plating. Warehouses, laboratories, and office buildings
have also been located on the island. The primary source of
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contamination at the Lockheed ShiFyard is shipbuilding activities
conducted at that facility since the mid-1930's. Some lead
contamination at this facility may also be attributed to the lead
smelter which operated nearby on the island.
Summary of the. Remedial XDvestiqatioD
In 1989, Lockheed conducted an Environmental Assessment of the
shipyard, which identified a numbe- of areas of potential
environmental concern. The review identified features iJ1'::::_.:':'l&;"
above and below ground storage tanks, impoundments, oil stained
areas, storm drain sediment and sandblasting grit. These areas
were sampled as part of the Remedial Investigation (RI) to
determine the nature and extent of contamination. Specific
sampling included the following: .
.0
,.
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Collection of
maximum depth
collection of
soil borings;
soil samples from 44 soil borings drilled to a
of approximately 7 feet using a drill rig and
soil samples from eight shallow hand auger
.
Collection of 20 surface samples for metals analyses in a
200-foot grid pattern across the upland portion of the
Lockheed facility; .
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Construction of 25 shallow (maximum depth approximately 20
feet) monitoring. wells and collection of soil samples and
groundwater samples. from each location; and
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Collection of 12 samples (4 during the RI and 8 after the
RI) of sandblasting grit in t'1e shipways.
Surface and Subsurface Soil Results
The results of analyses of surface soi1 samples collected during
the remedial investigation are presented in this section. Results
are presented according to classes of chemical compound. It was
determined that none of the soil on the Lockheed facility is RCRA
. characteristic or listed hazardous waste. . .
A total of 17 different volatile organic compounds (VOCs) were
detected in soil samples collected from the facility. The VOC
concentration ranged from 1 to 810 ug/kg. The most frequently
detected VOCswere tetrachloroethene, methylene chloride,
toluene, xylenes, and acetone. The highest concentrations of
tetrachloroethene were 500 and 810 ug/kg found at two locations
in the surface soil. The highest concentrations of methylene
chloride were 190 ug/kg at a 6.5 foot depth, and 590 ug/kg at a 5
foot depth. T,he highest concentrations of toluene were 88 'ut'f/kg
in the surface, and 210 ug/kg at a 7 foot depth. The highest
concentrations of xylenes were 16 ug/kg in the surface, and 49
ug/kg at a 5 foot depth. The highest concentrations of acetone
were 260 ugjkg in the surface, and 520 ug/kg at a 5 foot depth.
The locations where elevated concentrations of VOCs were detected
occur most frequently along the northern and southern portions of
the facility. .
Q
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.
u
A total of 27 different semi-vola~ih, halogenated organic
compounds, primarily polyaromatic hydrocarbons (PAHs), were
detected in soil samples .collected at the facility. In general,
these PAHs were found in are~s which had also been contaminated
with petroleum products. Fluoranthene, pyrene, phenanthrene, and
chrysene were the most frequently detected PAHs and the
concentrations of total PAHs at the facility ranged from 7 to
39,000 ug/kg. The highest concentrations of fluoranthene were
26,000 u?/kg in the surface, and 16,( )0 ug/kg at a 7 foo~ depth.
The highest concentrations of pyrene ,.,ere 15,000 ug/kg at the
surface, and 3,600 ug/kg at a 3 foot depth. The highest
concentrations of phenanthrene were 39,000 ug/kg in the surface,
and 17,000 ug/kg at a 5 foot depth. The highest concentrations of
chysene were 3,800 ug/kg at the surface, and 2,100 ug/kg at a 3
foot depth. ,
Arsenic, cadmium, lead, and mercury were detected at levels high
enough to be a potential risk to human health. Arsenic
concentrations ranged from 1.1 to 236 mg/kg and was found at its
highest concentration in the surface soil. cadmium ranged from
0.35 to 12.7'mg/kg and was detected at its highest concentration
at a 10 foot depth. Lead ranged from 0.84 to 3,520'mg/kg and was
found at its highest concentrations at a 5 foot depth. Mercury
ranged from 0.07 to 4.6 mg/kg and was found at its highest
concentration in the surface s.oil. ' ,
Total petroleum hydrocarbons (TPH) were detected frequently in
"the soil across' the facility. TPH concentration ranged from 5, to '
51,000 mg/kgwith the highest level occurring in the surface
soil. Four samples at a 5 foot depth were in the range of 10,000
to 18,000 mg/kg. The most significant area of contamination
occurs along the northern property boundary.
In the sandblasting grit samples, arsenic concentrations were in
the range of 300 to 500 mg/kg and the lead concentrations ranged
from 300 to 1,800 mg/kg. '
Groundwater Results
In the groundwater, contamina~ts of concern and their maximum
concentrations included: benzene in one well at 780 micrograms
per liter (~g/L) in June 1991 and 180 ~g/L in June 1992,
tetrachloroethane (PCE) at 48 ~g/L in two wells, copper at 74.1
Jjg/L, lead at 11. 4 ~g/L, and zinc at 329 ~g/L. The highest
levels of groundwater contaminants were found at the north and
south ends of the facility in monitoring wells located 200 to 450
feet back from the shoreline. The investigation did not find any
floating petroleum product on the groundwater associated with the
, petroleum contamina~ed soil areas. '
u
Routes of Potential Migration
The fate of contaminants originating from the Site, including the
Lockheed facility, depends on location-specific migration
pathways and on the chemical and physical properties of each
contaminant. This section focuses on the contaminants of concern
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and identifies their probable routes of migration in surface
soil, subsurface soil, and groundwater.
Surface Soil
The principal transport mechanisms of the contaminants in surfa~e
soil are as suspended soil in surface water runoff. Surface water
runoff is a significant current transport pathway for
contaminan"-.3 to reach the surroundin~ waterways and mari_ne
sediments. Surface water runoff can t._"ansport dissolved, .
suspended, and particulate-bound contaminants through storm
drains into the surrounding estuary.
Subsurface Soil
CO
The probable transport mechanism of the primary contaminants in
subsurface soil is vertica~ transport of dissolved contaminants
in rainwa.ter which permeates through the soil. The primary factor
which determines the rate which inorganic and organic
contaminants' leaches from the soil is the contaminant solubility.
For inorganics, the pH of the water contacting the contaminated
soil is also an important factor. Inorganics are relatively less
mobile in the soil than organics because inorganics have
relatively low solubility in water and they also strongly adsorb
to soil particles., particularly silts and clay. Organics, on the
other hand, are generally more soluble in water and primarily
bind to naturally occurring soil organic matter, such as humic
acid. Organic 'contaminants .inhigh concentrations, such as '.
petroleum, can also travel through pores in the soil as a Non-
Aqueous Phase Liquid (NAPL). Organic contaminants in the NAPL
state will not bir.d to soil organic m1tter and can flow through
soil pores at a relatively fast rate. Residual NAPL can remain in
the unsaturated (vadose) zone for long periods of time due to
capillary attraction. .
Groundwater
Contaminants in groundwater at the Lockheed facility are
typically transported as dissolved constituents. A two-
dimensional groundwater transport mod':!l (FLOWPATH) along with a
Digital Elevation Modei was used to determine both' loading ~ates
and concentrations of contaminants at the shoreline. The
contaminant transport calculations performed by the model predict
the concentration of contaminants at the shoreline and estimate
the time for contaminant concentrations to exceed cleanup goals
at the shoreline, which is the point of compliance. The results
of this model predict none of the contaminants currently in the
groundwater at the Lockheed facility will exceed cleanup goals,
at the point where the groundwater reaches the shoreline, withiri
the next 50 years.
o
G. SUHKARY OF SITE RISKS
An assessment of the human health risk for the Site, including
the Lockheed facility, was completed as part of the soil and
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groundwater unit Remedial Investigation Report. This assessment
involved several steps, including: identification of contaminants
of concern, an exposure assessment, a toxicity assessment, and a
risk characterization, all of which are described below.
The results of a habitat eva~uation indicated that Harbor Island
is unable to sustain a wildlife population or support a
functioning wildlife habitat due to widespread industrial
development Therefore, an ecological risk assessment w~s not
performed due to the absence of wildl_fe habitat areas on Harbor
Island. An ecological risk assessment will be conducted for the
marine sediment operable unit of this island.
'u
Contaminants of Concern
A mUltiple-step screening approach was used to identify the
analytes of concern for the human health risk assessment. To be
included .in the risk assessment, contaminants had to occur. in at
least stof the samples and had to be at a concentration high
enough to have a risk greater than 10-6 or hazard index of 0.1
Of all the contaminants identified as a potential health risk for
Harbor Island, only three .of them, lead, arsenic, and PAHs, are
in concentrations high enough to be of COncern at the Lockheed
facility.
Exposure Assessment
ijarbor Island has been u~ed for industrial purposes for .. .
approximately the last 80 years. There are no homes, residential
areas, schools, or commercial daycare facilities on Harbor
Island, . and these conditions are not~ikely to change in the
foreseeable future. For that reason, an industrial exposure
scenario is most appropriate for Harbor Island and the Lockheed
facility and is the exposure scenario discussed below.
Industrial workers Who may incidentally ingest soil through hand-
to-mouth contact and absorb contaminants through dermal contact
with conta~inated soil were identifi~d as the population most at
. risk of adverse he~lth effects. Inhalation is not a significant
pathway of exposure to contaminants on Harbor Island based on the
results of air dispersion modeling conducted during the remedial
investigation. The noncancer hazard from inhalation was not
significant (hazard index of less than one)., and the cancer risk
was approximately two orders of magnitude less than that observed
for the ingestion pathway for all scenarios evaluated.
"
Potential human exposure to contaminants in groundwater was not
.evaluated because there is no current or foreseeable use of
groundwater for drinking water purposes, and the entire island is .
serviced by the city of Seattle water system. Further, the
majority of groundwater beneath Harbor Island is naturally
brackish and unsuitable for drinking.
Assuming an industrial scenario, risk was calculated for the
re~sonable maximum exposure (RME) and for an average exposure.
The risks cited in this document are for RME only. The risks for
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the average exposure can be found in the Baseline Human Health
Risk Assessment. RME is equal to the upper 95% confidence limit
of the concentration distribution for each contaminant. For
incidental soil ingestion and dermal contact exposures, measured
soil concentrations were used to determine the RME values. RME
va:ues for inhalation exposures were estimated using the results
of air dispersion modelir.g. The exposure assumptions used for all
three pathways are based on EPA Region 10 risk assessment
guidelines.~nd are specified in the ~aseline Human Health Risk
Assessment.
r'
In calculating risk for an industrial exposures it was assumed
that risks from incidental soil ingestion, dermal absorption, and
inhalation were additive and contributed to the total body
burden. Combining all of the exposure assumptions, summary
intake factors (rates of ingestion, absorption and inhalation)
were derived for each exposure pathway~ For the purpose of the
risk assessment, the duration for an industrial exposure was set
at 25 years.
,.
Toxicity Assessment
In order of priority, the following EPA sources were consulted
for toxicity cri~eria:Integrated Risk Information System (IRIS):
Health Effects ASsessment Summary Tables (HEAST): and EPA's
Environmental criteria and Assessment Office (ECAO). The basis
for the noncarcinogenic and carcinogenic toxicity criteria used
to calculate risk for the contaminants of concern is briefly
discuSsed below. ..
The toxici~y criteria used to evaluate noncancer risks are
reference doses (RfDs). The term RfD refers to a daily intake of
a contaminant to which an individual, including sensitive
~ubpopulations, can be exposed without any expectation of
noncarcinogenic adverse health effects (e.g., organ damage,
biochemical alterations, birth defects). The contaminant of
concern for noncancer health effects at the Lockheed facility was
. arsenic. This contaminant was only of concern through the oral
route. . .
The toxicity criteria used to evaluate cancer risks are cancer
slope factors. A cancer slope factoz is a numerical estimate of
the potency of a contaminant that, when multiplied by the average
lifetime dose, gives the probability of an individual developing
cancer over a lifetime. In developing cancer slope factors, it
is assumed by the EPA that any dose of a carcinogen, no matter
how small, is capable of. causing cancer. Slope factors are
derived by EPA using a linearized multistage model and reflect
the upper-bound limit of a contaminant's cancer potency. ..
o
o
The contaminants of concern for cancer health effects at the
Lockheed facility were arsenic and PAHs.. Due to uncertainty on
the appropriate toxicity criteria to use for evaluating lead,
this metal was not included in cancer and noncancer risk
calculations, but was evaluated using the uptake biokinetics
model.
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Arsenic is classified by EPA as a known human carcinogen. The
oral slope factor for arsenic obtained from IRIS was 1.8 (mg/kg-
day) -1. Carcinogenic PAHsare classified by EPA as probable
human carcinogens. The oral slope factor (also used as the
. dermal slope factor) obtained from the EPA ECAO was 5.8 (mg/kg-
day) -1. This is the slope factor for benzo (a) pyrene. In
evaluating r1sk for other carcinogenic PAH~, this slope factor
was used in conjunction with a toxic equivalency factor (TEF)
approach. Using the TEF approach the slope factor for
benzo(a)pyrene was multiplied by u numeric factor to adJu~~ ~~r
the differing toxicities of the carcinogenic PAHs.
Risk Characterization
""
Noncarcinogenic risks were evaluated by comparing contaminant
daily intakes to reference doses (RfDs). This was accomplished
by calculating hazard. quotients and hazard indices. A hazard.
quotient for a particular contaminant' through a given exposure
route is the ratio between the estimated d~ily intake and the
applicable RfD. A hazard index is a sum of hazard quotients,
which may be summed for all contaminants for a given exposure
pathway, and across pathways. If a hazard quotient or hazard
index exceeds 1.0, it indicates that potential noncarcinogenic
health effects may occur under the defined exposure conditions.
Carcinogenic risk was calculated for each carcinogen by
multiplying the estimated daily intake of carcinogen by the
appropriate cancer slope factor. Carcinogenic risk was . .
calculated for each carcinogen through. each exposure pathway for
each individual. The total carcinogenic risk for the industrial
scenario was calculated by summin~; carcinogenic risk across
exposure pathways, and across exposure pathways and age groups
(infant and child) for the commercial scenario. According to t~e
National Contingency Plan, the acceptable risk range for
carcinogens at a Superfund site is between 1 in 1,000,000 (10-6).
and 1 in 10,000 (10-4).
For the L9ckheed facility the noncarcinogenic risks, calculated
. in the ~orm of a haza;rd index, were found t~ range from 0.01 to .
'0.07. This range is well' ~~low a hazard index of 1.0, which is
considered to be the threshold below which no adverse health
effects are observed. The carcinogenic risk at the Lockheed
facility was calculated to be in the range of 5 in 10 million (5
x 10-7) to 7 in 100,000 (7 x 10-5). Only two locations exceeded a
risk of 1 x 10-5 due to arsenic contamination.
"
A risk assessment was not conducted for lead, which is considered
to be a probable carcinogen, because a risk-based calculation
method for lead has not yet been established by EPA. .
Concentrations of lead were found at three locations exceeding
the state of Washington's cleanup standards of 1,000 mg/kg which
is considered to be a protective level for industrial workers.
Because the.groundwater on Harbor Island is not currently used
for drinking water, and is not anticipated to be used for
drinking water in the future, a human health risk assessment for
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ingestion of groundwater was not ~onducted. However, if
contaminated groundwater was to enter the adjacent Duwamish River
and Elliott Bay in significant concentrations, it could adversely
effect marine organisms or pose a th~eat to individuals consuming
these organisms. Contaminants in groundwater at the Lockheed
shipyard which pose a potential risk to marine organisms or human
health include benzene, PCE, copper, lead and zinc.
uncertainty
The accuracy of the risk estimates depends in large part on the
accuracy of the sampling data, exposure assumptions, and t~xicity
criteria. Most assumptions used in determining exposure to and
toxicity of hazardous substances are intentionally conservative,
resulting in a risk estimate which likely is greater than the
actual risk present at the Site.
. Uncertainties in sampling data directly influence the final. risk .
'calculations. A variability of minus 50 to plus 100% is typical
for samples containing analytes at concentrations less than the
contract-required quantitation limit. For samples containing
higher concentrations of analytes, relative percent differences
of 35% for soil are considered acceptable.
,:1\
The estimated exposure dose for each exposure scenario and age
class are standard values used in EPA risk asSessment based on
results ~f controlled studies conducted outside the scope of this
risk assessment. The standard values are intended to be .
conservative because accurate s.ite-specific data on' exposure dose'.
is not available.
The method for determining toxicity values is also intended to be
conservative. Several conservative uncertainty factors are used
in the development of toxicity criteria for carcinogens and
noncarcinogens. For example, cancer slope factors for carcinogens
and reference doses (RfDs) for noncarcinogens are often derived
from animal studies with an additional safety factor added for
extrapolating toxicity to humans.
. Environmental Evaluation
As the first step in the environmental evaluation, a habitat and
ecoloqical community evaluation was performed. The results of the
habitat evaluation showed that Harbor Island consists of an
industrial matrix with a number of small and disconnected
undeveloped patches of land. Due to the industrial development
on the island, these patches do not appear sufficient in size or
quality to sustain a wildlife population or support a functioning
ecological community. The evaluation of potential ecological
receptors indicated that only those species (i.e., rats, dogs,
crows,' a:'1d gulls) ...ssociate':' with \4rban areas would be expected
to temporarily reside on Harbor Island. A field investigation as
well as interviews were unable to verify the presence of any
mammals on Harbor Island. The lack of suitable habitat and
ecological receptors precluded the necessity for further'
environmental evaluation. .
o
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Petr:oleum in soil at the Lockheed shipyard is a potential risk to
the marine environment since petroleum may leach from the soil
into the groundwater and then migrate to the adjacent surface
water. Based on the state of Washington's guidelines for
petroleum contaminated soil, it was determined in the Harbor
Island Record of Decision that petroleum concentrations below 6JO
mg/kg would be protective of the environment. Petroleum was
found to exceed this protective level in seven areas at the.
Lockheed s~lipyard unit.
B. REMEDIAL ACTION OBJECTIVES
Actual Qr threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial. endangerment to public health, welfare
or the environment. The remedial action objectives (RAOs), and
their associated numerical cleanup goals, are intended to protect
human health and the environment by reducing risks to acceptable
levels. RAOs are based on the results of the above risk
assessment and on existing state and federal standards, which are
applicable or relevant and appropriate requirements (ARARs).
For Harbor Island, including the Lockheed facility, the primary
soil ARARs are the standards contained in MTCA and its
implementing regulations. Compared to subsurface soil, surface
soil presents a greater risk to human health because of' the """
potential: for more frequent exposure through direct contact or
ingestion. Therefore, cleanup goals for the surface are more
stringent and wer2 based on a risk c,.lculation specified by MTCA.
The RAOs and cleanup goals for the Lockheed facility operable
unit are shown in Table 1.
The cleanup goal for carcinogens in surface soil is to achieve a
total cancer risk from all carcinogens of less than one in
100,000 (10-5) for an industrial exposure. The cleanup goal for
noncarcinogens in surface soil is to achieve contaminant
concentrations with a hazard index of less than 1~0 (one). A
hazard index of less than 1.0 means 'contaminant concentrations
are not expected to pose an adverse health effect. The cl~anup
goal for lead, which is considered to be a probable carcinogen, .
is the MTCA numerical standard for an industrial exposure because
a risk-based calculation method for lead has not yet been
determined by EPA.
"
For subsurface soil, since human contact will be limited to
infrequent excavations of limited duration, MTCA numerical
standards for an industrial exposure were selected. The goal of"
these numerical standards is to achieve a risk from individual
carcinogens of less than 1 in 100,000 (10-5), and a hazard index
from individual noncarcinogens of less that 1.0. The MTCA
numerical standards selected for some of the contaminants in the
subsurface are also designed to protect groundwater quality. "
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Table 1- Remedial Action Objectives and Cleanup Goals for Lockheed
Medium Primary Receptors Remedial Action Objective Cleanup GoaIsa
Soil-Surface Humans Piotect human health from lead: 1.000 mg/kgb
exposure 10 contaminants in Arsenic: 3.60 to 32.6 mg/kgC
surface eoil which pose a Carcinogenic PAHs: 0.1 to 36.5
combined risk of greator than 1 x rng/kgC
10-5. -
Soil-Subsurface Humans and Protect human health from 18ad: 1.000 mg/kgb
Environment infrequent exposure to TPH (diesel): 600 mg/kgd
contaminants in the subsurface PAHs (carcinogenic): 20 mg/kgb
which pose a risk greater than Arsenic: 200 mg/kgb
10-5 for each contaminant. Benzene: 1.0 mg/kgd
Prevent release of contaminants Ethylbenzene: 200 mg/kgd
into the groundwater where they Toluene: 100 rng/kgd
can be 1ransported 10 the Xylenes: 150 mg/kgd
. shoreline. where marine organisms
could be exposed.
Ground_ter Environment Prewnt migration of contaminants Benzene: 71 p,g/L e
to the shoreline where marine Tetrachloroethylene: 8.8 p,g/l
organisms could be exposed. Copper: 2.9 p,g/L
Protect human health from 18ad: 5.8 /lg/L
consuming contaminated marine Zinc: 76.6 /lg/L
organisms which pose a risk
greater than 1 x 10-6
.
,.
a CI~anup goals were determined at various locations over the island and vary based on the
number and type 01 contaminants present.
b Goals are based on MTCA Method A lor soil at Industrial sites.'
C Based' upOn achieving a', x '0-5 .excess cancer riSk or Hazard Index equal to ,.
. d Bas~d o~'1he State 01 Washington Petroleum-Contaminated Soil Matrix Rating mcrt,od.
e All groundwater levels are based on protection of marine organisms'" human health from
COftSUl':"ption of org;:nisms.
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The Lockheed RI data indicate that soil cleanup goals were
exceeded in seven areas for one or more contaminants including
arsenic, lead, and petroleum (Figure 3). The total volume of
soi! which exceeds cleanup goals, associated with these seven
ar~as, is estimated to be 38,000 cubic yards. For sandblasting
grit located on the facility, eight samples exceeded the cleanup
goal for arsenic and two samples exceeded the cleanup goals for
lead. The a~proximate volume of sand~lasting grit on the facility
is estimated to be about 1,120 cubic yards.
In addition to the cleanup goal for petroleum of 600 mg/kg, a
petroleum "treatment level" of 10,000 mg/kg also applies to the
Lockheed facility. This treatment level was identified in the
Harbor Island soil and groundwater operable unit Record of
Decision and was determined through a cost-benefit analysis (see
. Appendix B) which included the Lockheed soil data. This
treatment level is considered to be the level above which
treatment of petroleum is preferred because it would provide
additional protection to the environment in a cost effective
manner. Petroleum exceeded this treatment level in four areas
(Figure 4), and the approximate volume of soil exceeding the
treatment level is 4,800 cubic yards. Areas exceeding this
treatment level are also referred to as "hot spots".
Groundwater
EPA and Ecology nave determined that .the federal and state
" drinking water standards do not apply to groundwater at Harbor"
Island. These drinking water standards are not relevant and
appropriate to Harbor Island because: 1) there is no current or
foreseeable use of groundwater for drinking water purposes, 2)
the entire island is serviced by the city of Seattle water
. ~ystem, and 3) the surface water standards for the protection of
marine organisms, and protection of human health from consumption
of marine organisms, will be the cleanup goals for contaminants
which reach the shoreline.
Several contaminants in the groundwater have. the potential to
eventually. exceed the surface water standards including: copper,
lead, zinc, benzene and PCE. However, none of these contaminants
currently exceed the cleanup goals in the groundwater at the
shoreline. Based on a computer model, which determines the
transport of contaminants in groundwater, it is predicted that
none of the groundwater contaminants are expected to reach the
shoreline at concentrations exceeding cleanup goals in less than
50 years. In applying this computer model to the Lockheed
facility, it was conservatively assumed that no remedial actions
were taken. .. .
Q
-------
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I. DESCRIPTION OF REMEDIAL ALTF""~AT~VES .
Soil Alternatives
"
Soil cleanup alternatives fall into five general categories:
o No Action (Alternative 1)
o Institutional Controls (Alternative 2)
o Co~tainment (Alternative 3)
o Tr",,:atment of All Soil above Cle 'nup Goals (Alternatives 4-6)
o Treatment of Hot spot Soil/Containment (Alternatives 7-8)
The estimated time to complete the following alternatives
includes activities from the beginning of the remedial design to
completion of the remedial action. It does not include an
additional 6-9 months typically required to finalize an agreement
between EPA and the Potentially Responsible Parties to perform
the work. Cost estimates for ea~h aiternative are given in
present value (1994) dollars.
Alternative 1: No Action
The "No Action" alternative provides a baseline for comparative
evaluation of other alternatives. Under Superfund, the "No
Action" alternative is used to establish the risk levels and site
conditions if no remedial actions are implemented. Site
conditions and risk levels would remain as they currently exist.
. No changes or restrictions would be made that would affect
.. activities at the site. This alternative has no treatment or
containment components. Land development, site maintenance, and
site improvement would continue in accordance with prevailing
practices.
Since this alternative does not require any remedial action,
there' are no ARARs which apply to it.
Estimated Cost: None
Estimated Time to Complete: None
Aiternative 2: IDstitutional Controls
u
Institutional controls may be used to control future uses of the
property or limit access to the property. Employees working on
the property would be instructed on how to minimize po~ential
risks due to exposure to contaminated soil through informational
meetings or health advisories issued by the State Department of
Health. Institutional controls may also be used to establish
maintenance and monitoring requirements for the Lockheed
facility. Signs would be posted in key affected areas to warn
workers of the potential for exposure associated with excavatio~
c= disturbance of the soils. Deed rsstrictions could also be
recorded to advise potential buyers of the hazards and use
limitations associated with the property. Periodic environmental
monitoring and inspections would be required to verify the
. iveness of the institutional controls.
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This alternative would not include treatment or containment, and
existing potential exposure routes would remain. MTCA is an
ARAR which would apply to this alternative (see section L,
"Compliance with ARARs"). MTCA allows institutional controls to
meet cleanup goals, but it is not the preferred method.
Estimated Capital Cost: $30,000
Estimated Operating Cost: $50,000
Estimate' Time to Complete: 2 mont lS
.,
Alternative 3: Containment (Cappinq)
Contaminated areas exceeding cleanup goals would be capped to
prevent exposure of workers to contaminated soil. capping would.
also minimize the transport of the contaminants by rain water
runoff and infiltration. A cap would be installed in areas where
soil contaminant levels exceed cleanup goals. Existing pavement
would also be. inspected and areas with cracks or heavily worn
pavement would be repaired or r~placed. Existing asphalt needing
replacement, would be disposed at an off-site facility.
Approximately 2,000 square yards of area on ~he Lockheed facility
would require capping under this alternative.
The cap design and the specific material used would be based upon
the use of the capped area. Typically, this cap would consist of
a 3-inch asphaltic wearing surface overlaying a base course of
well-graded crushed rock, although in certain areas a reinforced
concrete cap may be required to support heavy loads. A sealant
would be applied to the asphalt surface following installation.
Cap inspections and minor repairs based on those inspections
would be made annually. It is ".~tic.~pated that weather- and
traffic~induced degradation of the asphalt surface would occur
and the surface would need substantial surficial repair
approximately every 10 years to maintain integrity of the seal.
The cost estimate for this alternative is based on a'30 year
maintenance period for the cap, and includes resurfacing 50
percent of the paved area every decade. .
This alternative does not contain a treatment component. MTCA is
the only regulation which is an ARAR for this alternative (see
Section L, "Compliance with ARARs"). This alternative would meet
this ARAR 'but would not satisfy the preference for treatment
identified in MTCA.
Estimated Capital Cost:
Estimated Operating Cost:
Estimated Time to Complete:
$400,000
$300,000
2 months
Alternative 4: Off-site Thermal Treatment and Disposal
. u
All soil exceeding organic and inorganic cleanup goals,
approximately 38,000 cubic yards, would be excavated and
transported by truck to appropriate off-site treatment
facilities. Excavated areas would be backfilled with clean fill
and capped with asphalt. Soil contaminated with organics
(petroleum) would be treated at a permitted off-Site thermal
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desorption facility. Soil containing inorganic contaminant
concentrations designated as dangerous waste, according to the
Washington State Dangerous ,Waste Regulations, would be taken to a
hazardous waste disposal facility for solidification and
disposal.
Thermal desorption is a process by which soil is heated to a
moderate temperature, typically 300 to 1,000 F, which vaporizes
the organi~ contaminants and removes them from the soil~ After
the organics are vaporized, they can either be condensed and
recovered in liquid form, or they can be oxidized in a
secondary chamber, called an afterburner, at temperatures above
1400 F. For this alternative and alternative 7, which specify
off-Site thermal treatment, the vaporized organics would be
oxidized in an afterburner. The Puget Sound Air Pollution Control
Agency (PSAPcA) has permitted several thermal desorption units in
the puget Sound area to treat petroleum contaminated soil in this
manner. For alternatives 6 and 8, which specify on-Site thermal
treatment, the vaporized organics would be recovered in liquid
form and not oxidized.
Thermal desorption has been proven to be very effective in
removing petroleum products from soil and it is believed that the
cleanup goals for petroleum contaminated soil at this Site can
easily be achieved. Treatment costs increase and efficiency of
thermal desorption decreases as the moisture or clay content of
soil increases. At the Lockheed shipyard, soil immediately above
the water table will have elevated moisture content and may need
. to be set a.side and allowed to drafnprio::,. to treatment. Clay.
content in the fill material at the Lockheed shipyard is low and
is not ant icipated to adversely impa ':::t thermal desorption
operations. .
Before starting excavation, a pre-remedial design investigation
and survey would be conducted to verify the horizontal and
vertical extent of contaminated soil~.. Several of the areas are
located in buildings and these buildings would need to be
modified or demolished to allow access for excavation. equipment.
Aspoalt and concrete would be cut and removed as necessary to .
expose affected soils. Demolition debris including materials
from buildings, asphalt, and concret~ would be transported to an
approved facility fQr disposal of those materials after removing
loose soil.
This alternative does not contain a containment component. MTCA,
and PSAPCA regulations are ARARs which apply to this alternative
(see Section L, "Compliance with ARARs"). This alternative would
comply with these AtRARs and satisfy the CERCLA and MTCA
preference for treatment. . .
Estimated capital Cost: $6,200,000
Estimated Operating Cost: None
Estimated Time to Complete: 4 months
o
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Alternative 5: On-site Bioremediation and solidification
All soil exceeding cleanup goals for organics and inorganics,
approximately 38,000 cubic yards, would be excavated and treated.
Soil contaminated with organics would be treated by on-site
bioremediation and soil contaminated with inorganics would be
solidified by mixing with cement. . . .
",
Bioremediai:ion, under proper condi ti (InS, has the potential to
degrade pe~roleum products to concentrations below the cleanup
goals. Treatability studies would need to be performed prior to
full-scale treatment to ensure that the proper operatinq
conditions are achieved. Nutrients would be periodically added to
stimulate biological activity and tilling equipment would be used
to thoroughly mix the soil in each treatment cell and to
introduce oxygen. Periodic sampling would be conducted to
.' ' monitor, progress and to adjust additives as necessary. When,
treatment goals had been reached, treated soils would be returned
to the original excavation, backfilled, compacted, and paved.
o
o
Soils with both organic and inorganic contaminants wou~d receive
biotreatment for organic contaminants, and then solidified to
decrease the mobility of the inorganics. Soils containing only
inorganic contaminants above the cieanup goals would be
solidified. An on-site area would be estab~ished where
contaminated soil would be solidified by mixing with cement and
then backfilled into the original excavation, compacted, and
,paved. Because of the volume increase due to additives during
solidification" it is' possible that some of the treated sjils'
would be disposed off-site for use as a structural backfill in
constructi(~n projects. '
This alternative does not contain a containment component. MTCA,
the Clean Air Act, the State Clean Air Act, and PSAPCA
regulations are ARARs which apply to this alternativ~ (see
Section L, "Compliance with ARARs"). This alternative would
comply with these ARARs and satisfy the CERCLA and MTCA
preferenc~ for treatment. '
Estimated Capital Cost: $4,600,000
Estimated operating Cost: None
Estimated Time to Complete: 24 months
Alternative 6: On-site The~al Treatment and Solidification
. 0
All soil above the organic and inorganic cleanup goals,
approximately 38,000 cubic yards, would be excavated and treated.
Petroleum contaminated soil would be treated by on-Site thermal
desorption and soil contaminated with inorganics would be '
solidified by mixing with cement. The thermal desorption un)~
would heat the petroleum contaminated soil indirectly (no direct
flame) at a moderate temperature and the organic vapors desorbed
from the soil would be condensed and collected in liquid form.
If not recyclable, this liquid would be sent off-Site to be
incinerated. Following treatment, the clean soil would be
returned to the original excavation and backfilled.
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Soils with both organic and inorganic contaminants would first be
treated by thermal desorption for organic contaminants, and then
solidified to decrease the mobility of the inorganics. Soils
containing only inorganic contaminants above the cleanup goals
would be solidified. An on-site area would be established where
contaminated soil would be solidified by mixing with cement and
then .backfilled into the original excavation, compacted, and
paved. Because of the volume increase due to additives during
solidification, it is possible that some of the treated soils
would be disposed off-Site for USE as a structural backfil' .~
construction projects.
This alternative does not contain a containment component. MTCA,
the Clean Air Act, the State Clean Air Act, and PSAPCA
regulations are ARARs which apply to this alternative (see
Section L, "compliance with ARARS"). This alternative would
comply with MTCA but would not comply with the remaining ARARs
unless the thermal desorption system is equipped with an .
afterburner (see section H, "Documentation of Significant
Differences").This alternative satisfies the CERCLA and MTCA
preference for treatment.
Estimated Capital Cost: $15,600,000
Estimated Operating Cost: Norie
Estimated Time to Complete: 6 months
Alternative 7: Off-site Thermal Treatment of TPB Bot Spots and
containment
Alternative 7 co~sists of exc~vating approximately 4,800 cubic
yards of soil contaminated with petroleum concentrations
exceeding the treatment level of 10,000 mg/kg. This soil would be
treated in an off-Site thermal desorption unit with an
afterburner similar to that described in Alternative 4.
Excavations would be backfilled with compacted clean fill and
paved with asphalt. All other soil areas which exceed the
petroleum cleanup goal of 600 mg/kg and exceed cleanup goals for
inorganics, would be capped in place to contain and r~duce the
. mobility of these contaminants. The condition of the existing
asphalt pavement would be inspected in areas exceeding cleanup
goals ar.d repairs would be lllade as required to reduce the
potential . for exposure to affected soils in these areas.
The asphalt cap would be inspected and repaired on an annual
basis and extensive repairs to the pavement would be required
every 10 years. The cost estimate for this alternative is based
on a 30 year maintenance period for the cap, and includes
resurfacing 50 percent of the paved area every decade.
MTCA and PSAPCA regulations are ARARs which apply to this
alternative (see Section L, "Compliance with ARARs"). This
alternative would comply with these ARARs and satisfy the CERCLA
and MTCA preference for treatment.
c
Estimated Capital Cost:
Estimated Operating Cost:
$1,000,000
$300,000
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Estim3ted Time to Complete: 4'~onths
Alternative 8: on-site Thermal Treatment of TPH Hot spots and
. Containment
~\l
Alternative.8 consists of excavating approximately 4,800 cubic
yards of soil contaminated with petroleum concentrations
exceeding the treatment level of 10,000 mgjkg. This soil would be
treated in an on-Site thermal desorp~ion unit with condensate
collect.;on similar to that described in Alternative 6.
Contaminated soil would be excavated, treated by thermal
desorption, backfilled into the original excavation, and paved.
All other soil areas which exceed the petroleum cleanup goal of
600 mgjkg and exceed cleanup goals for inorganics, would be
capped in place to contain and reduce the mobility of these
remaining contaminants. The condition of the existing asphalt
pavement would be inspected in areas exceeding cleanup goals and
repairs would be made as required to reduce the potential for
exposure to affected soils in these areas.
" .
The asphalt cap would be inspected and repaired on an annual
basis and extensive repairs to the pavement would be required
every 10 years. The cost estimate for this alternative is based
on a 30 year maintenance period for the cap, and includes
resurfacing 50 percent of the paved area every decade.
MTCA, the Clean Air Act, the state Clean Air Act, and PSAPCA
regulatio~sare ARARs which apply to this alternative {see'
Section L, "Compliance with ARARs").This alternative would
comply with MTCA but would not comply with the remaining ARARs
unless the thermal desorption system is equipped with an
afterburner (see section M, "Documentation of Significant
Differences"). This alternative satisfies the CERCLA and MTCA
preference for treatment.
Estimated Capital Cost: $2,600,000
Estimated Operating Cost: $300,000
Estimated Time to Complete.: 4 months
"Groundwater Alternatives'
Alternative 1: No Action
The "No Action" alternative provides a baseline for comparative
evaluation of other alternatives. Under the "No Action" .
alternative, site conditions and risk levels would remain as they
currently exist. No changes or restrictions would be made that
would affect activities at the Site. This alternative contains no
treatment or. containment components. .. .
. u
S~"ce this alternative does not requ~r~ any remedial action,
there are no ARARs which apply to it.
Estimated Cost: None
Estimated Time to Complete: None
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Alternative 2: Extraction and Off-Site Treatment
This alternative consists of extracting groundwater from affected
areas and discharging the water to METRO for off-site treatment.
Groundwater extraction would take place in three areas on the
Lockheed facility and approximately three to five extraction
wells would be used. The estimated total extraction rate is 50
gallons per minute (gpm). The extracted water would be routed to
a central tank which would discharge to METRO. The discharge
water wouli be sampled at regular in ervals as required DY METRO.
The pretreatment standards required by METRO have been reviewed
and it is anticipated that the extracted water would be
acceptable without any pretreatment. Groundwater extraction and
treatment would continue until the cleanup goals are met.
Groundwater quality would be monitored in and downgradient of the
contaminated areas to determine when the cleanup goals are
achieved..
The groundwater ARARs which apply to this alternative are listed
in Section L, "Compliance with ARARs". This alternative would
comply with all of these ARARs.
Estimated Capital Cost: $270,000
. Estimated Operating Cost: $1,600,000
Estimated Time to Complete: 10 years
Alternative 3: Extraction and on-site Treatment
This alternative ~onsists of extracting groundwater. from affected
areas, treating the water to permissible discharge levels in an
on-Site treatment plant, and discharaing the treated water to the
storm drain system. Groundwater extl:action would take place in
three affected groundwater areas on the Lockheed facility. The
estimated total extraction rate is 50 gallons per minute and the
water would be extracted from approximately three to five
extraction wells. The extracted water would be routed to a
central storage tank at the on-Site treatment plant. The on-site
treatment plant would consist of a reverse osmosis unit to. remove
metals and an air stripper to remove volatile o~ganics. .
Groundwater extraction and treatment would continue until the
cleanup goals are met. Gr~undwater ~uality would be monitored in
and downgradient of the contaminated areas to determine when the
cleanup goals are achieved. Long-term requirements for reverse
osmosis can be substantial, particularly if clogging of the
membrane occurs. In these cases, frequent system downtime may be
likely and operational expenses will rise proportionally.
The groundwater ARARs which apply to this alternative are listed
in Section L, "Compliance with ARARs". This alternative would
comply with all of these ARARs.
o
Estimated Capital Cost: $980,000
Estimated Operating Cost: $1,900,000
Estimated Time to Complete: 10 years
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Alternative 4: Groundwater Monitoring
.
Groundwater modeling indicates that under current conditions,
contaminants in the groundwater at the Lockheed facility will
take more than 50 years to reach the shoreline, which is the
point of compliance. This a~ternative would require groundwater
monitoring at wells located downgradient of areas where
groundwater contamination has been detected. The groundwater
data would be used to verify that gr')undwater contaminant
concentrat~ons will not exceed clear.lp goals at the shoreline in
the future. Selected downgradient wells would be monitored semi-
annually for 30 years or until it has been demonstrated that
cleanup goals will be achieved at the shoreline in the long-term.
Groundwater quality data from these wells would be reviewed at .
least every five years by EPA and Ecology to identify trends in
contaminant concentrations and distribution. If contaminants are
found to be migrating to the shoreline at concentrations .
exceeding the cleanup goals, additional source control actions or
groundwater treatment may be required at that time. The cost
estimate for this alternative is based on groundwater monitoring
for a period of 30 years. .
This alternative contains no treatment or containment components.
The groundwater ARARs which apply to this alternative are listed
in Section L, "Compliance with ARARs". This alternative currently.
comply with these ARARs, but additional remedial actions may be
necessary in the future if groundwater monitoring demonstrates
that contaminants in groundwater may reach the shoreline in
. concentrations exceeding the surface water standards.
Estimated Capital Cost: None
Estimated Operating Cost: $300,000
Estimated Time to Complete: 30 years
J. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
This section discusses the comparison of alternatives with.
respect to the nine statutory CERCLA evaluation criteria. The
first two criteria~ "Protection of Human Health and the
Environment" and "Compliance with ARARs", are threshold criteria.
Protection of Human Health and the Environment
soil Alternatives
Alternatives 4, 5, and 6 have the highest overall protectiveness
of human health and the environment because all soil with
. contaminant concentrations above the cleanup goals' will receive
treatment under these alternatives. .. .
"
Alternatives 7 and 8 rank lower beca~se only the petroleum hot
spot soil would be treated and the remaining soil with
concentrations above the cleanup g9als would be capped.
Alternat~ve 3 ranks next because it prevents direct exposure to
contaminated soil but may not prevent migration of petroleum from
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hot spot soil to the groundwater and to the adjacent surface
water where marine organisms may pe exposed.
Alternative 2 ranks lower because direct exposure to contaminated
soil is controlled but not eliminated and migration of petroleum
from hot spot soil to groundwater is not eliminated. Alternative
1 has the lowest overall ~rotectiveness of the eight alternatives
because this alternative has highest potential for human and
environmental exposure to contaminants remaining on site.
Groundwater Alternatives
Alternatives 2 and 3 provide the best protection to the
environment because they require treatment of all groundwater
which exceeds the cleanup goals. Alternative 4 ranks slightly
lower because it does not provide for treatment of contaminated
groundwater. However, groundwater monitoring'would be used to
verify modeling predictions that contaminated groundwater will
,not reach t~e shoreline. If modeling prediction~ prove to be
inaccurate, the monitoring will enable the regulatory agencies to
take the necessary protective measures before environmental
damage occurs. Alternative 1 ranks lowest because it provides no
protection to the environment.
Compliance with Applicable or Relevant and Appropriate
Regulations (ARARs);
soil Alternatives ,
Alternatives ~,3,4,5 and 7 comply with all soil and air ARARs
listed in Section L, "Compliance with ARARS". . Alternatives 6 and
8 meet soil ARARs but would not comply with air ARARs unless the
thermal desorption system is equipped with an afterburner. This
issue is addressed in the description of the selected remedy and
in Section M, "Documentation of Significant Differences". '
Alternative I does not meet ARARs because it does not include any
action to address soil contamination above the cleanup goals.
Groundwater Alternatives
All the groundwater alternatives currently comply with
groundwater ARARs because contaminants are not currently at the
shoreline above the cleanup goals. However, the groundwater'
alternatives can be ranked on the ba~is of their ability to
continue to meet ARARs in the future. In this regard,
alternatives 2 and 3 rank highest because they require immediate
extraction and treatment of contaminated groundwater and would
provide the greatest assurance that cleanup goals would not be
exceeded at'the shoreline in the future. Alternative 4 ranks
slightly lower because it assures that ARARs will be achieved in
the future by monitoring groundwater quality and allowing for'
additional remedial act~ons if necessary to meet ARARs. '
Alternative I ranks lowest because it would provide no assurance
that ARARs \'rould be achieved in the f'lture.
o
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Long-Term Effectiveness and Permanence
""
Soil Alternatives
Alternative 4 has the greatest long-term effectiveness because it
permanen~ly destroys or removes all contamination exceeding the
cleanup goals and requires no long-term maintenance or controls.
Alternatives 5 and 6 have slightly less long-term effectiveness
than Alternative 4 because the long-term effectiveness of on-Site
stabilj~atior. of inorganic conta~inants is uncertain relative r'
off-sit.~ treatment and disposal. -
Alternatives 7 and 8 are next best for long-term effectiveness
because the petroleum hot spot soil is removed and treated but
long-term maintenance of capped areas will also be required.
Because all contaminated soil remains in place, alternative 3 .
ranks lower because it requires long-term maintenance of capped
areas to be effective. Alternatives 1 and 2 rank lowest because
they do not provide permanent protection of human health or the
environment. .
Groundwater Alternatives
Alternatives 2 and 3 rank highest for this criterion because they
require extraction and treatm~nt 'of contaminated groundwater and'
have a greater potential for long-term effectiveness and
permanence for groundwater contamination. Alternative 4 ranks
next because even though it does not include treatment, it would
include monitoring. which could trigger additional soil or
groundwater treatment. if it appears that cleanup goals are not
being achieved. Alternative 1 does not' include any groundwater
treatment or monitoring, and. therefore, has the lowest potential
for long-term effectiveness and J:~rmanence.
Reduction of Toxicity, MObility, or Volume. Through Treatment
soil 'Alternatives
Alternatives 4, 5, and 0 perform better than the other
alternatives under this criterion because they reduce toxicity,
mobility or volume through treatment for all contaminated. soil
above the cleanup goals. Alternatives 7 and 8 rank slightly.
lower because only the vcJ.nme and toxicity of petroleum hot spot
soil would be reduced through treatment in these alternatives.
Alternatives 1, 2, and 3 do not include a treatment component,
and therefore do not offer any reduction in toxicity, volume, or
mobility of contaminants through treatment. .
Groundwater Alternatives
Alternatives 2 and 3 include treatment to reduce toxicity and
volume of contaminated groundwater and are ranked high~r under
this criterion~ Alternatives 1 and 4 rank lower because t~ey do
not include treatment.
u
Short-Term Effectiveness
Soil Alternatives
Alternative 3 ranks highest in short-term effectiveness because
it addresses contaminants in the shortest period of time and
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becausp. capping causes minimal acditional short term risk to
workers and environment during remedial activities. Alternatives
7 and 8 rank next because they require excavation and handling of
a relatively small volume of soil. 'Alternatives 4 and 6 rank
lower under this criterion because they require excavation and
handling of a largp.r volume or contaminated soil and allow human
exposure to this excavated soil over a longer period of time.
Alternative 5 ranks next because of potential exposure during
excavation as well as potontial f~r additional exposure, during
the landfarming ac-+:i~!it1.es. Alte ~natives 1 and 2 do not provide
any protection to human health or the environment in the short-
term.
Groundwater Alternatives
Alternatives 2, 3, and 4 have good short effectiveness because
they present minimal exposure to humans during implementation and
ensure good protection to the environment in the short-term.
Alternative 1 ranks lowest because it does not include either
groundwater treatment or monitoring, and therefore does not
ensure protection to the environment in the short-term.
Implementability
Soil Alternatives
Alternative 1 ranks highest under this criterion because there is
nothing to implement. Alternative 2 ranks second because this
alternative involves specifying a set ,of procedures and does not
' involve any construction acti vi ties. Al ternati ve 3' ranks next,
becau'se, of all the alternatives involving construction
activities, it is the only one that does not entail any
excavation or treatment.
Alternatives 7 and 8 rank lower under this criterion because they
require excavation of a relatively small volume of soil.
Alternative 4 is next because it requires excavation of a larger
volume of contaminated soil. Alternative 6 ranks lower because
on-Site stabilization is a component of this alternative, which
would ~equire additional planning and oversight. Alternative 5 '
ranks lowest because both bioremediation and' stabilization
treatment techniques 'add to the planning and time required for
implementation.
Groundwater Alternatives
Alternatives 1 and 4 rank highest under this criterion because
there are no technical or administrative difficulties associated
with implementing them. Alternative 2 ranks next because there
may be difficulties in getting METRO to accept the contaminated
groundwater water without pretreatment. Alternative '3 ranks
lowest for this criterion because it may be technologically
difficult to consjstently treat groundwater to NPDES discharge
requiremsmts.
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Cost
,
Soil Alternatives
Alternative 1 has the lowest estimated overall cost (zero),
followed by Alternative 2 ($80,000) and Alternative 3 ($700,000).
Alternatives 7 has the next lowest cost at $1.3 million and
alternative 8 is next at $2.9 million: these alternatives are
moderate in cost relative to alternatives 4-6 which involve
excavatin~ and treating all contamir1ted soil. Alternat~ve 5
($4.6 mill,ion) is the least costly 2.ternative among this group
of alternatives. Alternative 4 is next at an estimated cost of
$6.2 million and alternative 6 ranks lowest with an estimated
cost of $15.6 million.
Groundwater Alternatives,
'Alternative 1 has the lowest estimated overall cost (zero),
£ollowed by Alternative ,4 ($300,OOO), Alternative 2 ($1.9
million), and Alternative 3 ($2.9 million). Alternative 3 has
the largest operation and maintenance costs because it requires
on-Site treatment over a 10-year duration.
state Acceptance
Ecology concurs with EPA's selected remedy, which is identified
below.
community Acceptance
The community generally supported the preferred alternative. The
most significant comments received during the public comment
period raised concern about the ther~1al desorption system which
was identified as the treatment technology in the preferred
alternative of the Proposed Plan. EPA has addressed this concern
by selecting thermal desorption with an afterburner, instead of
condensate collection, because an afterburner 'more efficiently
controls the emissions of volatile gases. A complete summary of
comments received and EPA's responses are provided in the
attached Responsiveness Summary.
K. THE SELECTED REMEDY
v
Major Components of the Selected Remedy
Based on CERCLA, the NCP, the Administrative Record, the
comparative analysis of the alternatives, and public comment, EPA
has decided to select a remedy for the Lockheed facility operable
unit which is a modified version of alternative 8 (On-Site
Thermal Desorption and Containment) combined with groundwater
alternative 4 (Monitoring). The modification to alternative 8 is
that the thermal desorption system must be equipped with an
afterburner instead of a condensate collector. This modification
is preferable because, after further evaluating the performance
of condensate collection technology, EPA has determined that
condensate collection does not meet ARARs which establish air
standards for emissions of volatile organic compounds (see
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Section M, "Documentation of Significant Differences").
Specifically, the selected remedy in~ludes the following
components:
1) Excavate and treat soil containing the highest levels of
petroleum contamination ("~o"i:. spots"). The petroleum hot spots
are defined as those areas with concentrations of Total
Petroleum Hydrocarbons (TPH) greater than 10,000 mg/kg. The TPH
hot spot soil will be treated on-s~te by a thermal desorption
system e'.ruipped with an afterburne', instead of a condensate
collector as identified in the preferred alternative of the
Proposed Plan. .
u'
2) Contain exposed contaminated soil exceeding inorganic and
organic cleanup goals. Containment would be achieved with a
three inch asphalt cap designed to reduce infiltration of
rainwater and reduce contaminant .migration into the
environment. Existing asphalt and concrete surfaces which are
damaged in areas exceeding cleanup goals would either be
replaced or repaired. Maintenance of new and existing caps
would also be required under a Consent Decree for the settling
PRPs as long they own the Lockheed facility.
3) Invoke institutional controls which would warn future
property owners of remaining contamination contained under
capped areas on this property, require future owners and
operators to maintain these caps, and specify procedures for
handling and disposal of excavated contaminated soil from
beneath the capped areas if excavation. is necessary in the
future.
4) Moni'Cor groundwater quality sellti-annual1y for 30 years, or
until it has been demonstrated that groundwater contaminants
will not reach the shoreline in concentrations exceeding
cleanup goals. The groundwater quality data will be reviewed at
a minimum of every five years to assess the effectiveness of
the selected remedy to meet water quality cleanup goals at the
shoreline~This periodic. data review will be conducted by EPA
. and Ecology and will coincide w~th the groundwater data review
'for the'soil ahd groundwater operable unit. If groundwater data
indicatEs that contaminants are likely to exceed cleanup goals
at the shoreline, additional soi1 and/or groundwater remedial
actions may be required in the future.
The performance requirements for the thermal desorption system
are: 1) greater than 99% destruction efficiency for volatiles, 2)
particulate emissions from the exhaust stack cannot exceed 0.02
grains/dry standard cubic feet, 3) the afterburner must operate
at a minimum temperature of 1400° F, and 4) opacity from the
exhaust stack cannot exceed 5% for three minutes in any hour of
operation. In addition to these performance requirements, EPA
will require that dust collected in the baghouse be tested for
TPH to determine if it meets cleanup goals before being mixed
with treated soil and replaced in the ground.
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The selected remedy will also require that all sandblasting grit.
in the shipways be consolidated and capped in place with a
minimum three inch asphal~ cap. containment of this sandblasting
grit is necessary because it exceeds cleanup goals for arsenic
and lead and because it may act as a source of contamination to
tLa nearby marine sediments.
.
EPA believes that the selected remedy best satisfies the nine
evaluation criteria. It is protectiv' of human health by
preventing direct contact with contaJ.linated soil, protective of
the environment by preventing discharge of contaminants to
surface water by runoff, and migration of contaminants to the
groundwater. It has good short- and long-term effectiveness, is
technically and administratively relatively easy to implement,
and achieves. the above objectives more cost effectively than any
other alternative. The selected remedy is also consistent with
the remedy selected in the Record of Decision for the Harbor
I.sland soil and groundwater operable unit.
Basis for Remediation Goals
soil
For Harbor Island, including the Lockheed facility, the primary
soil ARARs are the standards contained in MTCA and its
implementing,regulations. Compared to subsurface soil, surface
soil presents a greater risk to human health because of the
potential for more frequent exposure through direct contact or
'ingestion.' Therefore, cleanup goal's for ,the surface are more
stringent and were based on a risk calculation specified by MTCA
(see Table 1).
The objective for surface cleanup goals for carcinogens is to
achieve a total cancer risk from all carcinogens of less than one
in 100,000 (10-5). Principle carcinogens of concern at the
Lockheed facility include PAHs and arsenic. Cleanup goals for
noncarcinogens in the surface are also based upon the combined
risk from all contaminants at each location. The cleanup goal
for noncarcinogens was to ,achieve contaminant concentrations with
a hazard index of less than 1.0 (one'. A hazard index of less
than 1.0 means contaminant concentrations will not pose an
adverse health effect. The cleanup goal for lead, which is
considered to be a probable carcinogen, is the MTCA numerical
standard for an industrial exposure because a risk-based
calculation method for lead has not yet been established by EPA.
o
For subsurface soil, since human contact will be limited to
infrequent excavations of limited duration, MTCA numerical, . ,
, standards for an industrial exPosure were selected. The goal of
these numerical standards is to achieve a risk from individual
carcinogens of less than 1 in 100,000 (10-5). The MTCA numerical
standards selected for some of the contaminants in the subsurface
are also designed to protect groundwater quality.
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Groundwater
EPA and Ecology have determined that the federal and state
drinking water standards do not apply to groundwater at Harbor
Island. These drinking water standards are not relevant and
appropriate to Harbor Island because: 1) there is no current or
foreseeable use of groundwater for drinking water purposes, and
2) the entire island is serviced by the city of Seattle water
system. Instead the surface water qu~lity standards for the
protection of marine organisms, and protection of human-health
from consumption of marine organisms, will apply at the
shoreline.
Groundwater contaminant transport modeling conducted indicates
that none of the contaminants .in the groundwater at the Lockheed
facility will exceed surface water quality standards at the
shoreline within the.next 50 years.
Protection of the Environment During Remedial Action
Engineering controls will be implemented to mitigate the impact
on the environment. During excavation, run-on/runoff controls
will be installed to keep soil from being transported into the
island storm sewer system and ultimately to Elliott Bay.
Contaminated soil in excavation areas will be covered in
inclement weather to minimize contaminated runoff. The treatment
area will also be provided with run-on/runoff controls to
minimize contaminant transport. soil stockpiles in t~e treatment
facility area will be covered with a rain shelter to prev~nt .
contaminated runoff.. .
Decontamination pads will be installed to clean equipment and
minimize the spread of contamination to other areas of the Site.
Transport trucks will be covered as needed to prevent loss during
transport. .
Contaminated liquid storage tanks and storage facilities will be
provided \/ith double containment to prevent leaks from entering
the environment. Routine inspections of facilities will be
performed to assure safety measures are in place and functioning
properly. Discharges to the environment will meet. applicable
state and federal regulations.
Cost and Remediation Time Frame
The cost estimates prepared in the Feasibility Study for each
alternative are intended to be within a range of -30% to +50% of
actual costs. The net present value (cost in 1994 dollars) of the
selected soil remedy (modified alternative 8) is' approximately
$1,300,000. The cost for the selected groundwater remedy
(alternative 4) is approximately $300,000. Details of the cost
estimates for modified soil alternative 8 and groundwater
alternative 4 are shown in Tables 2, and 3, respectively. It is
anticipated that the soil remedial design and remedial action
component will tak.e approximately 9-12 months to complete and the
groundwater monitoring component will take 10-30 years to
"
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complet~, depending on groundwater- quality results. The cost
estimate for groundwater monitori~g is based on a 30 year
monitoring period.
L. STATUTORY DETERMINATIONS
The selected remedy for the Lockheed facility will comply with
CERCLA s~ction 121 as foll~ws:
"
Overall Protection of Ruman Health and the Environment
Long term protection of human health is obtained by removal and
treatment of soil hot spots containing TPH and by capping of all
the remaining soil above cleanup goals. These actions give a
reduction in contaminant toxicity, mobility, and volume.
, Following implementation of the remedy, the overall risk to human
health from potential exposure to contaminated soil will be less
than the cleanup goal of 1 x 10-5. Long term protection of the
surface water quality will ultimately be achieved through the
treatment of the petroleum hot spot soil, capping of the
remaining contaminated areas, long-term maintenance of these
caps, monitoririg groundwater quality, and natural attenuation of
remaining organics in the soil and 'groundwater.
Protection of human health during remediation will be obtained
through compliance with OSHA and WISHE requirements, the use of
, personnel'protective equipment, and other safety measures and
eng'ineering cortro1s. Protection 'of the environment will be '
obtained during remediation by covering stockpiles and using
berms and ditches around excavations to control contaminated
runoff. In addition, the ,environment will be protected from air
pollution through compliance with the substantive requirement of
PSAPCA. Long term monitoring and maintenance will be required
for the selected remedy. The asphalt caps will require annual
inspection and repair as necessary. The groundwater quality will
be monitored semi-annually until it has been demonstrated that
groundwater contaminants will not reach the shoreline in
concentrations exceeding cleanup goals. Periodic five-year,
reviews of the groundwater quality trends will be conducted to
determine if additional source control or groundwater treatment
actions are required to achieve surface water cleanup goals at
the shoreline.
compliance with ARARs
u
The selected alternative will meet all chemical-specific and
action-specific applicable ARARs for the Lockheed facility, which
are described below. No location-specific ARARs have been'
identified for the Lockheed facility.
ARARsfor Air
Clean Air Act (42 U.S.C. IS 7401 et seq.); Washington state clean
Air Act (RCW 70.94; WAC 173-400, -460)
-------
TABLE 2
COST ESTIMATE FOR ALTcr1NAT,VE GW4 (GROUNDWATER MONITORING)
TOTAL COSTS Unit Quantity Unit Cost Cost
1) GROUNDWATER MONITORING
Sampl.; Wells. Annual 30 $3,500.00 $43.432
laboratory Analyses. Annual 30 $5,500.00 $68,250
Reporting. Annual 30 $6,000.00 $ 74,454
Reviews.. 5-Years 6 $20,000.00 $43,154
SUBTOTAL (DIRECT COSTS)
Work Plan Development
Contingency Allowance (25% of Direct Costs)
TOTAL CAPITAL COSTS
$229,289
$25,000
$57,322
$311,611
TOTAL PRESENT-WORTH COST
$311,611 f
. Present value calculated using PIA = 12.409 (i = 7%. N = 30 years)
.. Present value calculated using f'/F = ~. 1577 (total) Ii ~ 7%. reviews at 5,10.15.20.25 & 30 years)
lOCl
-------
TABLE 3
COST ESTIMATE FOR AL TERNA TI'IE S8 (ONSITE THERMAL DESORPTION OF
HOT SPOTS)
Unit Quantity Unit Cost Cost
lS 1 $ 1 0,000.00 $ 1 0,000
IF 1,000 $ 1 2.00 $ 1 2,000
DAY 4 $800.00 - $3,200
lS 1 $ 1 0,000.00 $10,000
lS 1 $1,500.00 $1,500
"
CAPITAL COSTS
11 GENERAL
Site Mobilization
Temporary Fencing
Site ~ rvey/Layout
Deed Restriction
Install Signs
21 HEALTH & SAFETY
Decon Equipment
Health & Safety Expendibles
(6 persons X $25/daYI,
Rinsate Disposal
Laboratory Analyses
Photoionization Detector
lS 1
DAY 90
GALLON 9,000
EACH 150
MONTH 3
sa YD 1,800
CU YO 300
CU YO 4,800
LF 300
CU YO 4,800
CUYO, 1,100
CU YO 4,800
SQ vo 1,800
sa YO 3,000
31 SOil REMOVAL ACTIONS
Remove ConCrete/Asphalt
Dispose of Concrete/Asphalt
Excavate Soil
Shore Excavations
ThermallvDesorb TPH Soils
Import Clean Gravel
Backfill and Compact
Install Asphalt (Excavations)
Install Asphalt (Other'
SUBTOTAL (DIRECT CAPITAL COSTS)
Work Plan Development
Engineering Design
Construction Oversight
Contingency Allowance (25%"of Direct Capital Costs)
TOTAL CAPITAL COSTS
$5,000.00
$150.00
$0.77 '
$350.00
s600.00
$6.40
$98.00
$5.00
$40.00
$73.00
$ 12.00
$4.00
$ 15.00
$ 1 5.00
$5,000
$13,500
$6,930
$52,500
$1,800
$11,520
$29,400
$24,000
$12,000
$~50,400 .
$13,200
$19,200
$27,000
$45,000
$648,150
$75,000
$100,000
$40,000
$ 1 62.038
$1,025.188
OPERATION &'MAINTENANCE COSTS
Site Inspections.
Cap Maintenance.
Partial Cap Replacement. .
unit
Annual
Annual
10 Years
Quantity
30
30
3,
SUBTOTAL (DIRECT O&M COSTS)
Administrative Costs (15% Direct O&M Costs)
Contingency Allowance (25% Direct O&M Costs)
TOTAL :)PERATION & MAINTENANCE COSTS'
Unit Cost
$5.000.00
$6.000.00
$96.800.00
Cost
$62.045
$74.454
$86.936
$223.435
'$33,515
$55,859
$312.809
~
TOTAL PRESENT-WORTH COST
$1.337.997 II
. Pre8ent value calculated using PIA = 12.409 Ii = 7%. N = 30 years'
.. Pre80nt value calculated using i = 7% for replacements at 10. 20. and 30 years.
LOCKHEEDl412982C6OO1FS-AV1
-------
These acts require that remedial actions which would result in
major sources of emissions, su~h as soil or groundwater
treatment, will be designed to meet federal and state ambient air
quality standards.
Puget Sound Air Pollution Cr~trol Authority (Regulations I, III)
These regulations require that remedial actions which could
involve releases of contaminants to ~ir will be performed in
compliance with substantive requirem,nts of a permit from PSAPCA.
These regulations are applicable to all alternatives which
require soil excavation and to all alternatives which specify on-
site thermal desorption treatment of soil.
ARARs for Groundwater and Surface Water
Washington Water Pollution Control Act (RCW 90.48); washington
state Water Quality standards for Surface Waters (WAC 173-201A)
These requires that surface water quality standards for
protection of marine organisms wil.! be achieved at the point of
compliance, which is at the shoreline. .
Model Toxics Control Act (RCW 70.105D; WAC 173-340)
MTCA (WAC 173-340-730) identifies cleanup standards for surface
water and the point of compliance for these standards, both of
which are applicable to the Lockheed operaQle unit.,.
Clean Water Act (33 U.S.C. ~~ 1251 et seq.; 40 C.F.R. Part 131)
These identify federal marine and fr~sh surface water standards
for protection of marine organisms and human health from
ingestion of marine organi~ms. Only the marine water standards
apply to Harbor Island and the Lockheed operable unit.
state Mini~um Standards for the Construction and Maintenance of
Wells (WAC 173-160)
This includes standards for construction, testing, and
abandonmenL of water and resource protection wells which may be
used during groundwater monitoring o~ groundwater treatment.
ARARs for Soil
Model Toxics Control Act (RCW 70.105D; WAC 173-340)
MTCAspecifies numerical cleanup goals for soil and risk based
calculati()n methods for determining cleanup goals in soil. MTCA
cleanup goals based on an industrial exposure scenario are
applicable ~o Harbor Island and the L.>ckheed operable unit.
-------
Cost Effectiveness
The selected remedy is cost effective because soil treatment by
thermal desorption, which is the most expensive component of the
remedy, is only required for petroleum hot spot soil, which has
the greatest potential to migrate to the surrounding environment. .
The remaining contaminants in the soil above the cleanup goals
are contained by an asphalt cap, which is an effective but
relatively inexpensive method of con'~ainment.
'0
utilization of Permanent Solutions and Resource Recovery
Technologies to the Maximum Extent Practical
The selected remedy represents the'maximum extent to which ..
permanent solutions and treatment technologies can be utilized in
a cost effective manner for remediation of soil and groundwater
at the Lockheed facility. The selected remedy provides the best
balance in terms. of long-term effectiveness and permanence,
reduction of toxicity, mobility. and volume achieved through
treatment, short-term effectiveness, implementability and cost,
while also considering the statutory preference for treatment as
a principle element and considering state and community
acceptance.
Treatment of the petroleum soil hot spots provides long-term
effectiveness and permanence apd provides a significant reduction
of toxicity, mobility and volume while minimizing short-term
risks. Containment of. less contaminated areas of the site also
reduces the mobility and provides long-term effectiveness, while
minimizing implementation difficulties and costs associated with
removal of large quantities of soil ,.hich may be difficult to
excavate.
Alternatives which treat all contaminated soil and groundwater
provide greater reduction in toxicity, mobility and volume and
. better long-term effectiveness, but may cause short-term risks to
workers associated with the. cleanup, and have high costs.
Alternati'\l.es which consist of little or no treatment are more
easily and quickly implementable and have lower costs, but.
provide little reduction in toxicity, mobility, or volume.
The selected alternative satisfies the two mandatory threshold
criteria, protection of human health and the environment, and
compliance with ARARs. The selected remedy uses a combination of
treatment, containment, and controls to achieve optimum
compliance with the five balancing criteria: long-term
effectiveness, short-term effectiveness, implementability,
. reduction in toxicity, mObility and vOlume,. and cost. Reduct.ion'
in toxicity and volume and cost effectiveness were the two
balancing criteria which influenced the selection of the rem~~y.
Preference for Treatment as a principal Element
The selected remedy requires treatment of petroleum. hot spot soil
by thermal desorption. The selected remedy meets the statutory
-------
preference for using treatment a~ a principal element of the
remedial action at the Lockheed facility.
M. DOCUMENTATION OF SIGNIFICANT DIFFERENCES
The remedy selected in this Record of Decision:. is the preferred
alternative in the Proposed Plan with one significant difference.
This difference is that the on-Sji:e thermal desorption system
will be- required to have an aftel )urner to destroy orgariL. . --~i?: .cs
instead of collecting these vapors by condensation. This
modification is preferable because EPA has determined that
condensate collection does not efficiently capture volatile
organic compounds and will not meet ARARs which establish air
standards for emissions of volatile organic compounds. The .
efficiency of collecting volatiles by condensate collection with
carbon adsorption generally falls in the range of 95-99%. This
range of collection efficiency would not meet PSAPCA's
requirement that thermal desorption systems achieve greater than
99% destruction efficiency for volatile organic compounds. The
destruction efficiency of thermal desorption with an afterburner
is approximately 99.99%, whiGh is two orders of magnitude higher
than PSAPCA's requirement.
.
To verify that there would not be any risks to human health or
the environment from direct and indirect exposure to the
emissions from the operation of a thermal desorption system with
an afterburner, EPA evaluated each potential exposure pathway.
Since there are no wetlands or wildlife habitats on. Harbor. .
Island, there would be no direct or indirect ecological exposures
on the island. Also, since the i~land is used exclusively for
industrial purposes and groundwater is not a drinking water
source, indirect human exposure through ingestion of milk, beef,
vegetable, or water does not apply. The only significant exposure
pathway is inhalation by workers operating the thermal desorption
system. To address this pathway, EPA estimated the potential
maximum worker exposure to petroleum .co~stituents which pose the
greatest health risks, benzene and PAHs (Appendix C).. This.
exposure estimate identifies concentrations of benzene and PAHs
at the stack exit, which is the point of maximum concentration
before air dispersion occurs. Based.on the assumptions used in
the estimate, the cpncentrations of petroleum constituents in the
stack air emissions would be about four order of magnitude below
the industrial threshold value limits (TLVs) established for.
benzene and PAHs. Therefore, the operation of a thermal
desorption system on Harbor Island will not present a health
hazard to workers.
. Thermal desorption with an afte.rburner. will also be more ct:)st-
effective to implement than thermal desorption with condensate
collection for type of soil contamination at the Lockheed
facility. The approximate cost for implementing modified soil
alternative 8 will be $1,300,000 instead of $2,900,000 as
identified in the preferred alternative of the Proposed Plan. At
this decreased cost, on-Site thermal desorption would now cost
about the same as off-Site thermal desorption (alternative 7) ,
-------
eliminating the need for off-si~~ tt.ermal desorption as a
contingency. This option was identified in the Proposed Plan as a
contingency if the Lockheed operable unit remedial action were to
occur sooner than the remedial action for the Harbor Island soil
and groundwater operable unit.
;
-------
""
APPENDIX
A
RESPONSIVENESS SUMMARY
-------
Appendix A
RESpONSIVENESS SUMMARY
FOR THE LOCKHEED RECORD OF DECISION
Overview
.
From 1903
sediments
been used
shipping,
transfer,
and metal
have been
Island is
$urfaces.
to 1905, Harbor Island was created from marine
dredged from the Duwamish River. Harbor Island has
for commercial and industrial activities including
railroad transportation, bulk fuel storage and
secondary lead smelting, lead fabrication, shipbuilding
.plating. Warehouses, laboratories and office buildings
located on the island. Approximately 70% of Harbor
covered with buildings, ro~ds or other impervious
The site was placed on the National Priorities List in 1983, due
to elevated lead concentrations in soil, as well as elevated
levels of other hazardous substances. The lead concentrations
were due to a lead smelter on the island, which ceased operations
in 1984. The Lockheed property is an 18.5 acre shipyard facility.
located on the western side of Harbor Island adjacent to the West
Waterway of the Duwamish River. This facility was identified as
an operable unit of the Harbor Island site in 1990. Lockheed
. conducted a Remedial Investigation ~nd Feasibility study on this'
. . f ac i 1 i ty under Consent Order to EPA. .' '.' .
In addition to the Lockheed facility there are three other
operable units on the Harbor Island site. These are: the marine
sediments, the soil and groundwater unit, and the petroleum
storage tank facilities. E.i?A has designated the Department of
Ecology as the lead agency for the petroleum storage.tank unit.
The soil and groundwater operable uni~ has a Record of Decision,
signed on September 30, 1993. The marine sediments Record of
Decision will be issued in 1995. .
On April 22, 1994, EPA began the public comment period on the
cleanup al~ernatives for the Lockheed facility on Harbor Island.
The proposed plan as.well as the Remedial Investigation and
Feasibility Study reports were released for public comment.
The proposed plan recommended Alternative 8 for soil which
includes excavation of petroleum hot spot soil and treatment by
on-site thermal desorption. The proposed plan also recommended
Alternative 4 for, groundwater which includes monitoring .
groundwater quality at the Lockheed facility for up to 30 years
to ensure that cleanup goals are not exceeded at the shoreline.
Background on community Involvement
As described above, the proposed plan for the cleanup of the
Lockheed facility was released on April 22, 1994. The public
comment period ran from April 22 until May 22, 1994. As part of
-------
the comment period, a public meeting was held on May 11, 1994.
About 15 people attended the meeting, no one gave public comment.
A copy of the transcript are available at the Region 10 Records
office in the Park Place Building, 1200 West 6th Avenue.
C~mments received in writing are included in the following
summary.
Comment: ~PA's Preferred Alternativ~, which includes off-Site
treatment .Jf petroleum hot spots, Sf mId allow the use of any
permitted, off-site thermal treatment unit, including the use of
a cement kiln which essentially recycles the TPH-impacted soil
into a usable product (cement).
Response: 'Off-Site thermal desorption was considered as a
contingency in the preferred alternative only if the Lockheed TPH
contaminated soil could not be combined with other TPH '
contamina~ed soil on'Harbor Island which will also be treated by
thermal desorption. Because EPAhas selected on-site thermal
desorption with an afterburner instead of condensate collection,
the cost for off-Site and on-Site thermal desorption are now
about the same for the Lockheed facility. Therefore, EPA has
eliminated the contingency for off-Site thermal desorption as
part of the selected remedy.
J'
Comment: Lockheed believes that EPA's selection of alternative,
8~ which was modified to use the future Harbor Island thermal
desorption unit with condensate recovery, is not based on the
Yard 1 Feasibility Study and Technical Memorandum, nor has it
been evaluated using the nine-criterta evaluation. The use of
condensate recovery as a component of low temperature thermal
desorption for treating TPH-impacted soil dramatically increases
treatment costs without providing offsetting benefits.
ResDonse: EPA believes that thermal desorption with condensate
recovery is adequately described in the Technical Memorandum to
the Feasibility Study and was the basis for alternative 8 in the
Proposed Plan. However, after further evaluating the performance
and cost of thermal desorption with condensate collection, EPA
has selectad thermal desorption with an afterburner, which more
efficiently controls the emission of volatile organic compounds
and is significantly lower in cost.
Comment: The puget Sound Air Pollution Control Agency (PSAPCA)
is concerned that the proposed preferred alternative (thermal
desorption with condensate collection) may not be in compliance
with PSAPCA regulations which specify that the best available'
,control technology for thermal desorption units is an afterburner
and a baghcuse which obtains greater than 99% destruction
efficiency for volatile organic compounds.
Response: EPA has selected thermal desorption with an
afterburner and baghouse as the remedial technology for the
Lockheed facility operable unit.
-------
'0
APPENDIX
B
METHOD FOR DETERMINING HOT SPOT TREATMENT LEVELS
-------
Appendix B
Method for Selecting Hot Spot Treatment Levels
.
I.
Method Used in the Feasibility study
The obj ecti ve of selecting hot spot treatment levels in the
Feasibility study was to identify areas containing high
concentrations of contaminants in relatively small volumes which
could be excavated ,and treated, providing an optimal cost-benefit.
' The benefit, in this context, is the total mass of contaminant
treated. 'The first step in the process was to identify the
contaminants presenting the greatest risk to human health and the
environment. This was accomplished by comparing contaminant
concentrations to the cleanup goals to determine which had the
highest exceedances. This process identified lead, mercury,
arsenic, TPH, and PCBs. Arsenic was eliminated at this point
because the distribution of its concentration showed that it was
widely distributed across the island at levels not significantly
above background, and was not highly concentrated in any particular
areas. PCBs were also elimianted from further evaluation because
.' EPA decided to set its treatment level at an existing regulatory
limit, which is' 50 mg/kg as defined by the federal Toxic Substance
Control Act (TSCA).
For TPH, lead, and mercury, the concentrations and soil volumes
associated with these concentrations were reviewed to identify the
approximate point at which the mass of contaminant started rapidly
decreasing as a function of increased soil volumes. The treatment
levels were selected at the contaminant concentrations where the
incremental amount of contaminant was disproportionate to the
incremental soil volume. The cost to treat these contaminants was
also analyzed semi-quantitatively to verify that the 'cleanup level
selected was also at the point. where the cost per mass of
contaminant treated started rapidly increasing.
. u
For example, treating all lead contaminated soil would result in
treating 5.9 x 106 cubic yards of soil to remove 4.4 x 106 pounds
of lead for an average of 0.75 pounds/cubic yard treated. Treating
soil exceeding 2,000 mg/kg lead would result in an average lead
treatm~nt rate of 40 pounds/cubic yard. Treating soil exceeding
5,'000 mg/kg, 10,000 mg/kg and 20,000 mg/kg would result in average
rates of 57, 60, and 100 pounds/cUbic yard, respectively. A
noticeabl ~ increasE: in the a-lount c:' lead treated percubic yard of
soil occurs at a lead concentration of greater than 10,000 mg/kg.
Therefore, '10,000 mg/kg was selected as the treatment level for
lead. This treatment level contains approximately 85% of the total
-------
soil above the cleanup goal. The treatment level selected for TPH,
10,000 mg/kg, contains 66% of the total TPH mass within 14% of the
TPH contaminated soil volume. The treatment level selected for
mercury, 5 mg/kg, cont.ains 27% of the mass of mercury within 8% of
the contaminated soil volume. These results show that the objective
of containing a majority of the contaminant mass' in a minimum
volume is achieved at the treatment levels for lead and TPH. The
treatment .evel for mercury did not c ,pture a majority of the mass
of mercury, because mercury is. more evenly distributed as a
function of concentration than TPH or lead.
b"
The corresponding cost analysis for lead, for example, also shows
that as the pounds of contaminant per cubic yard decreases, the.
cost to treat each pound rapidly increases. Assuming it costs $100
to treat one cubic yard of soil, the average cost to treat a pound
of lead at soil concentration exceeding 2',000 mg/kg, 5,000 mg/kg,
10,000 mg/kg, and 20,000 mg/kg is $2.50/1b, $1.75/1b, $1.66jlb, and
$1.00/1b, respectively. The cost drops significantly at' a lead
concentration exceeding 10,000 mg/kg, indicating it is the cost
effective breakpoint, and therefore, should be the treatment level.
The cost effective breakpoint for TPH occurred at a concentration
of about 10,000 mg/kg, and the breakpoint for mercury occurred at
about 5 mg/kg. .
II. Cost-Benefit Analysis of Treatment Levels
. After selecti~g treatment l~vels in the' Feasibility Study, a
cost-benefit analysis was completed for lead, mercury and TPH to
confirm these treatment levels. The analysis involved generating
two types of functions (curves). The first type of curve, soil
volume versus contaminant mass, was generated by ranking areas with
the ~articular contaminant in ~rder of highest .to lowest
concentration. The curve is based on the cumulative total
contaminant mass, -and soil volume for each contaminant
concentration. One assumption used in generating this curve was
.that the average contaminant concentration is an area is
represented by the single sample taken from that location. .
The second type of curve, mass of contaminant treated versus cost
per pound of contaminant, was generated by calculating the
excavation cost and treatment cost per cubic yard of soil, and
dividing by the mass of contaminant treated. This process was also
performed using cumulative totals as discussed above. It is
important to note that this figure is semi-quantitative in nature
since it used only excavation and treatment cost elements and did.
not include other costs required to implement the treatment
alternative. Simplifying assumptions used to generate these curves
include: 1) soil excavation costs a:~e $2.00 per cubic yard, 2)
excavation and handling costs are $6.00 per cubic yard, 3) lead and
mercury are treated by solidification at a cost of $100 per cubic
yard, 4) TPH is treated by thermal desorption at a cost of $100 per
cubic yard, and 5) the contaminated soil associated with the
-------
the contaminated soil associated
operable unit was not included.
with
the
petroleum tank
farm
The volume versus mass curvP. was used to determine the point at
which removing and treating additional ~oil volume does not provide
a proportionate degree of benefit in term of mass treated. The mass
versus cost per pqund curve was used to determine the cost-benefit
of treating 3n additional incremental ,olume of soil. As~hown in
each of th.e figures, the treatment level.s generally mark the
location at which signigicantly decreasing quantities of
contaminant mass are treated with each incremental increase in soil
volume removed. The treatment levels also generally locate the
point at which the cost per pound of contaminant treated increases.
-------
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----'.-------.--.:--.1-:.---.-----
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12.5
15
Mass of.TPH Treated
(pounds)
. .
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200
400 479 600 800
Mass of Mercury Treated (pounds)
1000
1200
-------
.
u
APPENDIX
c
EXPOSURE ESTIMATE FOR THERMAL DESORPTION
-------
Appendix C
EXPOSURE ESTIMATE FOR THERMAL DESORPTION OF
PETROLEUM CONTAMINATED SOIL AT HARBOR ISLAND
o
It is pr~posed that petroleuw contaminated soil at~arbor
Island t.p- treated by thermal deso!)tion with an afterb'urr.e.... :..
order to determine if such a treatment system would produce air
emissions which are safe for the system operators, who would be
the individual with the greatest chance of exposure, the
following calculations were performed. The petroleum constituents
with the greatest potential for health effects were identified as
benzene and PAHs. The air concentrations of these constituents
, are estimate at the point where the stack vents to the
atmosphere, which would be the maximum possible concentration
before mixing with ambient air. Finally, t~~ industrial threshold
values for these constituents are provided for comparison. These
threshold values are based on an 8-hour work day and 40-hour work
week, which ar~ the assumed exposure durations for this case.
1. Assumptions
.
.
a. Soil process rate: 100 tons/hr (22,500 kg/hr)
b. Stack air flow rate: 600,000 ft3/hr (22,222 m3/hr)
c. Afterburner Destruction Efficiency (bF): . '99.99%
d. Average concentration of benzene in soil: 2.0 mg/kg
e. Average concentration of PARs in soil: 30mg/kg
2. Calculated Air Concentrations at stack
a. Formula:
[C) air = ([C]soid (process rate) (l-DF)/stack flow rate
b. Ben~ene Conceptration:
[Benzene]air = (2 mg/kg) (22,500 kg/hr) (10-4)/(22,222 m3/hr)
, = 2x10-4 mg/m3
c. PAR Concentration:
=
(30 mg/kg) (22,500 kg/hr) (10-~)/(22,222 m3/hr)
3x10-3 mg/m3
[PAR] air
=
3. Threshold Limit Values (TLVs)
[Benzene]nv = 30 mg/m3
-------
'0
APPENDIX D
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PAGE:
1
===============================~~==============================================
Operable unit: Lockheed RI/FS
Date: 09/11/90
Pages: 70
~~
File Number: 1.1 - ENFORCEMENT
Doc. Number: 0001
Document Type: LEGAL DOCUMENT
Title/Subject: Administrative Order on Consent for Remedial
Investigation/Feasibility Study, Lockheed Shipyard No.1
Operable unit
.
.
Author
organization
Addressee
Organization
: FINDLEY, CHARLES
:. EPA-QA MANAGEMENT OFFICE
: THOMPSON, JEFFERY M.
: LOCKHEED CORPORATION
(REGION 10)'
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
... ....... ....... ............... ...... ...... ... ..... ........... .... ............
operable unit: Lockheed RI/FS
Date: 04/16/91
Pages: 1
File .Number : 2.1.1 - FORMAL CORRESPONDENCE - LOCKHEED RIfFS
'Doc. Number: 0001 .
Document Type: LETTER/FORMAL CORRESPONDENCE
Title/Subject: Letter declaring as adequate McLaren's response to Westin's
comments on the Work Plan, Field Sampling Plan and Quality
'Assurance Plan for Lockheed, dated 4/14/91.
Author : ROSE, KEITH
organization: ENVIRONMENTAL PROTECTION
Addressee : REED, FRED
organization: LOCKHEED CORPORATION
AGENCY REGION 10 (EPA)
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
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. .
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PAGE:
2
===========================================--===================================
Operable unit: Lockheed RI/FS
Date: 04/01/92
. Pages: . 39
File Number: 2.1.1 - FORMAL CORRESPONDENCE - LOCKHEED RI/FS
Doc. Number: 0002
Document Type: LETTER/FORMAL CORRESPONDENCE
Title/Subject: -COVER LETTER AND COMMENTS ON THE LOCKHEED PHASE II RI/FS
SAMPLING PLAN
Author : ROSE; KEITH
Organization : E~~IRONMENTAL PROTECTION
. Addressee. : AMORFINI, BUDDY
Organization: MCLAREN HART
AGENCY REGION 10 (EPA)
Document Status: This Document is Selected for Inclusion in the Administrative
Record. -
... ............. ........ ...... ....... ..... ............. ........ .............. ......... ........
Operable unit: Lockheed RI/FS
Date: 04/01/91 (Est.)
Pages: 95
File Number: 2.2.1 - PHASE I LOCKHEED RI/FS WORK PLAN
Doc. Number: 0001
Document Type: REPORT/STUDY
Title/Subject: REVISED PHASE I REMEDIAL INVESTIGATION/FEASIBILITY STUDY WORK
PLAN FOR LOCKHEED SHIPBUILDING, SEATTLE, WASHINGTON YARD I
Author : NOT INDICATED
Organization: MCLAREN HART
Addressee : NOT INDICATED
Organization: NOT INDICATED
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
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PAGE:
3
================================'===============================================
Operable unit: Lockheed RI/FS
Date: 09/01/88
Pages: 39
File Number: 2.2.1 - PHASE I LOCKHEED RI/FS WORK PLAN
'Doc. Number: 0002
Document Type: PHOTOeS)
Title/Subject: Aerial Photographic Property STudy' : Lockheed Shipbuilding and
Construction Company Seattle, Washington 1936-1985
Author : NOT INDICATED
Organization: LOCKHEED CORPORATION
Addressee: REED, FRED
Organization: LOCKHEED CORPORATION
Document Status: This Document is the Original and is Selected for Inclusion
in the Administrative Record.
PRPs
HOWARD S. WHITNEY
MONO ROOFING CO.
,PILGRIM PET SUPPLY, INC.
, '
. .. .. .. .. .. .. .. ..... .. .. .. .. .. .. .. .. ,- .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. . .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. " ...- .. .. .. .
operable unit: ,Lockheed RI/FS ' , , 'Date: 06/01/92 (Est.)"
Pages: 243
File Number: 2.2.2 - PHASE II LOCKHEED RI/FS WORK PLAN
'Doc. Number: 0001
Document Type: REPORT/STUDY
Title/Subject: REVISED PHASE II REMEDIAL INVESTIGATION/FEASIBILITY STUDY
PROGRAM FOR LOCKHEED SHIPBUILDING SEATTLE, WASHINGTON YARD I
WORK PLAN, FIELD SAMPLING PLAN, QUALITY ASSURANCE PROJECT PLAN
Author .: NOT I~DICATED.
organization: MCLAREN HART
Addressee : NOT INDICATED
organization: LOCKHEED CORPORATION
Document Status: This Document is Selected for Inclusion in the Administrative'
Record.
. ....... ...... ......... .... .................... .................... .... ............................. ..........
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ADMINISTRATIVE RECORD
PAGE:
4
============================================--==================================
Operable Unit: Lockheed RI/FS
Date: 05/06/91
. Pages: 4
File Number: 2.2.2 - PHASE II LOCKHEED RI/FS WORK PLAN
Doc. Number: 0002
Document Type: LETTER/FORMAL CORRESPONDENCE
Title/Subject: COVER LETTER AND ENCLOSURES RE: FORM OF THE LETTER PROPOSED TO
SUBMIT TO THE AGENCY TO SATISFY THE REQUIREMENTS OF PARAGRAPH
82 OF THE LOCKHEED ADMINISTRATIVE ORDER ON CONSENT.
AuthQr : BLUMENFELD, .CHARLES R.
Organization : BOGLE & GATES.
Addressee : KOWOLSKI, ED
Organization: ENVIRONMENTAL PROTECTION AGENCY REGION 10 (EPA)
Document Status: This Document is the Original and is Selected for Inclusion
in th~ Administrative Record.
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .- . . . . . . . . . . . . . . . . . . . . . . . . . . .
Operable Unit: Lockheed RI/FS
Date: 06/27/91
Pages: 3
File .Number : 2..2.2 - PHASE II LOCKHEED RI/FS WORK PLAN
Doc. Number: 0003 .
Document Type: LETTER/FORMAL CORRESPONDENCE
Title/Subject: PROPOSED FINANCIAL ~SSURANCES LANGUAGE RE: LOCKHEED
ADMINISTRATIVE ORDER ON CONSENT
Author : KOWOLSKI, ED
Organization: ENVIRONMENTAL PROTECTION
Addressee : BLUMENFELD, CHARLES R.
Organization: BOGLE & GATES
AGENCY REGION 10 (EPA)
. .
Document Status: This Dopument is Selected.for Inclusion. in the Administrative
Record.
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PAGE:
5
===============================================================================
Operable Unit: Lockheed RI/FS
Date: 08/26/91
Pages: 1 .
'\
File Number: 2.2.2 - PHASE II LOCKHEED RI/FS WORK PLAN
Doc. Number: 0004
Document Type: LETTER/FORMAL CORRESPONDENCE
Title/Subject: LETTER GRANTING LOCKHEED AND MCLAREN HART AN EXTENSION FOR
DELIVERY OF THE PSCS TO EPA
Author : ROSE, KEITH
Organization: ENVIRONMENTAL PROTECTION
Addressee : AMORFINI, .BUDDY .
Organization: MCLAREN HART
AGENCY REGION 10 (EPA)
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
.... ...... ...... .... ..... ... ........ ........... ...... .... ................ .......
Operable unit: Lockheed RI/FS
Date: 11/18/91
Pages: 7
File Number: 2.2.2 - PHASE II LOCKHEED RIfFS WORK PLAN
. Doc~. Number: 0005 .
Document Type: .LETTER/FORMAL CORRESPONDENCE
Title/Subject: COMMENTS AND ENCLOSED SETS OF COMMENTS ON THE SITE
CHARACTERIZATION REPORT PREPARED BY MCLAREN ON THE LOCKHEED
SHIPYARD I .
Author : ROSE, KEITH
organization: ENVIRONMENTAL PROTECTION
Addressee : AMORFINI, BUDDY
Organization: MCLAREN HART
AGENCY REGION .10 (EPA)
Document status: This Document is Selected for Inclusion in the Administrative
Record.
....... ............. .......... ....... ........ ...................... ...... ......
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ADMINISTRATIVE RECORD
PAGE:
6
=========================================================~=====================
Operable Unit: Lockheed RI/FS
Date: 03/17/92
Pages: 1
File Number: 2.2.2 - PHASE II ~OCKHEED RI/FS WORK PLAN
Doc. Number.: 0006
Document Type: LETTER/FORMAL CORRESPONDENCE
.?
Title/Subject: LETTER RE: APPROVAL OF THE SITE CHARACTERIZATION SUMMARY
Author : ROSE, KEITH
Organization: ENVIRONMENTAL PROTECTION AGENCY REGION 10 (EPA)
Addressee ; REED, FRED . .
Organization: LOCKHEED CORPORATION
Document Status: This Document is Selected for Inclusion. in the Administrative
Record.
........... ..... .... ........... ....... ... ........... .............. .... ..... ....
Operable Unit: Lockheed RI/FS
Date: 06/15/92
Pages: 1
File Number: 2.2.2 - PHASE II LOCKHEED RI/FS WORK PLAN
Doc. Number: 0007 .
Document Type: LETTER/FORMAL CORRESPONDENCE
Title/Subject: APPROVAL OF THE REVISED RIfFS WORK PLAN DATED 6/92
Author : ROSE, KEITH
Organization: ENVIRONMENTAL PROTECTION AGENCY
Addressee: ICF Kaiser Engineers, Inc
Organization .: M€LAREN HART
REGION 10 (EPA)
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
-------
'J7 /06/94
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ADMINISTRATIVE RECORD
PAGE:
7
===============================================================================
Operable unit: Lockheed RI/FS
Date: 04/01/91 (Est.)
Pages: 79
File Number: 2.3.1 - PHASE I LOCKHEED RIfFS SAMPLING AND ANALYSIS PLAN
Doc. Number: 0001
bocument Type: REPORT/STUDY
.
o
Title/Subject: REVISED PHASE I REMEDIAL INVESTIGATION/FEASIBILITY STUDY
SAMPLING AND ANALYSIS PLAN FIELD SAMPLING PLAN FOR LOCKHEED
SHIPBUILDING SEATTLE, WASHINGTON YARD I VOLUME I
Author
Organization
Addressee
organization
: NOT INDICATED
: MCLAREN HART
: NOT INDICATED
: NOT INDICATED
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
.. ............ ...... ..... ...... ....................... ....... ................ .............
Operable unit: Lockheed RI/FS
Date: 04/01/91 (Est,)
Pages: 65
File Number 2.3.1 - PHASE I LOCKHEED RI/FS SAMPLING AND ANALYSIS PLAN
Doc~ Nuniber : 0002 .
Document Type: REPORT/STUDY
Title/Subject: REVISED PHASE I REMEDIAL INVESTIGATION/FEASIBILITY STUDY
SAMPLING AND ANALYSIS PLAN VOLUME 2 QUALITY ASSURANCE PLAN
LOCKHEED SHIPBUILDING SEATTLE, WASHINGTON YARD I
FOR
Author
organization
Addressee
Organizatio~
: NOT INDICATED
: MCLAREN HART
: NOT INDICATED
: NOT INDICATED.
Document Status:. This Document is Selected for Inclusion in the Administrative
Record.
.... .............. ........ ................. ............... ..... ..... ............... ........................
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PAGE:
8
===============================================================================
Operable Unit: Lockheed RI/FS
Date: 12/05/91
Pages: 3~4
File Number: 2.3.1 - PHASE I LOCKHEED RI/FS SAMPLING AND ANALYSIS PLAN
Doc. Number: 0003
Document Type: REPORT/STUDY
Title/Subject: QUALITY ASSURANCE MANUAL - MCLAREN ANALYTICAL LABORATORY
Author : NOT INDICATED
Organization: MCLAREN HART
Addressee: NOT INDICATED
Organization: NOT INDICATED
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
. ......... .~...... ... ................ .......... ........ .......... .......... ... ......... ...
Operable Un~t: Lockheed RI/FS
Date: 04/16/92
Pages: 127
File Number: 2.3.1 - PHASE I LOCKHEEDRI/FS.SAMPLING AND ANALYSIS PLAN
Doc. Number: 0004
D~cument Type: REPORT/STUDY
Title/Subject: AMENDMENT TO THE QUALITY ASSURANCE MANUAL FULFILLING EPA REGION
10 ADDITIONAL REQUIREMENTS REVISION 1 MCLAREN ANALYTICAL
. . LABORATORY
Author : NOT INDICATED
Organization: MCLAREN HART
Addressee: NOT INDICATED
Organi2ation : NOT INDICATED
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
-------
07/06/94
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ADMINISTRATIVE RECORD
PAGE:
9
===============================================================================
Operable unit: Lockheed RI/FS
Date: OS/20/92
Pages: 76
File Number: 2.3.1 - PHASE I LOCKHEED RI/FS SAMPLING AND ANALYSIS PLAN
Doc. Number: 0005
Document Type: REPORT/STUDY
.
D
Title/Subject: AMENDMENT TO THE QUALITY ASSURANCE MANUAL FULFILLING EPA REGION
10 ADDITIONAL REQUIREMENTS REVISION 2.0 MCLAREN ANALYTICAL
LABORATORY
Author : NOT INDICATED
Organization: MCLAREN HART
Addressee : NOT INDICATED
Organization: NOT INDICATED
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
.... ........ ... ............ ............... ..... ... ........ .... ... ..............
Operable Unit: Lockheed RI/FS
Date: 11/13/92
Pages: 118
File Number: 2.4.1 - SITE CHARACTERIZATION SUMMARY REPORT.- LOCKHEED RI/FS
Doc. Number.: 0001. ...
Document Type: REPORT/STUDY
Title/Subject: PHASE II SITE CHARACTERIZATION REPORT REMEDIAL
INVESTIGATION/FEASIBILITY STUDY LOCKHEED SHIPBUILDING
SEATTLE, WASHINGTON YARD 1 VOLUME 1 REPORT
Author : NOT INDICATED
Organization : MCLAREN,~T
Addressee : NOT INDICATED
organization: LOCKHEED CORPORATION
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
............... ................. ............ ......... ..... ..... ................
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PAGE:
10
===============================================================================
Operable unit: Lockheed RI/FS
Date: 11/13/92
Pages: 268
File Number: 2.4.1 - SITE CHARACTERIZATION SUMMARY REPORT - LOCKHEED RI/FS
Doc. Number: 0002
Document Type: REPORT/STUDY
Title/Subject: PHASE II SITE CHARACTERIZATION REPORT REMEDIAL
INVESTIGATION/FEASIBILITY STUDY LOCKHEED SHIPBUILDING
SEATTLE, WASHINGTON YARD I VOLUME II APPENDICES A-I
Author : NOT INDICATED
Organization: MCLAREN HART .
Addressee : NOT INDICATED
Organization: LOCKHEED CORPORATION
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
..... ....... ..... ... ............ ...... ..... ...... ... ..... ........ ...............
Operable unit: Lockheed RI/FS
Date: 11/13/92
Pages: 337
File Number: 2.4.1 - SITE CHARACTERIZATION SUMMARY REPORT.- LOCKHEED RIfFS
. Doc. Number: 0003
Document Type: REPORT/STUDY
Title/Subject: PHASE II SITE CHARACTERIZATION REPORT REMEDIAL
INVESTIGATION/FEASIBILITY STUDY LOCKHEED SHIPBUILDING
SEATTLE, WASHINGTON YARD I VOLUME III APPENDICES J-L
Author. : NOT INDICATED
Organization: MCLAREN HART
Addressee : NOT INDICATED
. Organization: LOCKHEED CORPORATION
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
PRPs
PACIFIC MOLASSES CO.
-------
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PAGE:
11
===============================================================================
Operable Unit: Lockheed RI/FS
Date: 03/01/93 (Est.)
Pages: 124
File Number: 2.4.1 - SITE CHARACTERIZATION SUMMARY REPORT - LOCKHEED RI/FS
Doc. Number: 0004
Document Type: REPORT/STUDY
.
J
Title/Subject: REVISED PHASE II SITE CHARACTERIZATION REPORT REMEDIAL
INVESTIGATION/FEASIBILITY STUDY LQCKHEED SHIPBUILDING
SEATTLE, WASHINGTON YARD I VOLUME 1 REPORT
Author : NOT INDICATED
Organization: MCLAREN HART"
Addressee: NOT INDICATED
Organization: LOCKHEED CORPORATION
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
PRPs
CITY OF SEATTLE
. . .. . . . . . .. .. .. .. . .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .'. .. . .. .. .. .. .. .. .. .. .. .. . .. .. .. .. .. .. .. .. .. .. .. .. . . .. . .. .. .. .. .. .. ..
Operable unit: Lockheed RI/FS
Date: 03/01/93 (Est.)
Pages: 270
File Number: 2.4.1 - SITE CHARACTERIZATION SUMMARY REPORT - LOCKHEED RI/FS
Doc. Number: 0005
Document Type: REPORT/STUDY
Title/Subject: REVISED PHASE II SITE CHARACTERIZATIPN REPORT REMEDIAL
INVESTIGATION/FEASIBILITY STUDY LOCKHEED SHIPBUILDING
SEATTLE, WASHINGTON YARD I VOLUME II APPENDICES A-I
Author : NOT INDICATED
organization: MCLAREN HART
Addressee. : NOT INDICATED
Organization : LOC~EED CORPORATION
Document status: This Document is Selected for Inclusion in the Administrative
Record.
.... ................ ........ ........... ...... ... ....... ....................... ...............
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PAGE:
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===============================================================================
Operable Unit: Lockheed RI/FS
Date: 03/01/93 (Est.)
Pages: 338
File Number: 2.4.1 - SITE CHARACTERIZATION SUMMARY REPORT - LOCKHEED RI/FS
Doc. Number: 0006
Document Type: REPORT/STUDY
Title/Subject: REVISED PHASE II SITE CHARACTERIZATION REPORT REMEDIAL
INVESTIGATION/FEASIBILITY STUDY LOCKHEED SHIPBUILDING
SEATTLE, WASHINGTON YARD I VOLUME III APPENCIDES J-L
Author : NOT INDICATED
Organization: MCLAREN HART
Addressee : NOT INDICATED
Organization: LOCKHEED CORPORATION
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
. .
.. ..... ...... ...... .... .................. ..... ............... ............................ .......
Operable unit: Lockheed RI/FS
Date: 01/01/92 (Est.)
Pages: 124
File Number: 2.4.1 - SITE CHARACTERIZATION SUMMARY. REPORT - LOCKHEED .RlfFS
Doc. Number: 0007 .
Document Type: R~PORT/STUDY
Title/Subject: PRELIMINARY SITE CHARACTERlXATION SUMMARY PHASE I REMEDIAL
INVESTIGATION/FEASIBILITY STUDY LOCKHEED SHIPBUILDING YARD I
SEATTE, WASHINGTON REVISED JANUARY 1992 VOLUME 1 OF 3
Author : NOT INDICATED
Organization: MCLAREN HART
Addressee : NOT INDICATED
Organization: NOT INDICATED
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
-------
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PAGE:
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===============================================================================
Operable unit: Lockheed RI/FS
Date: 01/01/92 (Est.)
Pages: 336
File Number: 2.4.1 - SITE CHARACTERIZATION SUMMARY REPORT - LOCKHEED RI/FS
Doc. Number: 0008
Document Type: REPORT/STUDY
Title/Subject:
PRELIMINARY SITE CHARACTERIZATION SUMMARY PHASE I REMEDIAL
INVESTIGATION/FEASIBILITY STUDY LOCKHEED SHIPBUILDING YARD I
SEATTLE, WASHINGTON REVISED JANUARX 1992 APPENDICES VOLUME. 2
OF 3
Author :.NOT INDICATED
organization: MCLAREN HART
Addressee: NOT INDICATED
Organization: NOT INDICATED
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..8 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Operable unit: Lockheed RIfFS
Date: oif01/92 (Est.)
Pages: 142
.File Number: 2.4.1 - SITE CHARACTERIZATION SUMMARY REPORT - LOCKHEEDRI/FS
Doc. Number: 0009
Document Type:
Title/Subject:
PRELIMINARY SITE CHARACTERIZATION SUMMARY
INVESTIGATION/FEASIBILITY STUDY LOCKHEED
SEATTLE, WASHINGTON REVISED JANUARY 1992
OF 3 .
PHASE I REMEDIAL
SHIPBUILDING YARD I
APPENDICES VOLUME 3
Author : NOT INDICATED
organization: MCLAREN HART
Addressee. : NOT INDICATED
Organization: NOT INDICATED
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
..... ... ..... ... .............. ............. ..... ..... ...... .......... ...... ....
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PAGE:
14
==============================----===============================================
Operable unit: Lockheed RI/FS
,Date: 04/01/92
. Pages: 254
File Number: 2.4.2 - QA/QC REVIEW REPORTS- LOCKHEED RI/FS
Doc. Number: 0001
Document Type: REPORT/STUDY
Title/Subject: QA/QC REVIEW REPORT OF LABORATORY PROJECT NUMBER L5170 AND
L5183
Comments
: THIS DOCUMENT IS INCORPORATED INTO THE ADMINISTRATIVE RECORD BY
REFERENCE ONLY,-, SEE SITE FILE OU3, 2.4.2 0001 FOR COpy
Author : NOT INDICATED
Organization: MCLAREN HART
Addressee : NOT INDICATED
Organization: LOCKHEED CORPORATION
Document Status: This Document is 'Selected for Inclusion in the Administrative
Record.
.... ...... ...... ...... ..... ........... ..... ...... ... .............. .... .........
Operable Unit: Lockheed RI/FS Date: 07/13/92
Pages: 236
File Number: 2.4.2 - QA/QC REVIEW REPORTS - LOCKHEED RI/FS
Doc. Number: 0002
Document Type: REPORT/STUDY
Title/Subject: QA/QC REVIEW REPORT OF LABORATORY PROJECT NUMBER L5804
Comments
: THIS DOCUMENT IS INCORPORATED INTO THE ADMINISTRATIVE RECORD BY
REFERENCE ONLY SEE SITE FILE OU3, 2.4.2 0002 FOR COPY
Author : NOT INDICATED
Organization: MCLAREN HART
Addressee' : NOT INDICATED
Organization: LOCKHEED CORPORATION
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
-------
=====================================================================--=========
07/06/94
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ADMINISTRATIVE RECORD
PAGE:
15
Operable unit: Lockheed RI/FS
Date: 08/18/92
Pages: 138
File Number : 2~4.2 - QA/QC REVIEW REPORTS - LOCKHEED RI/FS
Doc. Number: 0003
Document Type: REPORT/STUDY
<
"
. Title/Subject: QA/QC REVIEW REPORT OF LABORATORY PROJECT NUMBER L6147
: THIS DOCUMENT IS INCLUDED IN THE ADMINISTRATIVE RECORD BY .
REFERENCE ONLY SEE SITE FILE 2.4.2 0003, OU3
Author : NOT INDICATED
Organization: MCLAREN HART
Addressee: NOT INDICATED
organization: LOCKHEED CORPORATION
Comments
Document Status: This. Document. is Selected for Inclusion in the Administrative
Record.
. ......... ............ .... ............. ......... ..... ...... .... ... ........ .....
Operable Unit: Lockheed RIfFS
Date: 09/03/92
Pages: 87
File Number: 2.4.2 .- QA/QC REVIEW REPORTS - .LOCKHEEDRI/FS
Doc. Number: 0004
Document Type: REPORT/STUDY
Title/Subject: QA/QC REVIEW REPORT OF LABORATORY PROJECT NUMBER L6205
Comments
: THIS DOCUMENT IS INCLUDED IN THE ADMINISTRATIVE RECORD BY
REFERENCE ONLY, SEE SITE FILE 2.4.2 0004, OU3
Author : NOT INDICATED
Organization: MCLAREN HART
Addressee. : NOT IND~CATED
Organization: LOCKHEED CORPORATION
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
-------
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ADMINISTRATIVE RECORD
PAGE:
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=================================~=============================================
Operable Unit: Lockheed RI/FS
Date: 07/30/92
Pages: 222
File Number: 2.4.2 - QAfQC REVIEW REPORTS - LOCKHEED RIfFS
Doc. Number: 0005
Document Type: REPORT/STUDY
Title/Subject: QA/QC REVIEW REPORT OF LABORATORY PROJECT NUMBER L6107
Comments
: THIS DOCUMENT IS INCLUDED IN THE ADMINISTRATIVE RECORD BY
REFERENCE ONLY, SEE SITE FILE 2.4.2 0005, OU3
Author : NOT INDICATED
Organization: MCLAREN HART
Addressee : NOT INDICATED
Organization: LOCKHEED CORPORATION
Document Status: This Document is Selected ,for Inclusion in the Administrative
Record.
............ ............... ........... ..... .................. ..................
Operable unit: Lockheed RI/FS
Date: 08/20/92
Pages: 210
, "
File Number: 2.4.2 - QA/QC REVIEW REPORTS - LOCKHEED RI/FS
Doc.'Number : 0006
Document Type: REPORT/STUDY
Title/Subject: QA/QC REVIEW REPORT OF LABORATORY PROJECT NUMBER L6129
Comments
: THIS DOCUMENT IS INCLUDED IN THE ADMINISTRATIVE RECORD BY
REFERENCE ONLY, SEE SITE FILE 2.4.2 0006, OU3
Author : NOT INDICATED
Organization: MCLAREN HART
Addressee: NOT INDICATED,
Organization: LOCKHEED CORPORATION
Document status: This Document is Selected for Inclusion in the Administrative
Record.
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07/06/94
HARBOR ISLAND
ADMINISTRATIVE RECORD
PAGE:
17
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Operable unit: Lockheed RI/FS
Date: 07/27/92
Pages: 241
File Number: 2.4.2 - QA/QC REVIEW REPORTS - LOCKHEED RI/FS
Doc. Number: 0007
Document Type: REPORT/STUDY
Title/Subject: QA/QC REVIEW REPORT OF LABORATORY PROJECT NUMBER L6091
q"
Comments
: THIS DOCUMENT IS INCLUDED 'INTO THE ADMINISTRATIVE RECORD BY
REFERENCE ONLY, SEE SITE FILE 2.4.2 0007, OU3
Author : NOT INDICATED
organization: MCLAREN HART
Addressee : NOT INDICATED
Organization: LOCKHEED CORPORATION
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
... ..... ... ........... ................. ..... .......... .........................
Operab~e unit: Lockheed RI/FS
Date: 08/12/92
Pages: 213
File Number :2.4.2 - QA/QC REVIEW REPORTS - LOCKHEEDRI/FS
Doc. Number: 0008
Document Type: REPORT/STUDY
, Title/Subject: QA/QC REVIEW REPORT OF LABORATORY PROJECT NUMBER L6121
: TH1s DOCUMENT IS INCLUDED INTO THE ADMINISTRATIVEJRECORD BY
REFERENCE ONLY, SEE SITE FILE 2.4.2 0008, OU3 '
Author : NOT INDICATED
organization : MCLAREN HART
Addr,essee ': NOT IJIDlCATED '
Organization: LOCKHEED CORPORATION
Comments
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
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)7 /06/94
HARBOR ISLAND.
ADMINISTRATIVE RECORD
PAGE:
18
=====--=========================================================================
. Operable Unit: Lockheed RI/FS
Date: NOT INDICATED
Pages: 305
File Number: 2.4.3 - FIELD DATA REPORTS - LOCKHEED RI/FS
Doc. Number: 0001
Document Type: REPORT/STUDY
Title/Subject: LOCKHEED YARD I PHASE I RI/FS FIELD DATA (VOLUME 1 OF 2)
Author : NOT INDICATED
Organization: MCLAREN HART
Addressee: NOT INDICATED
organization: NOT INDICATED
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
. . . . . . . . . . . . . . . . . . . . . . . . e. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Operable Unit: Lockheed RI/FS
Date: NOT INDICATED
Pages: 236
File Number: 2.4.3 - FIELD DATA REPORTS - LOCKHEED RI/FS
Doc. Number: 0002
Dc;>cument Type: REPORT/STUDY.
Title/Subject: LOCKHEED YARD I PHASE I RI/FS FIELD DATA (VOLUME 2 OF 2)
Author : NOT INDICATED
Organization: MCLAREN HART
Addressee : NOT INDICATED
Organization: NOT INDICATED
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
. .' . . .'. . . . . . . . . ... . . . . . . . . . . . . . . . . . . . . ~ . . . . . .'.4. . . . .'. . . . . . . .'. . . . . .'. . . . . . -- . ... . . . . .
Operable Unit: Lockheed RI/FS Date: 10/01/90
Pages: 155
File Number: 2.5.1 - PHASE I HEALTH AND SAFETY PLANS -LOCKHEED RI/FS
Doc. Number: 0001
Document Type: REPORT/STUDY
Title/Subject: SITE SAFETY AND HEALTH PLAN
. SEATTLE, WASHINGTON
FOR LOCKHEED' SHIPBUILDING YARD I
Author : NOT INDICATED
Organization: MCLAREN HART
Addressee : NOT INDICATED
Organization: LOCKHEED CORPORATION
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
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07/06/94
HARBOR ISLAND.
ADMINISTRATIVE RECORD
PAGE:
19
========================--======================================================
Operable Unit: Lockheed RI/FS
Date: 02/02/92
Pages: 62
File Number: 2.5.2 - PHASE II HEALTH AND SAFETY PLAN - LOCKHEED RI/FS
Doc. Number: 0001
Document Type: REPORT/STUDY
~
Title/Subject: LOCKHEED SEATTLE YARD I SITE SAFETY AND HEALTH PLAN
RI/FS
PHASE II
Author : NOT INDICATED
Organization: MCLAREN HART
Addressee : NOT INDICATED
Organization: NOT INDICATED
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
.. ..... ......... ..... ........ ...404O.... ...4O ........... ...... ....404O ..... .......404O
operable Unit: Lockheed RI/FS
Date: 05/01/93 (Est.)
Pages:. 212
File Number: 2.7.1 - RI REPORT - LOCKHEED RIfFS
Doc. Number.: 0001
Document Type: REPORT/STUDY
Title/Subject: REMEDIAL INVESTIGATION REPORT LOCKHEED SHIPBUILDING YARD I,
SEATTLE, HASHINGTON VOLUME I REPORT TEXT
Author
organization
Addressee. .
. organization
: NOT INDICATED
: MCLAREN HART
: NOT INDICATED
LOCKHEED CORPORATION
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
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07/06/94
HARBOR ISLAND
ADMINISTRATIVE RECORD
PAGE:
20
===============================================================================
Operable unit: Lockheed RI/FS
Date: 05/01/93 (Est.)
Pages: 481
File Number :2.7.1 - RI REPORT - LOCKHEED RI/FS
Doc. Number: 0002
Document Type: REPORT/STUDY
Title/Subject: REMEDIAL INVESTIGATION REPORT LOCKHEED SHIPBUILDING YARD I
SEATTLE, WASHINGTON
VOLUME II APPENDICES A THROUGH J
Author : NOT INDICATED
Organization : M~LAREN HART
Addressee : NOT INDICATED
Organization: LOCKHEED CORPORATION
Document Status: This Document is $elected for Inclus~on in the Administrative
Record.
. ................ ............ .... ..... ..... ........................... .............
,operab~e Unit: Lockheed RI/FS
Date: 05/01/93 (Est.)
Pages: 259
File Number: 2.7.1 - RI REPORT - LOCKHEED RI/FS
Doc~ Number :0003
Document Type: REPORT/STUDY
Ti~le/Subject: REMEDIAL INVESTIGATION REPORT LOCKHEED SHIPBUILDING YARD I,
SEATTLE,WASHINGTON VOLUME III APPENDICES F THROUGH K
Author : NOT INDICATED
Organization: MCLAREN HART
Addres,see ': NOT, INDICATED "
Organization: LOCKHEED CORPORATION
Document status: This Document is Selected for Inclusion in the Administrative
Record.
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.07/06/94
HARBOR ISLAND.
ADMINISTRATIVE RECORD
PAGE:
21
=====--=================--============================================--==========
Operable unit: Lockheed RI/FS
Date: 12/21/93
Pages: 155
File Number: 2.7.2 - FS REPORT
Doc. Number: 0001
Document Type: REPORT/STUDY
Title/Subject: Feasibility Study Report, Lockheed Shipyard No.1, Operable
unit of the Harbor Island Superfund Site, Seattle, WA
'oJ
Author : ICF Kaiser Engineers, Inc
Organization: NOT INDICATED
Addressee NOT INDICATED
Organization : LOCKHEED CORPORATION
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
.... ..... ..... ........ ....... ......... ............... ...... -... ........ ............. .................
Operable unit: Lockheed RI/FS
Date: 02/14/94
Pages: 13
File Number: 2.7.2 - FS REPORT
Doc. Number: 0002 .
Document Type: TECHNICAL. .MEMORANDUM
Title/Subject: Technical Memorandum summarizing thermal treatment alternatives
for soils containing total petroleum hydrocarbons
Author : C. A. YUGE
organization: LOCKHEED CORPORATION
Addressee : ROSE, KEITH
Organization: ENVIRONMENTAL PROTECTION
AGENCY REGION 10 (EPA)
~ocument Status: This Document is Selected for Inclusion in the Administrative
Record. .
.. ...... ... ... ...................... ................... ............. .................. ...... ....
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HARBOR ISLAND
ADMINISTRATIVE RECORD
PAGE:
22
===============================================================================
Operable Unit: Lockheed RIfFS
Date: 03/16/94
Pages: 8
File Number: 2.7.2 - FS REPORT
Doc. Number: 0003
Document Type: LETTER/FORMAL CORRESPONDENCE
Title/Subject: Letter.in response to request for Feasibility Study cost
estimates to remove or cap sand blast grit located in the
upland portion of the Lockheed Yard Shipway Nos. 2 and 3
Author: HELGERSON, R.N.
Organization: LOCKHEED CORPORATION
Addressee : ROSE, KEITH
Organization: ENVIRONMENTAL PROTECTION
AGENCY REGION 10 (EPA)
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
...................... ......... ....... ..... .............. ... ... ................
Operable unit: Lockheed RIfFS
. Date: 04/22/94
Pages: .18 ..
File Number: 3.1 -
Doc. Number: 0001
Document Type: PROPOSED PLAN
Title/Subject: THE PROPOSED PLAN HARBOR ISLAND SITE LOCKHEED SHIPYARD FACILITY
SEATTLE, WASHINGTON
Author : ROSE, KEITH
Organization; ENVIRONMENTAL
. Addressee. NOT INDICATED
Organization: NOT INDICATED
PROTECTION AGENCY REGION 10 (EPA)
Document status: This Document is Selected for Inclusion in the Administrative
Record.
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07/06/94
HARBOR ISLAND
ADMINISTRATIVE RECORD
PAGE:
23
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------
Operable Unit: Lockheed RI/FS
Date: 04/22/94
Pages: 2
f'
C,
File Number: 3.1 -
Doc. Number: 0002
Document Type: CO~~ITY RELATIONS/PUBLIC PARTICIPATION
r
"
Title/Subject: SUPERFUND FACT SHEET HARBOR ISLAND SITE LOCKHEED SHIPYARD
FACILITY SEATTLE, WASHINGTON
Author : ROSE, KEITH
Organization: ENVIRONMENTAL PROTECTION
Addressf:!e .: NOT INDICATED
Organization. : NOT INDICATED
Document Status: This Document is Selected ~or Inclusion in the Administrative
Record.
AGENCY REGION 10 (EPA)
. . . . . '. . . . . . . . . . ~ . . . . . -. . . eo . . . . . '. . . . . . . . . . . . ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .' . . ;.
Operable unit: Lockheed RI/FS
Date: 04/28/94
Pages: 2
File Number: 3.2 -
Doc. Number: 0001
Document Type: LETTER/FORMAL CORRESPONDENCE
Title/Subject: COMMENTS ON THE PROPOSED CLEANUP ALTERNATI ES AT THE HARBOR
ISLAND SITE REMEDIATION
Author. : KIRCHER, DAVID S~
organization: PUGET SOUND AIR POLLUTION CONTROL AGENCY
Addressee : POSE, KEITH. .
organization: E!NIRONMENTAL PROTECTION AGENCY REGION 10 (EPA)
Document Status: This Document is the Original and is Selected for Inclusion
in the Administrative Record.
. . . . . . . . . . . -0 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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07/06/94
HARBOR ISLAND
ADMINISTRATIVE RECORD
PAGE:
24
===============================================================================
Operable Unit: Lockheed RI/FS
Date: 05/11/94
Pages: 9
File Number: 3.2 -
Doc. Number: 0002
Document Type: LETTER/FORMAL CORRESPONDENCE
Title/Subject: LOCKHEED COMMENTS ON EPA'S PROPOSED PLAN FOR LOCKHEED SHIPYARD
NO.1, SEATTLE
Author : HELGERSON, R.N.
organization: LOCKHEED CORPORATION
Addressee: ROSE, KEITH .
organization: ENVIRONMENTAL PROTECTION
AGENCY REGION 10 (EPA)
Document Status: This Document is the Original and is Selected for Inclusion
in the Administrative Record.
. ........... .... ...... ..... ....... ..... .... ...... ......... .... .... ........ .....
Operable. unit: Lockheed RI/FS
Date: 06/23/94
Pages: 1
File Number: 3.2 -
Doc. Number: 0003
Document Type: LETTER/FORMAL CORRESPONDENCE
Title/Subject: Comments on Lockheed's RI/FS Record of Decision
Author : MADAKOR, NNAMDI
Organization: WASHINGTON STATE DEPARTMENT OF ECOLOGY (WDOE)
Addressee : ROSE, KEITH
organization: ENVIRONMENTAL PROTECTION AGENCY REGION 10 (EPA)
Document Status: This 'Document is.Selected for Inclusion in the Administrative
Record.
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07/06/94
'HARBOR ISLAND
ADMINISTRATIVE RECORD
PAGE:
25
=================================================================~===--=========
Operable unit: Lockheed RI/FS
Date: 06/23/94
Pages: 1
"
v
File Number: 3.2 -
Doc. Number: 0003
Document Type: LETTER/FORMAL CORRESPONDENCE
Title/Subject: COMMENTS ON LOCKHEED'S RI/FS RECORD OF DECISION
,
Cj
Author : MADAKOR, NNAMDI
Organization: WASHINGTON STATE DEPARTMENT OF ECOLOGY (WDOE)
Addressee : ROSE, KEITH .
Organization: ENVIRONMENTAL PROTECTION AGENCY REGION 10 (EPA)
Document Status: This Document is Selected for Inclusion in the Administrative
Record.
.. ...... ........ ......... ..... .......... .... ......... ...... .......... .... ......
Operable unit: Lockheed RI/FS
Date: 05/11/94
Pages: .14
File' Number: ,3..3- PUBLIC MEETING TRANSCRIPT
Doc. Number: 0001
Document Type: COMMUNITY RELATIONS/PUBLIC PARTICIPATION
Title/Subject: PROCEEDINGS: PUBLIC MEETING: LOCKHEED. PROPOSED PLAN FOR
HARBOR ISLAND
Author . : HOLMES, KATHEY L.
Organization: BAYSIDE REPORTERS
Addressee. : NOT INDICATED
Organization: ENVIRONMENTAL PROTECTION
AGENCY REGION 10 (EP~)
Document Status: This Document i's the Original and is Selected for Inclusion
in the Administrative Record.
.. ................. ...... .... .......... ........... ...... ... ........ ..... .......
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07/06/94
HARBOR ISLAND
ADMINISTRATIVE RECORD
PAGE:
26
=====--====================================================--====================
Operable unit: Lockheed RI/FS
Date: 06/28/94 .
Pages: 84
File Number: 4.1 - RECORD OF DECISION
Doc. Number: 0001
Document Type: REPORT/STUDY
Ti tIel Subj ect: RECORD OF DECISioN DELCARATION, .DECISION SUMMARY, AND
RESPONSIVENESS SUMMARY FOR LOCKHEED SHIPYARD FACILITY, HARBOR
'ISLAND SEATTLE, WASHINGTON
Author : CLARK, CHUCK
Organization: ENVIRONMENTAL
Addressee : NOT INDICATED
Organization: NOT INDICATED
Document Status: This Document is the Original and is Selected for Inclusion
in the Administrative Record~
P.ROTECTION AGENCY REGION 10 (EPA)
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