PB97-964601
EPA/541/R-97/045
November 1997
EPA Superfund
Record of Decision:
Harbor Island (Lead)
The Shipyard Sediment Operable Unit,
Seattle, WA
11/27/1996
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IXin£ AVENUE
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TABLE OF CONTENTS
Section Page
I. Declaration
II. Decision Summary
A. Introduction 1
B. Site Name, Location and Description . . . . 1
C. Site History 3
D. Highlights of Community Participation 5
E. Scope and Role of Response Action , 6
F. Summary of Site Characteristics 6
G. Summary of Risks for the Shipyard Sediment OU 16
H. Cleanup Objective and Sediment Standards 19
I. Description of Remedial Alternatives 21
J. Summary of the Comparative Analysis of Alternatives 25
K. The Selected Remedy .... 29
<
L. Statutory Determinations 35
M. Documentation of Significant Changes 40
APPENDICES
Appendix A: Responsiveness Summary
Appendix B: Alternative Cost Estimate Tables
Appendix C: Administrative Record Index
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List of Figures
Figure 1: Harbor Island Location Map 2
Figure 2: Harbor Island Site Map 4
Figure 3: Todd Shipyards Cleanup Area 7
Figure 4: Lockheed Shipyard Cleanup Area 8
Figure 5: Surface Sediment Sampling Locations 13
List of Tables
Table 1: EBAP Sediment Contaminant Concentrations 14
Table 2: RI Sediment Contaminant Concentrations ....... '. 14
Table 3: SRI Sediment Contaminant Concentrations 14
*••
Table 4: Chemical Cleanup Standards .22
Table 5: Alternative Cost Estimates .28
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DECLARATION
SHIPYARD SEDIMENT OPERABLE UNIT, HARBOR ISLAND,
SEATTLE, WASHINGTON
SITE NAME AND LOCATION
Shipyard Sediment Operable Unit, Harbor Island
Seattle, King County, Washington
STATEMENT OF BASIS AND PURPOSE
The Harbor Island Superfund Site (Site) is located in Seattle, King County, Washington. The
U.S. Environmental Protection Agency (EPA) has divided this Site into five operable units
(OUs), which are: 1) the petroleum storage tank OU, 2) the Soil/Groundwater OU, 3) the
Lockheed Shipyard OU, 4) the Shipyard Sediment OU, and 5) the Waterway Sediment OU.
The Shipyard Sediment OU includes contaminated nearshore sediments at the Todd and
Lockheed Shipyards. This Record of Decision (ROD) presents the selected remedial action
for the Shipyard Sediment OU.. 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 Shipyard Sediment
OU 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
for the Shipyard Sediment OU.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the Shipyard Sediment OU, if not
addressed by implementing the response action selected in this ROD, may present an
imminent and substantial endangerment to human health and the environment.
DESCRIPTION OF THE SELECTED REMEDY
Based on CERCLA, the NCP, the Administrative Record, the comparative analysis of the
alternatives, and public comment, EPA has selected Alternative 4, Dredge to the Chemical
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Cleanup Screening Level (CSL) and Cap, as the remedy for the Harbor Island Shipyard
Sediment OU. Alternative 3, Dredge to the Chemical Sediment Quality Standard (SQS), is
identified as a contingent remedy if sediment sampling conducted during remedial design
indicates that Alternative 3 provides a better cost-benefit than Alternative 4.
The essential elements of the selected remedy for the Shipyard Sediment OU are:
1) All sediments exceeding the chemical CSL and shipyard waste must be dredged.
This also applies to sediments and shipyard waste in the shipways at Lockheed
Shipyard. The extent of dredging of contaminated sediments and waste under piers at
Todd and Lockheed Shipyards will be determined during remedial design based on
cost, benefit, and technical feasibility;
2) Dredged sediments must be disposed in appropriate confined nearshore disposal
(CND) or confined aquatic disposal (CAD) facilities. Appropriate CND or CAD sites
will be selected during remedial design. If suitable CND or CAD sites are not
identified, dredged sediments must be taken to an appropriate upland disposal facility.
Any dredged material which is predominately shipyard waste must be disposed in a
solid waste disposal facility. Sandblast grit may be recycled as feedstock for cement
production;
3) After dredging, all remaining areas which exceed the chemical and/or biological
SQS must be capped with a minimum two feet of clean sediment. The cap will meet
the SQS cleanup objective by isolating remaining contaminants and preventing release
of these contaminants to the environment. The cap is also intended to be protective of
any future cleanup goals for TBT and PCB bioaccumulation by eliminating the
exposure pathways associated with residual concentrations of.these contaminants. The
cap may require armoring with gravel or small rocks if analyses conducted during
remedial design demonstrate that armoring is necessary;
4) Dredging and capping must be conducted with the objective of creating a flat
surface out to the boundary of the Shipyard Sediment OU to minimize the potential
for recontamination of the cap by resuspended contaminated sediments from other
sources. Dredging, capping and disposal methods must also minimize adverse impacts
to the existing habitat. In particular, the selected dredging and disposal methods shall
minimize the release and resuspension of contaminated sediments to the environment.
To the extent practicable, the marine habitat in the Shipyard Sediment OU must also
be restored to its most productive condition; and
5) Long-term monitoring of contaminant concentrations in the cap, and monitoring of
cap thickness, must be periodically conducted. Long-term maintenance of the cap,
which involves adding supplemental clean sediment to the cap, must periodically be
performed to maintain the cap at a minimum 2-foot thickness. Future maintenance
dredging in the Shipyard Sediment OU would be allowed only if it maintains the
protectiveness of the selected remedy.
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The estimated volume of sediment to be dredged at Todd Shipyards is 116,000 cubic yards,
and approximately 80,000 cubic yards of clean sand would be needed for the cap. The
estimated volume to be dredged at Lockheed Shipyard is 18,000 cubic yards, and the
estimated volume of clean sand required for the cap is about 11,000 cubic yards. The
estimated cost of the selected remedy is based on the assumption that all dredged sediment
can be placed in a CND facility. The estimated cost to design and implement this remedy at
Todd Shipyards is $4.5-6.9 Million (M), with an additional cost of about $1.0 M for the first
ten years of cap monitoring and maintenance after construction is complete. The estimated
cost to design and implement this remedy at Lockheed Shipyard is $1.5 M, with an
additional cost of about $0.5 M for the first ten years of cap monitoring and maintenance. It
is estimated that it would take approximately 28-34 months to design and implement the
selected remedy at Todd Shipyards, and 22-28 months to design and implement this remedy
at Lockheed Shipyard.
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 to the
maximum extent practicable. The statutory preference for treatment will be satisfied by
evaluating during remedial design the technical feasibility, implementability, and cost-
effectiveness of physical separation technologies to separate sandblast grit from dredged
sediments.
Because this remedy will leave some hazardous substances on site above cleanup goals, a
review of the site and its remedy will be conducted within five years after initiation of the
remedial action to ensure the remedy continues to provide adequate protection of human
health and the environment.
Chuck Clarke D
Regional Administrator, Region 10
U.S. Environmental Protection Agency
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DECISION SUMMARY
RECORD OF DECISION
SHIPYARD SEDIMENT OPERABLE UNIT, HARBOR ISLAND,
SEATTLE, WASHINGTON
A. INTRODUCTION
The Shipyard Sediment Operable Unit (OU) consists of nearshore sediments at the Todd and
Lockheed Shipyards, which contain shipyard hazardous substances and wastes. The Shipyard
Sediment OU is within the Harbor Island Superfimd Site (Site), in Seattle, King County,
Washington. The Site was listed on the National Priorities List (NPL) in 1983, due to the
release of lead from a secondary lead smelter on the island, as well as the release of other
hazardous substances from other industrial operations on the island. A Remedial Investigation
(RI) and Feasibility Study (FS) of Harbor Island sediments was initiated by the United States
Environmental Protection Agency (EPA) in 1991, pursuant to the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980, 42 U.S.C. § 9604, as
amended, (CERCLA).
The Site has been divided into five OUs: 1) the petroleum storage tank facilities OU, 2) the
Soil/Groundwater OU, 3) the Lockheed Shipyard OU, 4) the Shipyard Sediment OU, and 5)
the Waterway Sediment OU. EPA is the lead agency for the Lockheed, Shipyard Sediment,
Waterway Sediment, and Soil/Groundwater OUs. A cleanup action was selected for the
Soil/Groundwater OU in a Record of Decision (ROD) issued in September 1993. A cleanup
action was subsequently selected for the Lockheed Shipyard OU hi a ROD issued in June
1994. EPA intends to issue a ROD for the Waterway Sediment OU after further studying
these sediments. This decision document addresses only the Shipyard Sediment OU.
EPA has designated the Washington Department of Ecology (Ecology) as the lead agency for
the petroleum storage tank OU because the primary contaminant there is petroleum, which is
excluded from CERCLA but is a specifically included hazardous substance under the State's
Model Toxic Control Act (MTCA). A cleanup decision for the petroleum storage tank OU is
expected to be made by Ecology in late 1996.
B. SITE NAME, LOCATION, AND DESCRIPTION
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 (Figure 1). The island is man-made and has been used for industrial purposes
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SEATTLE
North Area
East
Waterway
West
Waterway
Kellogg
Island
Vicinity Map
UR
1
u«, JOB NUMBER: 400042-46-2110 DATE: August 1994
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since about 1912. The island is approximately 430 acres in size and is bordered by the East
Waterway and West Waterway of the Duwamish River and by Elliott Bay to the north.
Major features of Harbor Island, including the locations of the Todd and Lockheed
Shipyards, are shown hi Figure 2.
C. SITE HISTORY
Prior to 1885, the area which is currently Harbor Island consisted of tideflats and a river
mouth delta with some piling-supported structures. Initial construction of the island began
between 1903 and 1905 when dredging of the East and West Waterways and the main
navigational channel of the Duwamish River 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 industrial activities. Major activities have
included ocean and rail transport operations, bulk petroleum storage and transfer, a
secondary lead smelter, metal fabrication, and shipbuilding and repair. Warehouses,
laboratories, and office buildings also have been located on the island.
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 ambient
air concentration of lead exceeded the federal standard for lead of 1.5 /Kg/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 National Priority List (NPL) in 1983.
In 1985, Ecology performed a preliminary investigation of the Site to further define the
nature and extent of contamination on the island. This investigation, and subsequent
investigations, revealed numerous types of contaminants in the soil including: cadmium,
chromium, arsenic, copper, zinc, mercury, polycyclic aromatic hydrocarbons (PAHs),
polychlorinated biphenyls (PCBs), and petroleum products. A summary of enforcement
activities conducted by EPA in regard to cleanup actions for the Soil/Groundwater and
Lockheed Shipyard OUs is provided in the RODs for these two OUs.
An initial investigation of marine sediments around Harbor Island was completed by EPA in
1988 as part of the Elliott Bay Action Program (EBAP). The nature and extent of
contamination in Harbor Island sediments was characterized in an RI Report issued by EPA
hi September 1994. A Supplementary RI conducted by a group of Potentially Responsible
Parties (PRPs) in 1995 further characterized the extent of chemical contamination in Harbor
Island sediments and reported results of biological effects tests conducted on these sediments.
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East
Waterway
Harbor island Site
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D. HIGHLIGHTS OF COMMUNITY PARTICIPATION
CERCLA requirements for public participation include releasing the RI and FS Reports and
the Proposed Plan to the public and providing a public comment period on the these
documents. EPA met these requirements for the Shipyard Sediment OU by placing the RI,
Supplementary RI, and FS Reports hi the public information repository and issuing the
Proposed Plan on October 31, 1995, 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 November 3, 1995. Notice of the 60 day public comment period and the public
meeting discussing the proposed plan were included in the newspaper notice. The public
meeting was held on December 6, 1995, at the EPA Region 10 Office at 1200 Sixth Avenue,
Seattle, WA. Public comments received are located in the Responsiveness Summary section
of the ROD. The remedy selected in this ROD is based on the Administrative Record for this
OU, which is located in the Record Center at EPA's Region 10 Office at 1200 Sixth Avenue,
Seattle, WA.
To date, the most important community relations activities conducted by EPA at the
Harbor Island site have been:
March 1988- EPA updated the 1985 Community Relations Plan.
December 1988- EPA released a fact sheet announcing the beginning of the Remedial
Investigation.
November 1989- A fact sheet is released explaining the work being conducted by the City of
Seattle to clean and sample the storm dram system on the island.
June 23, 1993- EPA releases the Proposed Plan for the cleanup of the Soil/Groundwater
operable unit.
November 3, 1993- EPA releases fact sheet announcing cleanup decision for the
Soil/Groundwater.
April 22, 1994- EPA releases a Proposed Plan summary fact sheet and the Proposed Plan for
cleanup of the Lockheed Shipyard facility.
August 3, 1994- EPA releases fact sheet announcing cleanup decision for the Lockheed
Shipyard.
January 4, 1995- EPA releases fact sheet announcing public comment period on the
Lockheed Shipyard Consent Decree.
August 23, 1995- EPA issues fact sheet announcing public comment period on proposed
amendment to the Soil/Groundwater ROD.
October 31, 1995- EPA releases the Proposed Plan for cleanup of the Shipyard Sediment
OU.
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November 3, 1995- Ad runs in the Seattle Times announcing the public comment period for
the Shipyard Sediment OU.
December 6, 1995- Public meeting on the Shipyard Sediment OU Proposed Plan.
January 11, 1996- EPA issues fact sheet announcing public comment period on the
Soil/Groundwater Consent Decree.
E. SCOPE AND ROLE OF RESPONSE ACTION WITHIN THE REMEDIAL
STRATEGY
./
Contaminated media at the Harbor Island Site consist primarily of soil, groundwater,
petroleum products floating on groundwater, and sediments. The overall remedial strategy for
the Site is to first remediate contaminant sources on Harbor Island, which include soil,
groundwater, and floating petroleum products, before initiating sediment cleanup actions,
because sources on the island could recontaminate cleaned sediments.
The Shipyard Sediment OU includes nearshore subtidal sediments at Todd Shipyards out to
the edge of the steep slopes of Elliott Bay (to the north) and the West Waterway (to the
west), which occur approximately at the minus 42 (-42) foot Mean Low Low Water
(MLLW) contour, as shown hi Figure 3. The Shipyard Sediment OU also includes nearshore
subtidal sediments at Lockheed Shipyard out to the edge of the steep slope of the West
Waterway, which occurs at approximately the minus 36 (-36) foot MLLW contour, as shown
in Figure 4. These sediments are distinct from other contaminated sediments at Harbor Island
because they are predominately contaminated with hazardous substances and shipyard wastes
(primarily sandblast grit) released by shipbuilding and maintenance operations at Todd and
Lockheed Shipyards. Hazardous substances released from these shipyards include copper,
lead, mercury, tributyl tin (TBT), and zinc, which were additives to marine paints. The
Shipyard Sediment OU is selected for the first Harbor Island sediment remedial action
because: 1) sediments in this OU contain the highest concentrations of shipyard hazardous
substances, and 2) hazardous substances in this OU likely are a source of contamination to
other sediments around Harbor Island.
The remedial action selected in this ROD only addresses contaminated sediment hi the
Shipyard Sediment OU. The remedial action selected hi this ROD is intended to be the final
remedy for the Shipyard Sediment OU. EPA intends to further study the remaining
contaminated sediments around Harbor Island to determine if additional remedial actions are
required on these sediments. Any actions required for sediments outside of the Shipyard
Sediment OU will be addressed in a future ROD,
F. SUMMARY OF SITE CHARACTERISTICS
1. Physical Characteristics of the Duwamish River
Harbor Island is situated in a geographic area known as the Puget Lowlands, a trough
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Todd Shipyard
Cleanup Area
Areas to be Remediated
Contour in Feet
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Lockheed Shipyard
Cleanup Area
Areas to be Remediated
Contour in Feet
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characterized by low relief, with glacially shaped bluffs and low rising hills, and a vast area
of intertidal and tidal flats. 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 historical drainage basin of the Duwamish River was approximately 300 percent greater
than it is today, prior to modifications of the river channel morphology and flow.
Discharges prior to the mid-1800s have been estimated at 2,500 to 9,000 cfs, in contrast to
the present average of flow of 1,500 to 1,800 cfs. The sediment of the Duwamish River
typically consists of slightly sandy silt with variable to abundant organic detritus (e.g., wood
fragments). The bottom sediment in the East and West Waterways is dark brown to black
and is characterized as slightly sandy silt in low-flow summer months, and as silty fine sand
during high-flow months. Tidal influence in the lower river alters density gradients and river
flows, affecting the settlement and movement of sediment in the river. Because of this tidal
influence, approximately 80 percent of the Duwamish River suspended sediment load is
deposited upstream of Harbor Island. A portion of the remaining sediment is deposited in the
nearshore areas of the East and West Waterways, and in the Kellogg Island area, which is
about 2 km upstream of Harbor Island.
Transport of suspended and bed sediment in the lower Duwamish River appears to be a
function of complex riverine and estuarine processes. River flows and sediment loads (both
suspended and bedload) from upstream sources vary seasonally. The amount of natural
sediment supplied to the river from upland sources has been limited by anthropogenic
changes to the river, including dam construction and shoreline stabilization. The sediment
supply to the waterways is further depleted by the periodic maintenance dredging of bed
sediment from the turning basin (upriver of Harbor Island), as well as construction of an
upriver sediment trap by the Corps.
Although volumes are postulated to be small by comparison, some of the fine-grained muds
around Harbor Island are supplied by transport processes hi Elliott Bay that carry bed
material into the Duwamish River estuary. Evidence exists for seasonal transport and
deposition of Elliott Bay sediment upriver as far as the turning basin.
2. Ecological Characteristics of the Shipyard Sediment OU
a. Intertidal and Subtidal Habitat
<
The aquatic environment surrounding Harbor Island is part of the ecologically important
Duwamish River estuary. In the last century, development and dredging have severely
reduced intertidal habitats in Elliott Bay and the Duwamish River estuary. Prior to 1895,
Elliott Bay included approximately 2,091 acres of intertidal sand and mudflats. This area has
been reduced to 54.1 acres through filling, dredging, and bulkheading, eliminating most
shallow intertidal habitats. The present shoreline of Harbor Island is generally composed of
riprap, pier aprons, or sheet piling.
The Shipyard Sediment OU is mostly a shallow subtidal habitat, with a small amount of
intertidal habitat. Sediment in this area reflects riverine inputs as well as intrusion of bay
sediment. The natural sediment in the Shipyard Sediment OU is composed of organic detritus
and sand which is dark brown to black. The shallow subtidal habitat within the slips of Todd
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Shipyards is regularly disturbed by propeller wash, which disrupt colonization and succession
of benthic and epibenthic organisms.
b. Intertidal and Shallow Subtidal Biota
The intertidal and subtidal habitat of the Shipyard Sediment OU supports diverse biota,
including polychaetes, bivalves, gastropods, ostracods, and amphipods. In general, subtidal
macroinvertebrate populations show weak seasonal trends with peaks in abundances in
summer and early fall. Stress-tolerant species were found to be abundant in sediment samples
collected from the shipyard sediments during the EBAP investigation. Such species are able
to adapt to organic enrichment, changes in salinity, physical disturbance, and chemical
contamination. In general, high silt and clay content in the sediment and periodic fast
currents tend to preclude long-term stable populations of infaunal filter-feeding species.
Deposit-feeding polychaetes, including the cirratulid Tharyx multifilis and members of the
families Capitellidae, Maldanidae, Spionidae, and Paraonidae, tend to be numerically
dominant. The most abundant clam species are Axinopsida serricata and Macoma
carlottensis.
c. Fish
The Duwamish estuary is home to migratory and resident fishes. Elliott Bay and the
Duwamish River serve as a migratory route and nursery for coho, Chinook, and chum
salmon. The estuary also provides an important osmoregulatory transition zone for out-
migrating juvenile anadromous fish (e.g., salmonids). Steelhead, cutthroat trout, and Dolly
Varden are the most abundant species to use the Duwamish estuary as a migratory route. The
most abundant resident fish are Pacific herring, shiner perch, and several demersal species,
including English sole, Pacific staghorn sculpin, and starry flounder. Twenty nine resident
and seasonal species of demersal fish have been observed in the Duwamish estuary.
d. Marine Mammals
The most common sightings of marine mammals within Elliott Bay are of the harbor seal,
California sea lion, and the harbor porpoise. Little information exists regarding marine
mammal use of the lower Duwamish River, although there have been sightings of marine
mammals in the estuary. Elliott Bay primarily serves as an adult foraging area. It is assumed
that the lower Duwamish River would serve a similar function.
e. Avian Species
The small amount of intertidal habitat in the Shipyard Sediment OU may be occasionally
used by aquatic birds and shore birds. Such aquatic birds may include a number of summer
resident or migratory species of dabbling or diving birds (e.g., horned grebe, hooded
merganser, gad wall, wigeon, common murre). Shore birds may include dowitcher, dunlin,
yellowlegs, and sandpipers.
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3. Contamination Sources for the Shipyard Sediments
Sources of contamination on Harbor Island which have potentially contaminated sediments in
the Shipyard Sediment OU include: public and private storm drams, non-point surface runoff
from contaminated soil, direct waste disposal, floating petroleum product on groundwater,
and contaminated groundwater.
Public storm drains on Harbor Island, owned by the City of Seattle, were cleaned by the City
in 1990 and are no longer considered to be a significant source of contamination to
sediments. Private storm drains on Harbor Island, some of which release permitted industrial
discharges (treated and untreated industrial process wastewater) to the surface water, were
sampled in 1993 by EPA and were found not to contain significant contaminant
concentrations. These private storm drains are therefore not considered to be significant
sources of contamination to sediments.
In the past, contaminated surface soil on Harbor Island has been a significant non-point
source to storm drains and surface water. Paving of exposed soil areas over the past two
decades by the City and other entities has caused some reduction in the amount of
contaminated surface runoff. It is expected that the remedies selected for the
Soil/Groundwater and Lockheed Shipyard OUs, which require treatment of petroleum hot
spot soil and asphalt paving for soil contaminated above cleanup levels, will eliminate the
further release of contamination to surface runoff from both of these OUs.
Contamination groundwater from most of the island, except at Todd Shipyards and the
petroleum storage tank OU, have been found to be insignificant. However, floating
petroleum product and associated contaminated groundwater at Todd Shipyards is considered
to be a source of contamination to sediments at the north end of Harbor Island. This source
should be adequately controlled when the remedy selected in the ROD for the
Soil/Groundwater OU, which requires pumping and treating floating product and associated
contaminated groundwater at Todd Shipyards, is implemented.
Shipbuilding and ship maintenance activities at Todd and Lockheed Shipyards on Harbor
Island have resulted in the direct disposal of waste into sediments adjacent to these shipyards.
Much of the waste is believed to have originated from sandblasting, which is the process
used to remove paint and paint preparations containing copper, lead, mercury, zinc, and
TBT. Todd Shipyards has been an active facility since about 1918 and the Lockheed
Shipyard began operating in the mid-1930's. Direct discharge of waste is no longer an issue
at the Lockheed Shipyard because it is not an active, shipyard. It is intended that direct
discharge of waste at Todd Shipyards will be eliminated through best management practices,
as defined by Washington State solid waste regulations, before the shipyard sediment remedy
is implemented. .
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4. Summary of the Nature and Extent of Contamination
Three independent investigations of Harbor Island sediments have been conducted. The first
was conducted in 1986 during the EBAP, the second in 1991 during the RI, and a third in
1995 during a Supplementary Remedial Investigation. Surface sediment locations sampled
during the EBAP investigation, the RI, and the SRI are all shown in Figure 5. During the
EBAP investigation, contaminants and areas of concern were determined based on
exceedance of Puget Sound Apparent Effects Thresholds (AET). An AET is the contaminant
concentration in sediment above which specific adverse biological effects have always been
observed in Puget Sound studies. Generally, for any one contaminant, different benthic
organisms demonstrate biological responses at different concentrations, leading to a range of
AETs (e.g., for benthic abundance, amphipod acute toxicity, oyster larvae acute toxicity, and
microtox responses). In this investigation, most sediments sampled at Harbor Island exceeded
the lowest AET (LAET). Contaminants which were frequently found to exceed the LAET
value throughout the entire study area were arsenic, copper, lead, mercury, zinc,
poly chlorinated biphenyls (PCBs), low molecular weight poly nuclear aromatic hydrocarbons
(LPAHs), and high molecular weight polynuclear aromatic hydrocarbons (HPAHs).
The EBAP investigation found the highest concentrations of copper, lead, mercury, and zinc,
in nearshore sediments at Todd and Lockheed Shipyards. These contaminants were used for
many years hi marine paints, and were found to be associated with sandblast grit released
from the shipyards, further indicating that the shipyards were the major source of these
contaminants found in the nearshore sediments. Other contaminants found in shipyard
sediments and potentially associated with shipyard activities included PCBs and PAHs. The
highest concentrations of contaminants found in two samples taken at Todd Shipyards, and in
three samples taken at Lockheed Shipyards, and the comparison to the LAET value for each
contaminant, are shown in Table 1.
In order to determine the acute and chronic toxicity to marine organisms of contaminants in
Harbor Island sediments, the EBAP investigation also conducted sediment bioassays and
determined the abundance of major benthic taxa in sediment samples. The results of these
biological tests are summarized in the "Ecological Assessment" section of this ROD.
The RI of Harbor Island sediments was initiated by EPA in 1991. In this investigation
surface (0-2 cm) sediment samples were collected from 96 locations and analyzed for
contaminant concentrations. For the RI, the screening level used to identify contaminant
concentrations of concern was the Sediment Quality Standard (SQS) of the Washington State
Sediment Management Standards. The surface sediment samples collected during the RI
indicated that contaminants exceeding the chemical SQS at Todd and Lockheed Shipyards
were copper, mercury, PCBs, HPAHs, and LPAHs. The highest concentrations of these
contaminants found at Todd (ten samples) and Lockheed Shipyards (six samples), and the
comparison to the chemical SQS for each contaminant, are shown in Table 2. Since there is
currently no cleanup standard for TBT, the highest TBT concentrations (as tin) found at the
shipyards are compared to the Puget Sound Dredge Disposal Agencies (PSDDA) screening
level.
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• SRI sampling station
O EBAP sampBng station
O Rl sampling station
Figure 5. Locations of sediment sampling stations for the EBAP, R|, and SRI
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TABLE 1
EBAP Sediment Contaminant Concentrations (mg/kg, dry weight)
Contaminant (LAET) Todd Shipyards Lockheed Shipyard
Arsenic
Copper
Lead
Mercury
Zinc
PCBs
LPAHs
HPAHs
(85)
(310)
(300)
(0.41)
(260)
(0.13)
(5.2)
(12)
119
2050
550
10
1300
109
273
1674
239
618
1180
0.8
1170
537
316
1453
TABLE 2
RI Contaminant Concentrations (mg/kg*) Exceeding Chemical SQS
Contaminant (SQS)
Copper
Mercury
TBT
PCBs
LPAHs
HPAHs
(390)
(0.41)
(0.03)**
(12)
(370)
(960)
Todd Shipyards
788
4.2
35
141
1928
8574
Lockheed Shipyard
ne
0.47
0.99
14.6
ne
ne
TABLE 3
SRI Contaminant Concentrations (mg/kg*) Exceeding Chemical SQS
Contaminant (SQS)
Arsenic
Copper
Lead
Mercury
Zinc
TBT
PCBs
(57)
(390)
(450)
(0.41)
(410)
(0.03)**
(12)
Todd Shipyards
ne
909
ne
4.6
ne
15
177
Lockheed Shipyard
99
394
651
2.2
1160
1.5
ne
* Metals and TBT (as tin) are in dry weight, organics are organic-carbon
normalized.
ne = no exceedance
** The PSDDA Screening Level {mg/kg, dry weight)
14
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In the RI, subsurface sediment samples were also collected to depths of 4 feet from 8
locations in nearshore areas of Harbor Island and analyzed for contaminant concentrations.
Two of these subsurface cores were located at Todd Shipyards and two were located at the
Lockheed Shipyard. In the subsurface samples taken at the shipyards, arsenic, copper, lead,
mercury, and zinc exceeded their SQS levels at depths up to 4 feet below the surface. In
fact, the concentrations of these contaminants in the subsurface at the shipyards actually
increased with depth, reaching maximum concentrations at depths of 3 or 4 feet below the
surface. These data indicate that copper, lead, mercury, and zinc were released in greater
quantities prior to the mid-1980s when the shipyards began implementing controls to reduce
the release of sandblast grit to the environment.
In February 1995, subsequent to completion of EPA's remedial investigation, a group of
potentially responsible parties (PRPs), under an Administrative Order issued by EPA,
conducted a Supplementary Remedial Investigation (SRI) of Harbor Island sediments to
verify contaminant concentrations in these sediments and to determine if these contaminants
are causing adverse biological effects in benthic organisms. In this investigation, surface (0-
10 cm) sediment samples were collected from a total of 61 locations around the island,
including ten samples collected within the Shipyard Sediment OU. The results of this
investigation showed that contaminants exceeding the chemical SQS at Todd and Lockheed
Shipyards were arsenic, copper, lead, mercury, zinc, and PCBs. The highest concentrations
of these contaminants found during the SRI at Todd and Lockheed Shipyards, and the
comparison to the chemical SQS for each contaminant, are shown in Table 3.
During the SRI, biological effects tests (bioassays) were conducted on sediment samples
collected from 35 stations around Harbor Island. However, the PRPs elected to conduct
bioassays on sediments from only three stations at Todd Shipyards and three stations at
Lockheed Shipyard within the Shipyard Sediment OU. The results of these bioassays are
summarized in the "Ecological Assessment" section of this ROD.
5. Routes of Potential Contaminant Migration in Sediments
Harbor Island shipyard contaminants (copper, lead, mercury, TBT, zinc, PAHs, and PCBs)
all have high affinity for sediment and organic matter found in sediment. However, these
contaminants also bind to suspended particulates and dissolved organic macromolecules.
Depending on the physical and chemical properties of each contaminant, they are also
dissolved in water to a small degree.
When bound to suspended particulates or dissolved in water, these contaminants can be
transported away from the site in the water column. The ultimate fate of contaminants are
dependent on the rate of freshwater flow in the Duwamish River and tidal exchange with
Elliott Bay. Under conditions of low flow (i.e., during the summer months), the majority of
the suspended paniculate matter leaving Harbor Island settles into the sediment in the East
and West Waterways. However, during months of heavy rainfall, a large fraction of the
particulates is transported in a buoyant plume to Elliott Bay, where settlement likely takes
place.
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Sediment-bound contaminants are also transported as bedload, driven by both tidal movement
within the salt wedge, and riverine flows. Mobile bottom sediment tends to settle out in areas
of null current (i.e., the vicinity of the toe of the salt wedge). Under conditions of low flow,
this process could cause bedload sediment around Harbor Island to be transported several
miles up the Duwamish River. Under higher flow conditions, deposition of bedload sediment
extends out into Elliott Bay. The ultimate sink for bedload sediment may be the submarine
canyon that connects to the central Puget Sound basin.
G. SUMMARY OF RISKS FOR THE SHIPYARD SEDIMENT OU
1. Ecological Assessment
Evidence of Historical Biological Impacts
Biological effects data were collected at stations around Harbor Island during the EBAP
study in 1986. In this study, sediment acute toxicity was determined using the amphipod
Rhepoxynius abronius, and chronic toxicity was determined by observing the abundance of
three major benthic taxa, pofychaeta, Crustacea, and mollusca (measured as abundance of
pelecypoda and gastropoda). At one station (NH-03) located near the shoreline on the north
side of Todd Shipyards, the mean amphipod mortality was 94%, which was significantly
higher than mortality measured at the reference station and was the highest mortality
measured at any Harbor Island station. Since the amphipod mortality for NH-03 was 30%
higher than the reference station, this station fails the biological CSL of the Sediment
Management Standards. At this station gastropods were depressed by 94% relative to the
reference station, pelecypods were depressed by 87%, and crustaceans were depressed by
77%. Since the benthic abundance for NH-03 was significantly different from the reference
station and depressed by greater than 50% for two major benthic taxa, this station also fails
the biological CSL for benthic abundance. At another EBAP station (WW-19) located near
the shore on the west side of Todd Shipyards, there was a significant depression in
pelecypods and crustaceans. At this station pelecypods were depressed by 93% relative to the
reference station, and crustaceans were depressed by 65%. Since the benthic abundance for
WW-19 was depressed by greater than-50% for two major benthic taxa, this station fails the
biological CSL for benthic abundance.
Biological effects were also measured at three sediment stations located near the shoreline at
the Lockheed Shipyard (WW-09, WW-11, and WW-12) during the EBAP investigation. At
these stations the mean amphipod mortality was 60%, 41%, and 33%, respectively. The
amphipod mortality for stations WW-09 and WW-11 was significantly higher (P< .05) than
the reference station, and the mortality at station WW-09 was more than 30% higher than the
reference station, which is a failure of the biological CSL. The abundance of pelecypods each
at WW-09, WW-11, and WW-12 was depressed 85%, 90%, and 57%, respectively, relative
to the abundance at the reference station. Since the abundance of pelecypods at each of these
three stations was significantly different and depressed by more than 50% relative to the
reference station, these stations fail the biological SQS for benthic abundance. The abundance
of crustaceans at WW-12 was also significantly different and depressed 81% relative to the
abundance at the reference station. Since the abundance of two major benthic taxa was
16
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depressed by more than 50% at station WW-12, this station also fails the biological CSL for
benthic abundance.
Evidence of Ongoing Biological Impacts
A mussel bioaccumulation study conducted during the RI demonstrated that bioaccumulation
of contaminants and adverse biological effects occurred in mussels placed at stations located
near the shoreline at Todd and Lockheed Shipyards. Caged mussels were suspended 1 meter
above contaminated sediments for 80 days at 12 nearshore locations at Harbor Island,
including at Todd and Lockheed Shipyards. The results of this study demonstrated that the
highest bioaccumulation of copper and zinc, and the second highest bioaccumulation of TBT,
occurred at a station located at Todd Shipyards. The slowest juvenile mussel growth rates
also occurred at this station. Relative to the reference station, high bioaccumulations of
copper, lead, and TBT, occurred at a station next to the Lockheed Shipyard in the West
Waterway, arid a significant decrease in mussel growth rates also occurred at this station.
This study indicates that contaminants in the shipyard sediments bioaccumulate in mussels
and are associated with adverse biological effects in these organisms.
Two acute and one chronic biological tests (bioassays), according to the requirements of the
Sediment Management Standards, were conducted on sediments from six stations within the
Shipyard Sediment OU during the SRI. Of these six stations, three (NS-09,-10,-14) were
located in nearshore sediments at Todd Shipyards, and the other three (WW-12,-13,-18) were
located in nearshore sediments at Lockheed Shipyard. Two of the stations (NS-09 and NS-14)
at Todd Shipyards failed the biological SQS for juvenile polychaete growth in Neanthes
arenaceodentata. One of the stations (WW-12) at the Lockheed Shipyard also failed the
biological SQS for mortality/abnormality in the bivalve Mytilus galloprovincialis.
2. Human Health Risk Due to Consumption of Seafood
A 1988 EPA report titled, "Health Risk Assessment of Chemical Contamination hi Puget
Sound Seafood", which was based on data collected during the EBAP study, evaluated the
potential adverse human health effects associated with regular consumption of recreationally
harvested seafood from Puget Sound. The most significant human health risk identified in
this study was an elevated cancer risk due to high concentrations of PCBs in fish (English
sole) captured in the Elliott Bay/Duwamish River area. Among the trawling locations
sampled for English sole in this area, two of them were immediately adjacent to the Shipyard
Sediment OU. While the results of this study are not specific to the Shipyard Sediment OU,
it is likely that high concentrations of PCBs in sediment at Todd Shipyards contribute to the
elevated cancer risk identified in this study.
Contaminant Screening
The contaminants of concern for this seafood risk assessment were selected based on the
following criteria: 1) high persistence in the aquatic environment, 2) high bioaccumulation
potential, 3) high toxicity to humans, 4) known sources on contamination hi the area, and 5)
high concentrations hi previous samples of seafood from the area. Contaminants of concern
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identified in this study included: lead, cadmium, mercury, arsenic, HPAHs, PCBs, alpha-
hexachlorohexane, and DDT.
Exposure Assessment
Risks were estimated for a subsistence fisherman consuming average quantities of seafood
(12.3 grams fish, 1.1 grams shellfish, and 0.029 grams seaweed per day), and high quantities
of seafood (95.1 grams fish, 21.5 grams shellfish, and 20.3 grams seaweed per day).
Mean contaminant concentrations and the average consumption rates for various categories of
seafood were used to estimate average lifetime doses for contaminants of concern. The upper
95 percent confidence limit of mean contaminant concentrations in seafood and the high
consumption rates for seafood were used to estimate high lifetime doses for each
contaminant.
Toxicity Assessment
The dose-response variables used in this risk assessment were potency factors for carcinogens
and reference dose (RfD) values for non-carcinogens. The carcinogenic potency factors used
in this study were typically the upper 95 confidence limit of slope of the linearized multistage
model. The RfDs used were the estimated single daily chemical intake rate which would
cause no adverse health effects if ingested over a lifetime. Both carcinogenic potency factors
and RfD values used in this assessment were taken from EPA's Integrated Risk Information
System (IRIS), dated 19.87.
Risk Characterization
The average risk from consumption of Elliott Bay fish was found to be 3 in 10,000 (3.0E-
04), and high risk was found to be 4 in 1,000 (4.0E-3). Both these risk levels exceed the
acceptable excess cancer risk of 1 in 10,000 (l.OE-04) identified in the National Contingency
Plan (NCP). The risk levels for consumption of Elliott Bay fish were among the highest
found anywhere in Puget Sound and were driven by the high concentrations of PCBs in fish
caught in the upper Duwamish River and around Harbor Island. In particular, fish caught at
trawling locations in the West Waterway and North Harbor Island area, immediately adjacent
to Todd Shipyards, had tissue concentrations of PCBs which were among the highest in this
study area. The mean concentrations of PCBs in fish tissue were 460 ug/kg for the West
Waterway, and 350 ug/kg for the North Harbor Island area. In comparison, the mean
concentration of PCBs hi fish tissue at the reference station was 5.4 ug/kg.
Since English sole are migratory and feed over a large area during their lifetime, the results
of this seafood risk assessment cannot be used to identify specific sediment sources
responsible for the PCBs detected in English sole. However, it is likely that the high
concentrations of PCBs in sediments at Todd Shipyards contribute to the elevated cancer risk
identified in this study.
In addition to the seafood risk assessment, an additional human health exposure pathway was
evaluated in the RI. This pathway, which was direct contact with and accidental ingestion of
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contaminated sediment by tribal fishermen while pulling up fishing nets, was found to be an
insignificant human health risk.
3. Uncertainty Analysis
a. Uncertainties in Analytical Data
Uncertainties in analytical results directly influence uncertainties associated with final risk
calculations. All analytical results, not only those flagged as "estimated" during the
validation process, possess an inherent variability. This variability or uncertainty is
dependent upon the sample matrix, analytical method, and the particular analytical laboratory
performing the analysis. Homogeneous samples (i.e., sediment with uniform grain size and
water content) typically exhibit higher precision than relatively heterogeneous sediment.
A variability of minus 50 to plus 100 percent is not unreasonable for samples containing
contaminants at concentrations less than the contract-required quantitation limit. For samples
containing higher concentrations of contaminants, relative percentage differences between
duplicates of 35 percent for sediment are considered acceptable.
b. Toxicity-Related Assumptions
The major site-specific uncertainty relating to potential human health risks pertains to the
carcinogenicity of PCBs. The cancer slope factor for all PCBs is derived from a chronic
rodent bioassay of Aroclor-1260. However, the highly chlorinated PCB mixtures such as
Aroclor-1260 are more potent than the lower chlorinated mixtures (e.g., Aroclors 1254 and
1248). Consequently, using the slope factor for Aroclor-1260 to evaluate Aroclors 1248 and
1254 is expected to overestimate the excess cancer risk estimates associated with these lower
chlorinated PGBs. The EBAP and RI studies referenced in this ROD measured only total
PCBs, and did not determine concentrations of individual PCB Aroclors in sediment or fish
tissue.
H. CLEANUP OBJECTIVE AND SEDIMENT CLEANUP STANDARDS
The Shipyard Sediment OU includes nearshore sediments at Todd and Lockheed Shipyards
which contain hazardous substances and shipyard waste (primarily sandblast grit) released
from these shipyards. Shipyard hazardous substances include: copper, lead, mercury, TBT,
and zinc, which were additives to marine paints used at the shipyards. Other hazardous
substances potentially associated with shipyard activities include PCBs and PAHs. Evidence
for adverse effects in benthic organisms due to contaminants in .the Shipyard Sediment OU
was initially demonstrated by bioassays and benthic abundance studies conducted during the
EBAP investigation. Adverse benthic effects in the Shipyard Sediment OU were also
demonstrated by bioassays conducted during the SRI. The RI mussel study results further
indicate that copper, lead, zinc, and TBT in the shipyard sediments are biologically available
and bioaccumulate in mussels, causing adverse biological effects in these organisms. Actual
or threatened releases of hazardous substances from the Shipyard Sediment OU, if not
addressed by implementing the remedy selected in this ROD, may present an imminent and
substantial endangerment to human health and the environment.
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Since the Shipyard Sediment OU is part of a ecologically rich and diverse estuarine habitat
where juvenile salmonid feed, the cleanup objective for this OU is to reduce concentrations
of hazardous substances to levels which will have no adverse effect on marine organisms.
Chemical and biological cleanup standards which will meet this objective are contained in the
Washington State Sediment Management Standards, which are the primary applicable or
relevant and appropriate requirements (ARARs) for the Shipyard Sediment OU. The
Sediment Management Standards define two levels of chemical and biological standards. The
more stringent level, the "Sediment Quality Standard" (SQS), is the sediment cleanup
objective and corresponds to a sediment quality which has no acute or chronic adverse effects
on marine organisms. In other words, contaminant concentrations below the chemical SQS
are not expected to cause adverse biological effects in marine organisms. The less stringent
level, the "Cleanup Screening Level" (CSL), is the level above which minor adverse effects
always occur in marine organisms. The biological standards are based on results of biological
tests which demonstrate adverse effects in benthic organisms which dwell in sediments. If
both biological and chemical data are obtained at a site, the biological data determine
compliance with the Sediment Management Standards.
According to the Sediment Management Standards, sediment cleanup standards are
established on a site-specific basis (WAC 173-204-570). The site-specific standard must be
between the SQS, which is the cleanup objective, and the CSL, which is also known as the
minimum cleanup level (MCUL). Criteria to be considered in the selection of a site-specific
standard include technical feasibility, cost, and environmental benefit. The approach used to
select the site-specific standard for the Shipyard Sediment OU was to determine the
difference in costs and environmental benefits of technically feasible general response actions
which achieve the SQS and the MCUL. There are three possible results of this type of
evaluation. If neither costs nor benefits are significantly different between response actions
which achieve the SQS and the MCUL, the SQS should be selected as the cleanup standard.
If greater benefits are gained by achieving the SQS but costs are not significantly different,
the SQS should also be selected as the cleanup standard. Finally, if costs are significantly
greater to achieve the SQS but benefits are not significantly different, the MCUL should be
selected as the cleanup standard.
The only feasible response action which would achieve the MCUL is to dredge to the CSL.
The three feasible response actions which would achieve the SQS include: 1) dredging to the
SQS, 2) capping contaminated sediments in place without dredging, and 3) dredging to the
CSL and then capping (referred to as "dredging and capping"). The net environmental benefit
of each method was qualitatively evaluated and ranked as either "low", "medium", or
"high". Capping without dredging to achieve the SQS would likely result in a future release
of contaminants which exceed the CSL if cap erosion occurs. Because cap erosion could
result in the future release of contaminants exceeding the CSL, this method was ranked
"low" for environmental benefit and was eliminated from further evaluation. Dredging to
achieve the CSL was ranked "medium" for environmental benefit because remaining
contaminants between the SQS and CSL are exposed to the environment and capable of
causing minor adverse biological effects. Dredging to achieve the SQS was ranked "high" for
environmental benefit because all contaminants of concern are removed from the
environment. "Dredging and capping" was also ranked "high"
because contaminants remaining after dredging to the CSL are isolated from the environment
by a clean cap.
20
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The estimated costs of the general response actions are based on the cost estimates of the
remedial alternatives identified in this ROD (see, "Description of Remedial Alternatives").
The cost of dredging all sediments exceeding the CSL in the Shipyard Sediment OU,
including long-term monitoring costs, would be approximately $9.0 M. The cost of
"dredging and capping" to achieve the SQS would cost approximately 15% more than
dredging to the CSL. The cost of dredging to the SQS would cost approximately 70% more
than dredging to the CSL.
The costs and environmental benefits of the CSL general response action were compared
with the two SQS general response actions which provide a greater environmental benefit.
Even though dredging to the SQS provides a greater benefit, it is significantly more
expensive than dredging to the CSL, and therefore cannot justify selecting the SQS as the
cleanup standard. On the other hand, "dredging and capping" to achieve the SQS can provide
a greater environmental benefit with only a 15% increase in cost compared to the response of
dredging to the CSL. Since the "dredging and capping" response can achieve a greater
environmental benefit without a significant cost increase, this justifies selecting the SQS as
the site-specific cleanup standard for the Shipyard Sediment OU. Therefore, the SQS is the
cleanup standard for the Shipyard Sediment OU.
According to the RI and SRI chemical data, contaminants which exceed the chemical SQS in
sediments at Todd Shipyards include copper, mercury, PCBs, LPAHs, and HPAHs.
Contaminants which exceed the chemical SQS in sediments at Lockheed Shipyard include
arsenic, copper, lead, mercury, and zinc. Biological effects data collected during the SRI
from Todd and Lockheed Shipyards indicate that two stations failed the biological SQS at
Todd and one station failed the biological SQS at Lockheed. However, in areas not tested
during the SRI, the EBAP biological data indicate that two stations failed the biological CSL
at Todd, and one station failed the biological CSL at Lockheed. Since there are both
chemical and biological data for Todd and Lockheed Shipyard sediments which fail the SQS
cleanup standard, remedial action is required for these sediments.
Contaminants which exceed the chemical SQS in the Shipyard Sediment OU, and their
corresponding numerical SQS and CSL values, are shown in Table 4. The current standards
for PCBs are not intended to be protective of human health from bioaccumulation of PCBs in
seafood. Also, there are no standards for TBT, which is toxic to marine organisms. This
ROD does not establish TBT or PCB bioaccumulation cleanup goals for the Shipyard
Sediment OU. However, EPA intends to establish such cleanup goals in the ROD for the
remaining contaminated sediments at Harbor Island.
I. DESCRIPTION OF REMEDIAL ALTERNATIVES
Numerous technologies and techniques for removing, containing, or treating contaminated
sediments were screened for their effectiveness, implementability, and cost in the Harbor
Island Sediment Feasibility Study. As a result of this screening, three remedial alternatives
which best met these criteria were identified for the Harbor Island sediments. These three
alternatives are: 1) Capping, 2) Dredge to the Chemical SQS, and 3) Dredge to the Chemical
21
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TABLE 4
CHEMICAL SQS AND CSL FOR HARBOR ISLAND SEDIMENTS
CONTAMINANT
Arsenic
Copper
Lead
Mercury
Zinc
PCBj
LPAHj"*
HPAHs***
SQS (mg/kg).
57 dw.
390 dw.
450 dw.
0.41 dw.
410 dw.
12 o.c
370 o.c.
960 o.c
CSL (mg/kg)
93 dw.
390 dw.
530 dw.
0.59dw.
960 dw.
65 o.c
780 ox.
5300 o.c.
d.w. =dry weight
o.c. ^organic carbon normalized
"tow molecular weight polynuclear aromatic hydrocarbons
***hlgh molecular weight polynuclear aromatic hydrocarbons
22
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CSL and Cap. To these three alternatives, a "No Action" alternative was added as a baseline
alternative, against which the three active remedial alternatives could be compared.
At the time of this ROD, adequate information does not exist to select specific disposal sites
for dredged contaminated sediments from Todd and Lockheed Shipyards. Two conventional
disposal options for dredged contaminated sediments are confined nearshore disposal (CND)
and confined aquatic disposal (CAD). Specific CND or CAD sites will be selected during
remedial design after obtaining adequate information on available CND and CAD sites in the
Elliott Bay area. However, since the capacity for CAD is limited in Elliott Bay, CND is
considered the most feasible disposal option for the shipyard sediments, and is the option
used to develop alternative cost estimates in this ROD. To determine a reasonable cost for
disposal in a CND facility, EPA averaged CND costs associated with other dredging projects
in Elliott Bay and Commencement Bay. This average CND cost was determined to be about
$30 per cubic yard of sediment. Independently, Todd Shipyards conceptually designed a
CND facility which could be constructed at one end of the slips which Todd owns on the
West Waterway. Todd's cost estimate for disposal in this on-site CND facility was about $16
per cubic yard. Since Todd's on-site CND facility cost is significantly less than EPA's
estimated average cost for CND, the cost estimates for Todd Shipyards' alternatives are
shown as a range of cost. The lower end of each cost range is based on the estimated cost of
disposal in the proposed on-site CND facility, and the higher end of the range is based on the
average CND cost.
The cost estimates for Alternatives 2, 3, and 4 do not include the cost of dredging under-pier
sediments because the cost, the environmental benefit, and effect on pier stability of dredging
under-pier sediments has not been determined. In particular, the cost of under-pier dredging
is strongly dependent on site-specific conditions and could be 5 to 10 times the cost of open-
water dredging. Therefore, the extent of under-pier dredging necessary to meet the cleanup
standard will be determined by EPA during remedial .design. The cost estimates for
Alternative 2 and 4 also do not include the cost of cap armoring because it is uncertain if
armoring will be required until the remedial design is completed. The details of the cost
estimates for each alternative are provided in Appendix B of this ROD.
Alternative 1, No Action
This alternative includes no containment, dredging, or institutional controls to reduce the
exposure to the contaminated sediments. These sediments would remain in place and continue
to act as a source of contaminants to the environment. There would be no further monitoring
of biological effects or sediment contaminant concentrations under this alternative. There
would be no cost associated with this alternative.
Alternative 2, Capping
This alternative consists of capping the shipyard sediments with up to 4 feet of clean
sediment to contain the underlying contaminants and create a suitable benthic habitat. Prior to
capping, a moderate amount of dredging would be required in the nearshore areas of the
Todd and Lockheed Shipyards to maintain navigation depths and to reduce slopes to a grade
of less than 20%, which would ensure cap stability. The cap may require armoring with
23
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gravel or small rocks to protect it from erosion in areas exposed to ship traffic, dry dock
activities, or natural forces. Long-term maintenance of the cap would be required to assure
the effectiveness of this alternative. This alternative would decrease the water depth in the
slips on the north side of Todd Shipyards and would restrict the size of vessels which could
access these slips.
Dredging may be performed by either a cutterhead/pipeline dredge, watertight clamshell, or a
suction dredge. Depending upon the restrictions to navigation allowable, and the distance to
the disposal or holding area, the dredged sediments may be transported by either a pipeline
or barge. The clean cap would be put in place either by a split-hull barge or by a hydraulic
pipeline. In areas to be capped immediately adjacent and under piers, it would be necessary
to use a pipeline to accurately place the capping material. Dredging and capping would not
be conducted during the period of juvenile sahnonid migration, which typically runs from
April 1 to June 15.
Daily short-term water quality monitoring would be performed during dredging, capping, and
disposal activities to assure that water quality standards are not exceeded. Long-term
monitoring, by bathymetric surveys, would be required to verify cap stability and thickness.
This monitoring would be performed one year after capping, and then periodically. To verify
that the caps provide a suitable habitat for benthic organisms, biennial monitoring for benthic
abundance would be conducted in the-capped areas until it is demonstrated that a stable
benthic community is established. ^
For this alternative, the estimated volume of sediment to be dredged at Todd Shipyards is
45,000 cubic yards and approximately 160,000 cubic yards of clean sediment would be
needed for the cap. The estimated design and construction cost for this alternative at Todd
Shipyards is $3.0-3.9 Million (M). After construction is complete, ten years of cap
monitoring and maintenance at Todd is estimated to cost $1.0 M. The estimated volume to
be dredged at Lockheed Shipyard is 21,000 cubic yards, and the volume of sediment required
for the cap is about 23,000 cubic yards. The estimated design and construction cost for this
alternative at the Lockheed Shipyard is $1.7 M. Ten years of cap monitoring and
maintenance at Lockheed would cost about $0.5 M. It is estimated that it would take
approximately 26-32 months to design and construct this remedy at Todd Shipyards, and 22-
28 months to design and construct this remedy at the Lockheed Shipyard.
Alternative 3, Dredge to the Chemical SQS
This alternative consists of dredging all shipyard sediments which exceed chemical SQS. No
cap would be required in this alternative. Disposal sites for dredged sediments would be
selected during the remedial design after the dredged sediments are characterized and
available disposal sites are evaluated. Dredging and transport of dredged sediments would
occur as described in Alternative 2. Short-term water quality monitoring of dredging and
disposal activities would also occur as described in Alternative 2. This alternative would not
require any long-term- monitoring or maintenance.
Based on RI data, this alternative would require dredging approximately the uppermost 5-7
feet of sediment on the north side and approximately the uppermost 5 feet of sediment on the
west side of Todd Shipyards. At the Lockheed Shipyard, approximately the uppermost 6 feet
of sediment would have to be dredged. For this alternative, the estimated volume of sediment
to be dredged at Todd Shipyards is 205,000 cubic yards, and the estimated design and
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construction cost is $6.4-10.7 M. The estimated volume to be dredged at Lockheed Shipyard
is 32,000 cubic yards and the estimated design and construction cost is $2.0 M. Monitoring
for contaminant concentrations in the shipyard sediment areas would be required after
dredging to assure that the cleanup goals are achieved. It is estimated that it would take
approximately 30-36 months to design and construct this remedy at Todd Shipyards, and 22-
28 months to design and construct this remedy at the Lockheed Shipyard.
Alternative 4, Dredge to the Chemical CSL and Cap
This alternative consists of dredging shipyard sediments which exceed chemical CSL and
placing a minimum 2 foot cap of clean sediment to contain remaining contamination and
create a suitable benthic habitat. This cap may require armoring with gravel or small rocks to
protect it from erosion in areas exposed to ship traffic, dry dock activities, or natural forces.
Long-term maintenance of the cap would be required to assure the effectiveness of this
alternative. Disposal sites for dredged sediments will be selected during the remedial design
after the dredged sediments are characterized and available disposal sites are evaluated. This
alternative would maintain present water depth in the slips on the north side of Todd
Shipyards and not restrict the size of vessels which could access these slips. Dredging,
capping, and transport of dredged sediments would occur as described in Alternative 2.
Short-term monitoring of water quality during dredging, capping, and disposal activities
would be required as in Alternative 2. Long-term monitoring and maintenance of the cap
would also occur as described in Alternative 2.
Based on RI data, this alternative would require dredging approximately the uppermost 2-4
feet of sediment at Todd Shipyards and approximately the uppermost 3-5 feet of sediment at
the Lockheed Shipyard. For this alternative, the estimated volume of sediment to be dredged
at Todd Shipyards is 116,000 cubic yards, and approximately 80,000 cubic yards of clean
sediment would be needed for the cap. The estimated design and construction cost for this
alternative at Todd Shipyards is
$4.5-6.9 M. Ten years of cap monitoring and maintenance at Todd is estimated to cost $1.0
M. The estimated volume to be dredged at Lockheed Shipyard is 18,000 cubic yards, and the
volume of sediment required for the cap is about 11,000 cubic yards. The estimated design
and construction cost for this alternative at the Lockheed Shipyard is $1.5 M. Ten years of
cap monitoring and maintenance at Lockheed is estimated to cost $0.5 M. It is estimated that
it would take approximately 28-34 months to design and construct this remedy at Todd
Shipyards, and 22-28 months to design and construct this remedy at the Lockheed Shipyard.
J. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The above four alternatives for the Todd and Lockheed Shipyard sediments were evaluated
using each of the nine criteria outlined in the National Contingency Plan. These criteria are:
Overall Protection of Human Health and the Environment
Compliance with ARARs
Long-Term Effectiveness and Permanence
Reduction of Toxicity, Mobility, and Volume through Treatment
Short-Term Effectiveness
Implementability
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Cost
State Acceptance
Community Acceptance
Overall Protection of Human Health and the Environment
For overall protection of human health and the environment, Alternative 3 (Dredge to the
Chemical SQS), ranks highest because it requires the removal of all contaminated sediments
above the SQS cleanup goals and permanent disposal of the dredged sediments in an
appropriate disposal facility. Alternative 4 (Dredge to the Chemical CSL and Cap), provides
the next highest degree of protection because it requires removal and disposal of the most
toxic sediments (which exceed the chemical CSL) and achieves the chemical SQS by isolating
the remaining contamination under a minimum two-foot thick cap. Alternative 2 (Capping),
provides the least degree of protection because it leaves the most toxic sediments in place and
depends entirely on long-term containment of contamination for protection of human health
and the environment. Alternative 1 (No Action) provides no protection of human health or
the environment.
Compliance with ARARs
Alternatives 2, 3, and 4 all achieve the site-specific cleanup standard, which is the chemical
SQS of the Sediment Management Standards. If properly designed and implemented, these
three alternatives would also comply with other ARARs which apply to dredging, capping,
and disposal of contaminated sediments. Alternative 1 (No Action) does not comply with the
minimum requirements of the Sediment Management Standards. Because Alternative 1 is not
protective and does not comply with ARARs, it was eliminated from further consideration as
a feasible alternative for the Todd and Lockheed Shipyards.
Long-Term Effectiveness and Permanence
Alternative 3 offers the highest degree of long-term effectiveness and permanence because it
requires removal of all sediments exceeding the chemical SQS, which is the level at which
adverse biological effects may begin to occur in marine organisms. Alternative 4 ranks next
because it requires removal and disposal of the most toxic sediments (exceeding the chemical
CSL) which are most likely to cause adverse biological effects in marine organisms.
Alternative 2 offers the least amount of permanence because all contaminated sediment
remains hi place where it may be released to the environment if the cap is damaged or
eroded by natural forces or shipping activity. The long-term effectiveness of Alternatives 2
relies heavily on long-term maintenance of the cap to ensure cap integrity and containment of
underlying contaminated sediment.
Reduction of Toxicity, Mobility, and Volume through Treatment
As originally described in the Feasibility Study, none of the remedial alternatives included
treatment to reduce toxicity, mobility, or volume because it was believed that there were no
available full-scale technologies capable of addressing the complex mixture of contaminants
found in the shipyard sediments. However, after further consideration, it was decided that a
physical separation technology may cost-effectively separate sandblast grit from sediment,
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reducing the volume of dredged material requiring expensive upland disposal. The cost-
effectiveness of physical separation technologies will be further evaluated during remedial
design. Therefore, all three viable remedial alternatives are equally ranked for this criterion.
Short-Term Effectiveness
Alternative 2 offers the highest degree of short-term effectiveness because it involves the
minimum amount of disturbance of contaminated sediments, which will minimize the release
of these contaminants to the environment and the exposure of workers to contaminants.
Alternative 4 provides the next best short-term effectiveness because it requires dredging of
only moderate volumes of sediment with slightly increased possibility of release of
contaminants to the environment and worker exposure. Alternative 3 provides the least
amount of short-term effectiveness because it requires dredging of the largest volumes of
sediment and the greatest potential for release of contaminants to the environment and worker
exposure.
Short-term adverse environmental impacts would result from the implementation of
Alternatives 2, 3, or 4 due to the displacement of bottom dwelling organisms during dredging
and capping. It is expected that this disturbance would be temporary and that marine
organisms would recolonize the new bottom surface in a relatively short time.
Implementability
All three alternatives can be implemented using conventional dredging and capping
technology. However, the primary difficulty in implementing any of the alternatives would
be the extent of adverse impact on the operation of Todd Shipyards, which is an active
shipyard facility. The extent of adverse impact to Todd Shipyards can best be measured by
the duration of in-water dredging and capping activities, and by the degree of restrictions
placed on the future use of the facility by each alternative. In terms of in-water activities, it
would take approximately 19 weeks of in-water activities to implement alternative 2,
approximately 5 weeks to implement alternative 3, and approximately 12 weeks to implement
alternative 4. In terms of future use of the Todd Shipyards facility, Alternatives 3 would
have the least amount of adverse impact because it would allow for unrestricted maintenance
dredging to deepen the slips on the north side of Todd Shipyards for use by deeper draft
vessels. Alternative 4 would not require a reduction in the size of vessels which could access
the slips, but future maintenance dredging would be allowed only if it maintained the
protectiveness of the remedy. Alternative 2 would decrease the water depth in the slips by up
to four feet by the placement of a cap, and would likely restrict future use of the slips to
vessels smaller than the current maximum size. Based on these considerations of potential
adverse impacts during and after remediation, alternative 3 ranks highest for
implementability, alternative 4 ranks second, and alternative 2 ranks lowest.
Cost
The alternative cost estimates for Lockheed and Todd Shipyards, not including long-term
monitoring and maintenance costs, are shown in Table 5. The cost of disposing dredged
sediments is a major portion of the total cost for alternatives 3 and 4. For the purpose of
estimating alternative costs in this ROD, it is assumed that all dredged sediments are placed
in a CND facility. The cost estimates for Todd Shipyards are a range of costs. The lower
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end of each range is based on disposal in a CND facility at Todd Shipyards, and the higher
end of the range is based on an average of estimated CND costs for dredging projects in
Elliott Bay and Commencement Bay. The cost estimates do not include the costs for cap
armoring, habitat mitigation, or under-pier dredging. The need for these additional actions
will be determined during remedial design.
For the Lockheed Shipyard, the volumes of dredged sediment for Alternatives 2 and 4 are
about the same, resulting in a small cost difference between these two alternatives. However,
the volume of dredged sediment associated with Alternative 3 is about 75% greater that
Alternative 4, which causes the total cost for Alternative 3 to be about 30% greater than the
cost for Alternative 4.
For Todd Shipyards, the volumes of dredged sediment are significantly different for each
alternative, resulting in a large cost differential between each of the alternatives. Alternative
2 is the least expensive, alternative 4 is about 50-75% more than alternative 2 depending on
whether on-site or off-site CND is used, and alternative 3 is about two to three times as
expensive as alternative 2 depending on which disposal option is used.
Table 5
Alternative Cost Estimates ($ M)
Alternative Lockheed Shipyard Todd Shipyards
2 1.7 3.0-3.9
3 2.0 6.4-10.7
4 1.5 4.5-6.9
State Acceptance
The remedial alternatives described in this ROD have been developed in coordination with
Ecology. Ecology believes that the selected alternative is consistent with the Sediment
Management Standards and will provide benefits to the environment and to the public.
Community Acceptance
Several sets of comments were received in response to the Proposed Plan for the Shipyard
Sediments Operable Unit. A summary of these comments and EPA's responses to these
comments appear hi the Responsiveness Summary, Attachment A. None of these comments
recommended selecting an alternative other than the preferred alternative. EPA therefore
retained the preferred alternative as the selected remedy.
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K. THE SELECTED REMEDY
1. Description of the Selected Remedy
Based on CERCLA, the NCP, the Administrative Record, the comparative analysis of the
alternatives, and public comment, EPA has selected Alternative 4, Dredge to die Chemical
CSL and Cap, as the remedy for the Harbor Island Shipyard Sediment OU. Alternative 3,
Dredge to the Chemical SQS, is identified as a contingent remedy if sediment sampling
conducted during remedial design indicates that Alternative 3 provides a better cost-benefit
than Alternative 4.
Alternative 4 was chosen over Alternative 2 primarily because there would be less adverse
effect on the environment if the cap were eroded in the future and underlying contaminants
were released to the environment. In addition, Alternative 4 can be implemented with less
adverse impact on the operation of Todd Shipyards during remediation, and Alternative 4
would maintain present water depth in the slips on die north side of Todd Shipyards and not
restrict the size of vessels which could access these slips.
Alternative 4 was chosen over Alternative 3 because, based on RI data, Alternative 3 would
be about 50% more expensive to implement for the Shipyard Sediment OU dian Alternative
4. Therefore, Alternative 4 would be more cost-effective in protecting human health and the
environment than Alternative 3. However, comprehensive sediment core sampling to be
conducted during remedial design will allow a more accurate estimation of sediment volumes
exceeding both the chemical SQS and CSL. If this sampling indicates, contrary to RI data,
that the volume of sediment exceeding the SQS is not significantly greater than the volume
exceeding the CSL, a cost-benefit analysis will be conducted. This cost-benefit analysis will
determine: 1) the costs of dredging and disposing the volumes of sediment exceeding the
CSL and the SQS, 2) the costs of constructing and maintaining die cap required for
Alternative 4, which would be the cost saved if a cap is not necessary, and 3) the
incremental environmental benefit of dredging to the SQS instead of dredging to the CSL and
capping. Based on the results of this analysis, if Alternative 3 is shown to provide a greater
environmental benefit at an equal or marginally increased cost, Alternative 3 will be
implemented instead of Alternative 4. If the remedy is changed to Alternative 3, EPA will
document this change in the form of an Explanation of Significant Difference.
j
The essential elements of the selected remedy for the Shipyard Sediment OU are:
1) All sediments exceeding the chemical CSL and shipyard waste must be dredged. This
also applies to sediments and shipyard waste in the shipways at Lockheed Shipyard. The
extent of dredging of contaminated sediments and waste under piers at Todd and Lockheed
Shipyards will be determined during remedial design based on cost, benefit, and technical
feasibility;
2) Dredged sediments must be disposed in appropriate confined nearshore disposal (CND)
or confined aquatic disposal (CAD) facilities. Appropriate CND or CAD sites will be
selected during remedial design. If suitable CND or CAD sites are not identified, dredged
sediments must be taken to an appropriate upland disposal facility. Any dredged material
which is predominately shipyard waste must be disposed in a solid waste disposal facility.
Sandblast grit may be recycled as feedstock for cement production;
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3) After dredging, all remaining areas which exceed the chemical and/or biological SQS
must be capped with a minimum two feet of clean sediment. The cap will meet the SQS
cleanup objective by isolating remaining contaminants and preventing release of these
contaminants to the environment. The cap is also intended to be protective of any future
cleanup goals for TBT and PC8 bioaccumulation by eliminating the exposure pathways
associated with residual concentrations of these contaminants. The cap may require
armoring with gravel or small rocks if analyses conducted during remedial design
demonstrate that armoring is necessary;
4) Dredging and capping must be conducted with the objective of creating a flat surface
out to the boundary of the Shipyard Sediment OU to minimize the potential for
recontamination of the cap by resuspended contaminated sediments from other sources.
Dredging, capping and disposal methods must also minimize adverse impacts to the
existing habitat. In particular, the selected dredging and disposal methods shall minimize
the release and resuspension of contaminated sediments to the environment. To the extent
practicable, the marine habitat in the Shipyard Sediment OU must also be restored to its
most productive condition; and
5) Long-term monitoring of contaminant concentrations in the cap, and monitoring of cap
thickness, must be periodically conducted. Long-term maintenance of the cap, which
involves adding supplemental clean sediment to the cap, must periodically be performed to
maintain the cap at a minimum 2-foot thickness. Future maintenance dredging hi the
Shipyard Sediment OU would be allowed only if it maintains the protectiveness of the
selected remedy.
Significant recontamination of the cap required by this remedy is not anticipated because
contaminated sediments deposited on this cap will be mixed with clean sediments hi the top
10 centimeters of the cap through bioturbation (burrowing of marine organisms). In addition,
the periodic addition of clean sediment to the cap, as required by long-term maintenance, is
expected to maintain contaminant concentrations below the chemical SQS.
Dredged material which is predominately shipyard waste will be managed as a solid waste.
Based on the composition of sediment cores collected during the RI, the volume of such
shipyard waste is expected to be a small fraction of the total dredged sediment volume. The
two disposal options for shipyard waste are: 1) it can be disposed in a solid waste disposal
facility, or 2) pure sandblast grit, and grit which can be separated from sediment, can be
recycled as feedstock for cement production. In order to separate sandblast grit from
dredged sediment for recycling, a physical separation technology, such as hydrocycloning,
will be used in the remedy if during remedial design this technology is found to be
technically feasible, practical to implement, and cost-effective.
Subsurface sediment data collected during the RI indicate that the depth to the chemical CSL
near the shoreline at Todd Shipyards is about 4 feet below the sediment surface, and about 2
feet below the surface further out from the shoreline. This subsurface sediment data also
indicate that the depth to the chemical CSL at Lockheed Shipyard ranges from about 3 to 5
feet below the surface. Based on these data, the selected remedy requires dredging
approximately 116,000 cubic yards of sediment at Todd Shipyards and placing approximately
80,000 cubic yards of clean sediment for a cap at that location. The estimated volume to be
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dredged at Lockheed Shipyard is about 18,000 cubic yards, and volume of clean sediment
required for this cap is about 11,000 cubic yards.
The estimated cost of the selected remedy is based on the assumption that the entire area
defined as the Shipyard Sediment OU will be dredged and capped out to the steep slopes of
either Elliott Bay or the West Waterway. The cost estimate for the selected remedy also
assumes that all dredged sediments can be placed in a CND facility. The estimated cost to
design and construct this remedy for Todd Shipyards is $4.5-6.9 M. After construction is
complete, ten years of cap monitoring and maintenance at Todd Shipyards is estimated to
cost $1.0 M. The estimated cost to design and construct this remedy for the Lockheed
Shipyard is $1.5 M. The cost often years of cap monitoring and maintenance at Lockheed
Shipyard is estimated to be $0.5 M. These cost estimates do not include the costs of habitat
mitigation, under-pier dredging, or cap armoring. The need for these additional actions will
be determined during remedial design.
It is estimated that it would take approximately 28-34 months to design and construct the
selected remedy at Todd Shipyards, and 22-28 months to design and construct this remedy at
Lockheed Shipyard. Dredging activities will take approximately 3 weeks at Todd Shipyards,
and 1 week at Lockheed Shipyard. Capping activities will take approximately 9 weeks at
Todd Shipyards, and 2 weeks at Lockheed Shipyard. EPA will consider the impact on
operations at Todd Shipyards when establishing the schedule for remedial action at Todd
Shipyards.
Source Control Prior to Remedial Action
The first step of the remedy is to ensure that source identification and source control have
been adequately implemented at Todd and Lockheed Shipyards. Source control is
implemented to eliminate or reduce, to the extent practicable, the release of contaminants to
the marine sediments, such that sediments are not recontaminated after remediation. Source
control includes the application of regulatory mechanisms and remedial technologies to be
implemented according to applicable or relevant and appropriate requirements (ARARs),
including the application of all known, available, and reasonable methods of treatment
(AKART) for NPDES-permitted discharges, as necessary to
achieve and maintain sediment cleanup objectives, and to ensure compliance with
environmental regulations.
Source identification efforts will focus on identifying any potential sources of contaminants
from the shipyards to the Shipyard Sediment OU. Source identification includes an
assessment of all potential pathways (e.g., soil, groundwater, stormwater, storm drain
sediments), as well as any permitted or non-permitted direct discharges related to on-site
practices (e.g., active shipyard work in upland areas, along piers, and in marine ways/dry
docks). Source control efforts will focus on implementing methods to adequately control any
ongoing sources to ensure that sediments will not be recontaminated after remediation.
Source control documentation, including certification that adequate source control efforts
have been achieved such that sediment recontamination is not expected, will be summarized
in a Source Control Report to be submitted by both Todd and Lockheed Shipyards for EPA
approval prior to sediment remediation.
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Monitoring During Remedial Action
Monitoring during dredging, disposal, and capping must be conducted to assure that the
cleanup is constructed as designed, and that there are no unavoidable environmental impacts.
During dredging, bathymetric surveys or other appropriate techniques shall be employed to
verify that dredging occurs to the depths necessary to remove all contaminated sediments
exceeding the chemical CSL. This should include a baseline survey of the targeted dredging
areas, and a post-dredge survey. Monitoring during placement of the cap will verify that the
cap is placed as designed, and that the proper thickness is achieved. In-situ markers,
bathymetric surveys, or other appropriate techniques shall be conducted during capping to
monitor placement location and thickness. Cap thickness will also be verified by sediment
core samples collected immediately after construction.
Water quality monitoring must also be performed during dredging to measure contaminant
release to the water and assure that the marine acute water quality criteria are not exceeded.
This monitoring will consist of grab samples at various depths throughout the water column
and at various distances from the dredge activity. Analyses will include real-time
conventional analyses of dissolved oxygen and turbidity, and chemical analyses for
contaminants of concern in the shipyard sediments.
In-water disposal monitoring must be conducted to verify that sediment disposal is occurring
as designed, and evaluate sediment loss at the disposal site. Positioning equipment on board
disposal barges will be used to verify navigation position prior to disposal. Bathymetric
surveys will then be used to verify where placement occurred on the bottom.
Long-term Monitoring and Cap Maintenance
Long-term monitoring and maintenance of the cap is expected to be performed for a
minimum of 30 years. Techniques such as bathymetric surveys, in-situ markers, side-scan
sonar, or sediment vertical profile camera will be used to verify cap thickness and stability
after the remedy is constructed. This monitoring must be performed one year after capping,
and then periodically, as determined by the stability of the cap. In addition, prop-wash
related erosion should be evaluated by spot monitoring »f limited areas that are exposed to
potential erosion by prop-wash. Spot monitoring should be conducted in areas where berthing
operations occur and in areas where ships and/or tugs navigate close to or over the cap. To
assure that the cap is not recontaminated by other sources, surface grab samples (0-10 cm)
will be collected from the cap and analyzed for contaminants of concern. The frequency of
this type of sampling will be determined during remedial design. To verify that the caps
provide a suitable habitat for benthic organisms, biennial monitoring for benthic abundance
must be conducted in the capped areas until it is demonstrated that recolonization is occurring
at a reasonable rate, and that a diverse benthic community is established comparable to a
suitable reference location.
It is anticipated that an additional 1-foot thickness of clean sediment will need to be added to
the cap every five years to maintain the cap thickness at the minimum 2-foot thickness.
However, long-term monitoring will identify the rate of cap erosion and will determine the
frequency at which supplemental clean sediment must be added to the cap to maintain its
minimum thickness. If the cap is not initially armored, erosion rates determined by long-term
monitoring will be used to reevaluate the need to armor the cap.
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2. Remedial Design Objectives
a. Identify Sediment Contamination Exceeding the CSL and SQS
The area and depth .of sediment exceeding the chemical CSL and SQS throughout the
Shipyard Sediment OU, including the areas under the piers, will be determined by collecting
sediment cores during remedial design. These data will be used to determine the depth of
dredging required in each area, and will also be used to accurately determine the volume of
sediment to be dredged. Each sediment core will be divided into several samples including a
surface sample (0-10 cm), and samples at 2-foot increments to a depth of 10 feet, or until
native sediment is reached. Sediment samples will be analyzed for arsenic, copper, lead,
mercury, zinc, PCBs, and PAHs. Analytical techniques will be sufficiently sensitive to detect
chemical concentrations at or below SQS concentrations. Sediment core samples will also be
visually inspected to identify areas containing significant concentrations of sandblast grit.
b. Conduct Confirmatory Biological Effects Tests
Although not required, confirmatory biological effects tests may be conducted by the
Potentially Responsible Parties (PRPs) during remedial design in order to determine the acute
and chronic toxicity of sediments to marine organisms, and to evaluate potential adverse
effects associated with bioaccumulation of PCBs, TBT, and mercury. The suite of biological
tests which will be allowed include two acute tests and one chronic test as specified in the
Sediment Management Standards (WAC 173-204-315), and alternative biological tests
designed to assess bioaccumulation and associated adverse effects. If the PRPs decide to
conduct biological effects tests, EPA will determine which specific biological tests are
appropriate for the Shipyard Sediment OU after consultation with Ecology. It is anticipated
that the allowed suite of biological tests will be similar to that recently completed by the Port
of Seattle for the Terminal 18 maintenance dredging project in the East Waterway. If
confirmatory biological tests are not conducted, exceedance of the chemical SQS will
determine which areas require remediation.
c. Characterize Dredged Sediments
*-•
Sediment to be dredged will be characterized to predict sediment behavior during dredging
and disposal, and to support the design of a CND or CAD facility. The characterization may
include: leach tests to determine the ability of contaminants to migrate from a the disposal
site, determination of grain size distribution, Atterberg limits, bulk density, shear strength,
total organic carbon, and in situ and post-dredging density/water content. Potential
contaminant migration pathways will also be evaluated, including release of leachate to
surface water during dredging and disposal, and migration of contaminants through
containment materials at the aquatic disposal site.
If it is necessary to dredge sediment which does not exceed the chemical CSL in order to
construct a flat cap, such sediment may be eligible for PSDDA open-water disposal. To
determine if this sediment is suitable for PSDDA disposal, additional tests must be conducted
according to PSDDA guidance, including: core sample densities, compositing strategies,
biological tests to determine sediment toxicity, and biological tests to determine potential
bioaccumulation of contaminants in marine organisms.
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d. Evaluate Armoring of the Cap
The potential for the cap to be eroded as a result of prop wash, dry dock activity, or natural
forces will be evaluated during remedial design. Current velocities will be measured
throughout the areas to be capped and modeling will be conducted to determine if a sandy
sediment cap will experience unacceptable erosion. If it is determined that a sandy cap is not
adequate, methods of armoring the cap, such as using gravel or small rocks, will be
evaluated and the most appropriate method will be used to protect the cap from erosion.
e. Conduct Habitat Inventory
It is important that cleanup activities do not cause additional adverse impacts to the habitat in
the Shipyard Sediment OU, and to the extent possible, contribute to restoration of productive
habitat in this area. In order to accomplish this objective, a habitat inventory of the Shipyard
Sediment OU will be conducted during the remedial design. This inventory will include
evaluation of the physical characteristics of the habitat (e.g., bathymetry, grain size) as well
as biological characteristics of the habitat (e.g., benthic community structure and prey base
use, aquatic vegetation, and salmonid and forage fish use). Land use, structures, and other
attributes of the habitat that may affect its productivity will also be noted. This habitat
inventory will serve as a baseline for evaluating the success of remedial and mitigation
activities carried out for the shipyard sediments.
In order to minimize and mitigate adverse impacts of remediation identified in this ROD,
EPA intends to ask the natural resource trustees for Harbor Island to assist in reviewing the
remedial design. The trustees may also independently develop a habitat restoration plan for
the Duwamish estuary. If such a habitat restoration plan is developed after this ROD is
issued, the relevant criteria in the restoration plan shall be incorporated into the shipyard
sediment remedial design to the maximum extent practical.
f. Evaluate Potential Disposal Sites
At the tune of this ROD, adequate information does not exist on potential CND or CAD sites
in the Elliott Bay area to support the selection of specific disposal sites. The appropriate
disposal sites will be selected during the remedial design after all feasible CND and CAD
sites hi Elliott Bay are evaluated. If the selected disposal sites are within the Harbor Island
Superfund Site, EPA will elicit public comment on the disposal sites through an Explanation
of Significant Differences, which is a modification to the ROD. If the selected disposal sites
are outside of the Harbor Island Superfund Site, the public will be allowed to comment on
the disposal sites through the dredged disposal permit process required under Section 404 of
the Clean Water Act, which is administered by the Army Corps of Engineers.
Criteria which will be used to evaluate potential disposal sites include: location; rate and
extent of groundwater discharge in project area; proximity to Harbor Island; effectiveness in
containing contaminated sediment; impacts to the marine habitat; the potential for habitat
mitigation; implementability; long- and short-term harbor area and aquatic land use impacts,
with consideration to commerce, navigation, and existing business; and cost. Determination
of physical characteristics such as sedimentation rates, current velocities, and bottom depth,
grain size, and a habitat assessment of the potential disposal sites may also be needed to
assist EPA in the selection of the best disposal sites.
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g. Evaluate Physical Separation Technologies
Physical separation methods, such as hydrocycloning, have the potential to separate sandblast
grit, the primary component of shipyard waste, from dredged sediment. If sandblast grit can
be successfully separated from dredged sediment, this sandblast grit could be recycled as
cement feedstock and the amount of dredged material requiring expensive upland disposal
could be reduced. There is also the potential that physical separation could reduce the volume
of dredged sediment requiring placement in a CND or CAD facility. To determine if a
physical separation technology should be used hi the remedy, the technical feasibility,
implementability, and cost-effectiveness of all applicable physical separation technologies will
be evaluated in the remedial design. If a separation technology is found which meets these
criteria, it will be implemented as part of the remedy.
h. Determine the Extent of Dredging Under-Pier Sediments
Adequate under-pier sediment data does not exist to determine the extent of urider-pier
dredging required to achieve the chemical CSL at Todd and Lockheed Shipyards. Also, the
cost of under-pier dredging may be several times more expensive than open water dredging.
Therefore, the cost of dredging to the chemical CSL under piers at Todd and Lockheed
Shipyards will be determined during the remedial design. This cost will be compared to the
environmental benefit gained by dredging to the CSL. If the benefit gained is
disproportionate to the cost of dredging under piers, EPA may select an alternate method for
achieving the cleanup standard in the under-pier sediments. In addition, dredging under piers
may not be feasible if it were to cause the piers to become unstable. To determine the
potential effect of dredging on pier stability, a structural analysis of the piers will be
conducted during remedial design. The results of this structural analysis will be factored into
EPA's decision on the extent of dredging required under the piers.
L. STATUTORY DETERMINATIONS
The selected remedy for the Shipyard Sediment OU will comply with CERCLA Section 121
as follows:
1. Overall Protection of Human Health and the Environment
Long term protection of marine organisms, which are exposed to contaminated shipyard
sediments, is obtained by dredging and disposing all contaminated sediment which exceeds
the chemical CSL and capping the remaining contaminated sediment with a minimum 2 foot
cap of clean sediment. These actions remove the most contaminated sediment from the
shipyard sediments and reduce the mobility of the remaining contamination by containing it
underneath a cap. The selected remedy may also incrementally reduce the overall risk to
human health from consumption of Harbor Island seafood by eliminating sources of PCBs in
the shipyard sediments. PCBs are of concern, from a human health perspective, because of
their ability to bioaccumulate in seafood.
Existing aquatic habitat and biota would be destroyed in areas where dredging occurs.
However, after placement of the cap, the cap will be recolonized by opportunistic species
diat are available as larvae in adjacent habitats! The rate of colonization will be dependent
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upon the time of year when the cap is placed. Larval recruits may be present year round, but
are more abundant in the spring and summer. As organic material becomes incorporated into
the cap, the benthic community will likely diversify with a concomitant increase in overall
abundance. Additional shifts in community composition may occur, as opportunistic species
are displaced by other, more competitive community members. The abundance and diversity
of benthic organisms on the cap will likely reach a maximum in 3 to 5 years, based on
similar capping projects in Commencement Bay.
To protect migrating species of juvenile salmon, the dredging activities will be performed
outside of the fisheries closure period of April 1 through June 15. Tribal fishing areas and
fisheries are located near the areas to be dredged. Therefore, dredging will be performed at
times which minimize the impact on Tribal fishing activities.
Protection to the environment will also be achieved during dredging and disposal by using
methods which minimize the release of contaminants to the surface water. Surface water
samples will be collected during dredging and disposal of sediments to ensure that water
quality standards are not exceeded. Any release of contaminated sediments would be of short
duration and would be minimized by the use of appropriate dredging equipment and
engineering controls. Any activities which cause the water quality standards to be exceeded
would be stopped until appropriate corrective actions were implemented.
The potential for workers to be exposed to contaminated sediment would be short-term and
would pose a low risk. Activities that would results in worker exposer include handling of
dredged sediment, transport of sediment, and disposal of sediment. Protection of workers
during remediation will be achieved through compliance with OSHA and WISHA
requirements, the use of personnel protective equipment, and other safety measures and
engineering controls.
2. Compliance With ARARs
The selected remedy will comply with all chemical, action, and location specific ARARs.
Federal Water Quality Standards, (33 U.S.C. 1251 et seq.; 40 C.F.R. 131)
Ambient water quality criteria have been published as a requirement of the Clean Water Act
in order to protect aquatic organisms and human health. CERCLA requires the attainment of
water quality criteria where relevant and appropriate. Criteria for the protection of marine
aquatic life are relevant and appropriate requirements for discharges to surface water during
sediment remediation.
Washington State Sediment Management Standards (Chapters 43.21C, 70.105D, 90.48,
90.52, 90.54, and 90.70 RCW; Chapter 173-204 WAQ
Numerical and narrative criteria for chemicals and biological effects are specified for
sediment, and are applicable to Harbor Island shipyard sediments. For the Shipyard Sediment
OU, the chemical Cleanup Screening Levels (CSLs) are the levels which trigger a remedial
action. Once a remedial action is required, the chemical Sediment Quality Standards (SQS)
are the long-term cleanup objectives and the CSLs are the minimum cleanup objectives.
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Washington State Water Quality Standards for Surface Waters (Chapter 173-201-045,-
047 WAQ
Narrative and quantitative limitations for surface water protection are provided in these
regulations. Criteria are established for each water classification, including such items as
fecal coliform, total dissolved gas, total dissolved oxygen, temperature, pH, and turbidity.
The criteria do not apply within dilution zones near point sources. However, within dilution
zones, fish and shellfish should not be killed, nor should aesthetic quality be diminished. The
requirements for marine water are applicable for discharges to surface water during sediment
remediation.
Washington State Water Pollution Control Act (90.48 RCW), Water Resources Act
(90.54 RCW)
Requirements for the use of all known, available and reasonable technologies (AKART) for
treating wastewater prior to discharge to state waters are applicable to remedial actions
involving discharges to surface water during dredging, disposal, or dewatering activities.
Hydraulics Code Rules on Dredging (Chapter 220-110-130,-320 WAC)
Permits must be obtained from the Department of Fish and Wildlife for any project that may
interfere with the natural flow of surface water. Ori-site actions must achieve substantive
permit requirements.
National Pollutant Discharge Elimination System (40 C.F.R. 122, 125); State Discharge
Permit Program; NPDES Program (Chapter 173-216,-220 WAC)
Conditions to authorizing direct discharges to surface water are specified under 40 CFR 122.
Criteria and standards for discharges are specified in 40 CFR 125. The state of Washington
has been authorized by the EPA to implement the NPDES permit program (Chapter 173-216,
-220 WAC). These requirements are applicable to direct discharges to surface water
conducted as part of the remedial action. Substantive permit requirements would be met for
on-site activities.
Solid Waste Disposal Act (42 U.S.C. 3251 et seq.; 40 C.F.R. 257, 258); Washington
State Minimum Functional Standards for Solid Waste Handling (Chapter 173-304 WAC)
Requirements for the management of solid wastes may be applicable to dredged sediment
which is predominately shipyard waste and to sandblast grit which is separated from dredged
sediment. Such separated sandblast grit may be suitable for recycling as feedstock for cement
production.
Washington State Dangerous Waste Regulations (Chapter 173-303 WAC)
This regulation is applicable to any dredged shipyard waste which is determined to be a
dangerous waste. Such shipyard waste must be treated, stored, and disposed in accordance
with the sections of these regulations. Section 173-303-070 describes the procedures for
testing shipyard waste to determine if it is a dangerous waste.
Clean Water Act, Dredge and Fill Requirements Under Sections 401 and 404 (33 U.S.C.
1251 et seq.; 40 C.F.R. 230, 231; 33 C.F.R. 320-330)
These applicable regulations specify requirements for the discharge of dredged or fill
material to waters of the U.S., including wetlands. Dredge and fill activities, such as will
occur during remediation of the Shipyard Sediment OU, are specifically regulated by
requirements outlined in Section 404. These regulations also provide guidelines for the
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specification of disposal sites, and define permit requirements for dredge and fill operations
which would apply to the remedial action.
Seattle Shoreline Master Plan; State Shoreline Management Act (RCW 90.58)
Filling, dredging, and other remedial activities conducted within 200 feet of the shoreline
will comply with the promulgated substantive requirements of this plan, which was developed
pursuant to the State Shoreline Management Act.
Rivers and Harbors Appropriations Act (33 U.S.C. 403, 33 C.F.R. 322)
Section 10 of this statute requires a permit from the U.S. Army Corps of Engineers for
construction of marinas, piers, and outfall pipes, and for dredging and filling below the mean
high-water line in navigable waters of the United States. Dredging and filling which occur
within the Harbor Island site as part of the selected remedy must meet the substantive
requirements of the permit.
Executive Order 11990, Protection of Wetlands (40 C.F.R. 6 Appendix A)
Applicable to open waters and estuarine intertidal emergent and unconsolidated shore located
in and near the site. Remedial activities must be performed so as to minimize the destruction,
loss, or degradation of wetlands. Mitigation would be performed to ensure that no net loss of
wetlands occurred.
Endangered Species Act of 1973 (16 U.S.C. 1531 et seq.; 50 C.F.R. 200, 402)
Applicable to surface water around Harbor Island which is used as a salmonid migratory
route. Remedial actions must be performed so as to conserve endangered or threatened
species, including consultation with the Department of the Interior.
U.S. Fish and Wildlife Coordination Act (16 U.S.C. 661 et. seq.)
This Act is an applicable requirement because the site surface water is used as a salmonid
migratory route and includes potential use by bald eagles, etc. This act prohibits water
pollution with any substances deleterious to fish, plant life, or bird life and requires
consultation with the U.S. Fish and Wildlife Service and appropriate state agencies.
Items to Be Considered (TBCs)
Additional policies, guidance, and other laws and regulations which will be considered for
the Shipyard Sediment OU remedy include:
Dredge Disposal Analysis (PSDDA), which includes requirements and guidelines for
evaluating dredged material, disposal site management, disposal site monitoring, and data
management.
EPA Wetland Action Plan, which describes the National Wetland Policy and primary
goal of "no net loss".
Water Quality Management Plan, which sets water quality objectives relating to
confined disposal of contaminated sediments.
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Stormwater Management Program, (pursuant to 40 CFR Parts 122-24, and RCW
90.48), which describes Stormwater management objectives which may apply to
stormdrains at Todd and Lockheed Shipyards on Harbor Island.
Puget Sound Estuary Program Protocols (1987), as amended, which provides sample
collection, laboratory analysis, and QA/QC procedures for sampling and analyzing
sediment samples.
Standards for Confined Disposal of Contaminated Sediments (1990), which includes
standards and guidance developed by Ecology for confined disposal of dredged
contaminated sediments.
3. Cost-Effectiveness
The selected remedy provides protection of human health and the environment proportionate
to its costs. Alternative 4, the selected remedy, is more cost effective than Alternative 3 in
protecting human health and the environment. The selected remedy also provides better
protection to human health and the environment, in proportion to its cost, than Alternative 2.
4. Preference for Treatment as a Principal Element
Treatment of contaminated sediment to reduce toxicity or mobility of contaminants was not
considered feasible for the shipyard sediments. Such technologies were eliminated either
because they would not be effective on the mixture of organics and inorganics present in the
sediment, had not been demonstrated at full-scale operation, or were difficult to implement
because they would require additional handling, storage, and processing of a large volume of
contaminated sediment. However, physical separation technology, such as hydrocycloning, is
capable of reducing dredged sediment volume requiring upland disposal. If a physical
separation technology is demonstrated to be technically feasible and cost-effective to use on
the shipyard sediments during remedial design, it will be incorporated into the selected
remedy.
5. 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 used in a cost effective manner for remediation of the Harbor
Island shipyard sediments. The selected remedy provides the best balance in terms of
protection of human health and environment, long-term effectiveness and permanence, short-
term effectiveness, implementability, and cost.
Dredging of the most contaminated sediments and disposal of these sediments in a CND or
CAD facility will permanently confine the contaminants responsible for the highest human
health and environmental risks at this site. Physical separation technology, such as
hydrocycloning, has the potential to reduce the volume of dredged sediment requiring upland
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disposal. Such technology will be evaluated during the remedial design for potential
incorporation into the selected remedy.
M. DOCUMENTATION OF SIGNIFICANT CHANGES
The area of the Shipyard Sediment OU in this ROD is about 25% larger than the area
identified in the Proposed Plan because the outer boundaries of the OU have been expanded
to the steep slopes of Elliott Bay and the West Waterway. At Todd Shipyards the outer
boundary is located approximately at the -42 foot MLLW contour of Elliott Bay (to the
north), and at the -42 foot contour of the West Waterway (to the west). At Lockheed
Shipyard the outer boundary is located approximately at the -36 foot MLLW contour of the
West Waterway. This change is a logical outgrowth of the Proposed Plan and was made
because the sediments within these boundaries are distinct from other contaminated sediments
at Harbor Island because they are predominately contaminated with hazardous substances and
shipyard wastes released by shipbuilding and maintenance operations at Todd and Lockheed
Shipyards.
The cost estimates for remedial alternatives in this ROD are revised from the cost estimates
which appeared in the Proposed Plan because: 1) the 25% increase in area of the Shipyard
Sediment OU increases costs of dredging, capping, and sediment disposal required for each
alternative in proportion to the increase in area and associated dredged sediment volumes,
2) the alternative contingency allowance is reduced from 25% to 10% for each alternative,
reducing alternative cost estimates by about 15%, and 3) alternative cost estimates are based
on disposal of dredged sediments in a CND facility, which is now considered to be the most
feasible and cost effective disposal method for disposing the sediments dredged from Todd
and Lockheed Shipyards.
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APPENDIX A
RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
HARBOR ISLAND SHIPYARD SEDIMENT
RECORD OF DECISION
Overview
From 1903 to 1905, Harbor Island was created from marine sediments dredged from
the Duwamish River. Harbor Island has been used for commercial and industrial activities
including shipping, railroad transportation, bulk fuel storage and transfer, secondary lead
smelting, lead fabrication, shipbuilding and metal plating. Warehouses, laboratories and
office buildings have been located on the island. Approximately 70% of Harbor Island is
covered with buildings, roads or other impervious surfaces.
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.
In 1994, EPA completed a remedial investigation (RI) of Harbor Island sediments. In
1995 a group of Potentially Responsible Parties conducted a Supplementary Remedial
Investigation (SRI) of Harbor Island Sediments. On October 31, 1995, EPA began the public
comment period on the cleanup alternatives for the contaminated sediments at the Todd and
Lockheed Shipyards. The Proposed Plan, as well as the reports of the investigation, were
released for public comment. The preferred remedy in the Proposed Plan is to dredge the
most highly contaminated sediments and cap the remaining contaminants. The dredged
sediments would be contained in an appropriate confined aquatic disposal site.
Background on Community Involvement
As described above, the Proposed Plan for the cleanup of the shipyard sediments at
the Harbor Island Superfund site was released on October 31, 1995. The public comment
period ran from October 31 until January 2, 1996.
As part of the comment period, a public meeting was held on December 6, 1995.
About 5 people attended the meeting. No one gave public comment. A copy of the transcript
is available at the Region 10 Records office in the Park Place Building, 1200 West 6th
Avenue.
Comments received in writing are included in the following summary.
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Comments and Responses
1.- Comment: For the proposed cleanup action, a site-specific cleanup standard must be
defined in consideration of the net environmental benefit, cost, and the engineering feasibility
of different clean up alternatives, according to the provisions of the State Sediment
Management Standards.
Response: The environmental benefits, costs, and feasibility of achieving both the
SQS and the CSL for the Shipyard Sediment OU were estimated in the ROD. After
comparing the cost-benefit of the SQS to the CSL, EPA selected the SQS as the site-specific
cleanup standard. EPA believes that the selection of the SQS as the cleanup standard is
justified because it provides the highest environmental benefit by reducing contaminant
concentrations to levels which have no adverse effects on marine organisms, it is feasible to
achieve the SQS using conventional dredging and capping technology, and the SQS can be
achieved at a minimal cost increase compared to the cost of dredging to the CSL.
2. Comment: Capping aquatic lands of an active shipyard, such as Todd, present unique
logistical concerns. The effects of prop scour, recontamination and future construction
activities on the cap integrity will need evaluation. We ask that EPA consider the long and
short-term land use plans of Todd and Lockheed property in designing the dredge and cap
alternative. All effort must be made to limit the amount of material that may require disposal
on state-owned aquatic land. Cap placement and design must take into account recolonization
and habitat diversity to ensure that a functional habitat will develop.
Response: EPA agrees and will ensure that these concerns will be addressed during
the remedial design.
3. Comment: If a nearshore disposal facility is constructed to contain dredged sediments, a
habitat mitigation site would be required to replace habitat lost for the construction of this
disposal facility. The current cost estimates for the remedial alternatives do not take into
consideration the expense of mitigating for habitat loss due to remedial activities or habitat
destruction due to the creation of a near shore disposal site. In addition, there is a limited
number of areas hi the Elliott Bay/Duwamish River system where mitigation of a near shore
habitat can occur. Therefore, we would like to impress upon EPA the need for integration of
remedial activities and habitat mitigation/restoration in the remedial design.
Response: At a minimum, the remedy will be fully compliant with the requirements
of the Clean Water Act (CWA) Section 404. Also, one of the objectives of the remedial
design will be to ensure that adverse impacts to the existing habitats due to remediation are
minimized. Where required under the CWA Section 404, restoration, in addition to
mitigation for remedial impacts, will be incorporated into the remedial design. If construction
of a nearshore disposal facility is the selected disposal option, potential off-site habitat
mitigation areas will evaluated during the remedial design and the cost of required habitat
mitigation will be determined. The cost of any off-site habitat mitigation will be in addition
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to the current cost estimate for remediation. Prior to completing the remedial design, a
habitat inventory in the shipyard sediments will also be conducted which will serve as a
baseline for evaluating the success of the remedial and mitigation actions.
4. Comment: The Washington Department of Natural Resources leases several parcels of
submerged aquatic lands within the proposed cleanup area and manages several parcels
proposed for use as aquatic disposal sites. The loss of current or future revenue from aquatic
lands at Harbor Island could impact the state's ability to fund habitat enhancement projects
and other activities that benefit aquatic lands. As such, the remedial actions should be
designed and implemented in a manner that allows state aquatic lands to continue functioning
in the interest of the public trust and not preclude future water-dependent uses.
Response: The remedial actions will be designed and implemented in a manner that
allows state aquatic lands to continue functioning in the interest of the public trust. The
selected remedy would not impact navigation or other water-dependent uses because it would
not decrease water depth on submerged aquatic land leased by the Department of Natural
Resources to Todd Shipyards. In fact, over most of the cleanup area, the water depth would
be increased because a minimum of 3 feet of sediment would be dredged and replaced by
only 2 feet of clean sediment for the cap. If future use of these areas requires additional
dredging to increase water depths, such dredging would have to comply with proper
handling, testing, and disposal procedures necessary as required by all applicable state and
federal environmental regulations.
5. Comment: Who will assume responsibility for monitoring and maintaining the containment
cap and aquatic disposal site? What legal tool, consent decree or other, will EPA enter into
with the responsible parties to ensure compliance and protect the state from assuming an
unreasonable financial risk from future cleanup costs?
Response: EPA intends to negotiate a Consent Decree with the Potentially
Responsible Parties (PRPs) which would require these PRPs to monitor and maintain the cap
within the Shipyard Sediment OU and the confined disposal facility in which the dredged
sediments are placed.
6. Comment: The placement of a cap could require land use restrictions and institutional
controls which may limit actions to repair and maintain existing piers or conduct maintenance
dredging. The department (DNR) may be statutorily limited in the types of restrictions it can
place on statetowned lands.
Response: Restrictions on maintenance dredging may be necessary to prevent damage
to the cap. EPA will work with DNR to identify the most appropriate type of restriction on
state-owned lands.
7. Comment: The placement of a nearshore disposal facility in the nearshore area north of
Todd Shipyards would prevent the use of this area by water-dependent uses and may impede
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treaty protected fishing. Future dredging of the West Waterway to accommodate deeper draft
vessels may be impeded by the placement of a confined aquatic disposal site in that
waterway. However, if nearshore disposal facilities are sited at Terminal 91 or Slip 27
(owned by the Port of Seattle), there would be no impact to the current or future water-
dependent uses in the Todd Shipyards area or in the West Waterway.
Response: EPA expects the PRPs to evaluate all potential disposal sites in the Elliott
Bay area during the remedial design, including Terminal 91 and Slip 27.
8. Comment: The preferred alternative appears environmentally protective provided that
adequate source control is achieved for operations at the Todd and Lockheed Shipyards. We
are particularly concerned with the NPDES permitted discharges at Todd Shipyards and
ensuring that sufficient source control has been achieved through the NPDES program.
Response: The selected remedy requires that a Source Control Report be submitted to
EPA which certifies that all potential contaminant sources at Todd and Lockheed Shipyards,
including those covered under NPDES permits, are adequately controlled prior to
implementing the remedy.
9. Comment: In order to verify that a suitable habitat for benthic organisms is available,
periodic monitoring for benthic abundance should be conducted in the shipyard sediments
after placing the cap to ensure that a healthy benthic community is developing. Additionally,
cap placement and engineering design must take into account recolonization and habitat
diversity concerns to maximize the development of on-site habitat function, thus minimizing
the need for off-site mitigation.
Response: Periodic monitoring of the benthic community after placement of the cap is
required by this Record of Decision (ROD). .The design and placement of the cap, including
any required armoring, will take recolonization and habitat diversity into consideration to the
maximum extent practical.
10. Comment: Biological effects data are available from the Supplementary Remedial
Investigation (SRI) and from NPDES baseline sediment monitoring for portions of the area
around Todd Shipyards identified in the proposed plan. One SRI station (HI-NS-14), which
passed the biological criteria of the Sediment Management Standards, has been included
within the Shipyard Sediment Operable Unit (OU). The SRI and NPDES data indicate that a
significant portion of the Todd Shipyards sediment area identified for remediation in the
Proposed Plan complies with the SMS and should not require cleanup according to these
standards. These data demonstrate that collection of additional sediment characterization
information is required before a defensible remediation plan can be established.
Response: The EBAP biological data demonstrated that the highest amphipod
mortality and a decrease abundance in all four major benthic taxa occurred at a nearshore
station at Todd Shipyards. The RI mussel results indicate that the highest bioaccumulation of
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copper and zinc and the slowest growth rate in juvenile mussels also occurred at a nearshore
station at Todd Shipyards. Two SRI stations sampled for biological effects at Todd Shipyards
failed the biological SQS, which is the site-specific cleanup standard for the Shipyard
Sediment OU. EPA believes the EBAP, RI, and SRI biological data, together with the RI
and SRI chemical data for Todd and Lockheed Shipyard sediments, support the decision to
select a remedial action for the Shipyard Sediment OU without collecting additional data
prior to issuing this ROD. However, since SRI biological tests did not provide
comprehensive coverage of the Shipyard Sediment OU, additional biological tests will be
allowed during remedial design to more accurately define the areas which require
remediation.
11. Comment: EPA attempts to support the proposed cleanup action by using the results of a
mussel study described in the RI report. Although copper and zinc were found, in mussels
from the Todd Shipyards area, and juvenile mussel growth was relatively slow in this area,
the data do not provide direct evidence that the sediment was the source of the accumulated
constituents, that the measured growth effects were caused by the sediment, or that the
constituents in the sediment were actually bioavailable.
Response: The shipyard sediment areas were identified for remediation because RI
and SRI sediment chemical data demonstrate that these areas exceeded the chemical CSL for
several contaminants, and because EBAP and SRI biological data demonstrate that several
stations within the Shipyard Sediment OU fail the biological SQS. Furthermore, the RI
mussel study found a strong correlation between sediment contaminant concentrations, tissue
contaminant concentrations, and mussel growth, as stated in this passage from the study:
"By using transplanted mussels, we demonstrated that combining mussel growth,
tissue chemistry, and sediment chemistry was effective in differentiating areas of
contamination and potential bioeffects. . . . We were able to show an association
between toxicity-normalized tissue and sediment concentrations. There was a
statistically significant relationship between mussel growth and both tissue and
sediment chemistry, and mussels accumulated many of the contaminants measured in
sediments."
12. Comment: The need for a separate shipyard sediment operable unit or immediate action
in those areas cannot be supported for the folio whig reasons:
a) EPA is unable to quantify or attribute risk to human health via the most significant
exposure pathway (seafood ingestion) to any specific location around Harbor Island,
including Todd Shipyards,
b) The RI demonstrates that cancer and non-cancer risks to human health by ingestion
of and dermal contact with contaminated sediment are not significant,
c) Available site-specific ecological effects data, if interpreted consistently, do not
justify remedial action hi the Shipyard Sediment OU, and
d) The mussel study results have some acknowledged inherent weaknesses that nullify
their usefulness for preparing a site-specific risk assessment.
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Response: a) Demonstration of an increased human health risk or adverse biological
effects in marine organisms can trigger a remedial action for sediments. Evidence for adverse
biological effects occurring in the shipyard sediments was found during the EBAP study and
the RI mussel study (see response #10). The potential for increased human health risk due to
consumption of Elliott Bay/Harbor Island seafood is documented in the study, "Health Risk
Assessment of Chemical Contamination in Puget Sound Seafood" (Terra Tech, 1988).
Although this risk assessment was not specific to the shipyard sediments, it demonstrated that
high concentrations of carcinogenic contaminants (prirnarily PCBs) in seafood caught around
Harbor Island can cause increased human health cancer risks. Since concentrations of PCBs
are especially high in the sediments at Todd Shipyards, it is likely that these sediments
contribute to the overall elevated human health risk due to seafood consumption.
b) The human health risk due to ingestion and dermal contact with contaminated
sediment was found to be insignificant and was not used to determine areas of remediation.
c) EPA believes that the EBAP biological data and the RI mussel data together
provide adequate preponderance of evidence that contaminants in the shipyard sediments are
associated with adverse biological effects in marine organisms (see responses to #10 and
#11).
d) EPA does not agree that there are weaknesses in the mussel study results which
would nullify their usefulness in assessing adverse biological effects due to sediment
contamination. In fact, the mussel study found a strong correlation between sediment
contaminant concentrations, tissue contaminant concentrations, and mussel growth (see
response to #11).
13. Comment: The proposed plan does not take into account the available information from
the RI and SRI on natural recovery of contaminated sediment areas around Harbor Island.
Incorporation of natural recovery processes into the development of cleanup standards may
significantly reduce sediment areas that exceed the CSLs.
Response: The RI sediment accumulation rate data (Pb-210 profile) from the Todd
Shipyards area were inconclusive and can not be used to determine sediment accumulation
rates. The natural recovery modeling conducted in the SRI Base Level Data Interpretation
Report relies on an optimistic assumption (50% reduction in contaminants hi particulates
from off-site sources) which is not realistic. Without this assumption, there would be no
significant natural recovery over a ten year period (as required by the Sediment Management
Standards) of mercury and PCB, which are two contaminants of primary concern in Harbor
Island shipyard sediments.
14. Comment: Sources of contamination around Harbor Island are not adequately controlled
to justify the immediacy of the proposed plan. Any cleanup of sediment around Todd
Shipyards, if ultimately necessary, should be appropriately integrated with the timing of
cleanup actions in the remainder of the sediment operable unit.
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Response: EPA believes that the primary source of contaminants to the shipyard
sediments is direct discharge of waste as a result of past operations at Todd and Lockheed
Shipyards. As such, the most immediate concern will be to assure that all contaminant
sources at the shipyards are adequately controlled before implementing the shipyard sediment
remedy. The remedy requires that a Source Control Report for Todd and Lockheed
Shipyards be submitted to EPA verifying that all potential contaminant sources at these
shipyards are controlled prior to implementing the remedy. EPA intends to further evaluate
the need for remedial action in the surrounding contaminated Harbor Island sediments.
However, EPA is convinced that contaminants in the Shipyard Sediment OU are associated
with significant adverse biological effects in marine organisms, and therefore, EPA does not
want to delay remediation of the shipyard sediments until a remedial action is selected for the
remainder of the Harbor Island sediments.
15. Comment: As a point of clarification, the highest concentration of PCBs in sediments
reported in the RI is in the East Waterway, not near Todd Shipyards as stated in the
Proposed Plan.
Response: EPA agrees. The second highest concentration of PCBs occurs in the West
Waterway next to Todd Shipyards.
16. Comment: Although it is recognized that the cost estimates provided in the Proposed
Plan and supporting technical memorandum are general and for purposes of alternative
comparison, certain components of the estimates may be high. Two of the assumptions (rapid
sediment settling and no treatment necessary for dredging water) appear unrealistic and
significantly higher costs would result if either assumption turns out to be incorrect.
Sediment disposal costs, which are already a significant component of the cost estimates, are
understated because neither confined aquatic disposal nor nearshore disposal is available now
or in the foreseeable future, and upland disposal is expected to be more costly than identified
in the Proposed Plan due to the lack of potentially available sites near Harbor Island.
Response: If assumptions for sediment settling and treatment for dredged water are
not correct, EPA agrees that costs for these components of the remedy will be higher.
However, EPA disagrees that potential confined aquatic disposal sites are available near
Harbor Island. In the Harbor Island Sediment Feasibility Study, several potential confined
nearshore and aquatic disposal sites were identified. In addition, Todd Shipyard has recently
proposed using a portion of the slips at its shipyard as a site for a confined nearshore
disposal facility. It is EPA's expectation that the PRPs will further investigate and evaluate
these potential sites during remedial design.
17. Comment: The mechanics of dredging will inevitably result in resuspension and
spreading of contaminated sediment if dredging is performed according to the Proposed Plan.
Because the more recent sediment accumulations are less contaminated, the issue of sediment
resuspension during dredging must be seriously evaluated against the perceived benefit of
sediment removal versus natural recovery of contaminated areas.
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Response: It is anticipated that a variety of dredging technologies will be evaluated in
the remedial design. Minimizing the release and resuspension of contaminated sediment will
be a major factor in the selection of the dredging technology which will be used for dredging
hot spot sediments. EPA does not agree that natural recovery will accomplish reduction of
shipyard contaminants within a reasonable timeframe (see response #13).
18. Comment: While EPA acknowledges that there are not enough data at this time to
properly evaluate human health risks, the Proposed Plan nevertheless identifies human health
protection as one of the primary goals of the proposed remediation. It is arbitrary and
capricious for EPA to base a cleanup on human health risk in the absence of sufficient data
to evaluate such risk.
Response: Protecting marine organisms from adverse biological effects is the primary
objective for cleaning up the shipyard sediments. EPA believes that the EBAP biological
effects data and the RI mussel study provide a preponderance of evidence that shipyard
sediments are associated with adverse biological effects. Some protection of human health
may also be achieved by eliminating high levels of PCBs found in sediments at Todd
Shipyards (see response to #12a).
19. Comment: Source evaluation data presented in EPA's Remedial Investigation and
Feasibility Study of the Harbor Island Site, along with more recent data collected as part of
the Supplementary Remedial Investigation, suggest that there are ongoing inputs of
contaminants to the Site which could potentially recontaminate sediments following a
remedial action. There are insufficient data available to conclude that adequate source control
of contamination resulting from resuspension of upstream sediments, discharges from storm
drains and outfalls, and release of bottom paint chemicals from vessels during berthing and
other in-waterway activities, is in place at this time to move ahead with remedial action,
either within the Shipyard Sediments OU or in the marine sediment portion of the Site as a
whole.
Response: Sediment data indicate that most of the contamination found in the shipyard
sediments is due to the direct release of waste containing copper, lead, mercury, TBT, and
zinc from shipyard operations. As such, the most immediate concern prior to implementing
the remedy will be the assurance that potential sources at Todd and Lockheed Shipyards have
been adequately controlled. In regard to other sources:
a) EPA does not regard stormdrains on Harbor Island to be a significant ongoing
source of contamination. All public stormdrains on Harbor Island were cleaned by the City
of Seattle in 1990 and stormdrain catch basins are periodically cleaned by the City. The City
will also be expected to monitor ongoing discharges from these stormdrains under the
requirements of an NPDES permit to assure that ongoing discharges meet water quality
standards and are protective of marine sediments. In addition, EPA sampled all private
stormdrains on Harbor Island and found that there was no significant loading of contaminants
from these drains.
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b) Based on EBAP and RI sediment data, contaminant concentrations in upstream
sediments are generally below the chemical SQS, and are significantly below contaminant
concentrations in sediments around Harbor Island. Therefore, the only contaminated
sediments with the potential to recontaminate the cap in the Shipyard Sediment OU are
remaining contaminated sediments around Harbor Island. EPA is evaluating the need to take
remedial action on these remaining contaminated sediments at Harbor Island, and will issue
its decision in a future Record of Decision.
c) As for release of contaminants from vessels, it is possible that some of the
contamination in Harbor Island sediments is due to hazardous substances in paint chips
released from vessels during berthing and other in-water activities. However, data indicate
that most of the contamination found in the shipyard sediments is due to the direct release of
waste from shipyard operations.
20. Comment: The need for remedial action at the Shipyard Sediments OU, as set forth by
EPA in the Proposed Plan, is apparently based on determinations by EPA that contaminants
present in the shipyard sediments are bioaccumulating in marine organisms at concentrations
which can cause adverse biological effects. Our evaluation suggest that contaminant
bioaccumulation observed hi the caged mussel study was relatively limited and attributable to
ongoing inputs from upland or over-water activities. Transfer of contaminants from surface
sediments does not appear to have been a significant factor contributing to observed
bioaccumulation.
Response: EPA acknowledges that there may be ongoing upstream and over-water
sources of bioaccumulating contaminants. However, EPA does not regard upstream and over-
water sources to be a significant source of ongoing contamination (see response #19). EPA
believes that the contaminants in the shipyard sediments are a likely source of
bioaccumulating contaminants due to a correlation between contaminants in sediments,
mussel tissue, and mussel growth rates (see response #11).
21. Comment: There are a number of critical deficiencies associated with EPA's segregation
of operable units which will substantially limit the overall effectiveness of site-wide
remediation because: a) risk management of contaminated sediments within the Harbor Island
Site is more appropriately addressed on a Site-wide basis, and b) remedial design in either
the channel or nearshore areas will require an understanding of the design approach being
taken in the other sediment areas.
Response: a) The Shipyard Sediment OU is distinct from other contaminated Harbor
Island sediments because it has the highest concentrations of copper, lead, mercury, TBT,
and zinc, all of which are hazardous substances released from the shipyards. The high
concentrations of these contaminants in the Shipyard Sediment OU are likely associated with
the most significant adverse biological effects in marine organisms at Harbor Island. Also,
contaminants hi the Shipyard Sediment OU may be a source of contamination to surrounding
sediments. Establishing the Shipyard Sediment OU as a separate OU, and remediating this
-------
OU, will allow an incremental reduction in the adverse biological effects, and will prevent
further release of contamination from this OU. The concept of reducing risks incrementally
by establishing separate OUs to address unique wastes or hot spots, is consistent with the
definition of an operable unit in the National Contingency Plan (NCP).
b) EPA intends to further study the surrounding Harbor Island contaminated
sediments and determine if these sediments require remediation before completion of the
shipyard sediment remedial design. To the extent practical, the remedy for the shipyard
sediments will be consistent with the remedy required for the surrounding Harbor Island
sediments.
22. Comment: EPA should take a comprehensive and coordinated approach to disposal
facility siting and habitat mitigation so as to meet Superfund objectives throughout Elliott
Bay. Such an approach would result in cost savings through economics of scale and reduced
monitoring requirements.
Response: EPA is working with the Corps of Engineers, Ecology, and other agencies
to identify a multi-user disposal facility in the Elliott Bay area. However, it not anticipated
that a such a multi-user facility, if a suitable site if found in Elliott Bay, would be available
until the year 2001, at the earliest. Since dredging and disposal of the Harbor Island shipyard
sediments could occur as soon as 1998 or 1999, a multi-user disposal facility may not be
available soon enough to receive these sediments.
23. Comment: EPA's Technical Memorandum states that the non-under pier sediments will
be removed hydraulically. We believe that unless a nearshore fill site is the confined disposal
site, mechanical dredging may be the more economical and environmental preferred means of
removal.
Response: The dredging methods will be selected during remedial design based on
criteria which include: minimal adverse impacts to water quality, cost-effectiveness, dredging
depths, and accessibility to dredging equipment.
24. Comment: To effectively remove 3 feet of sediments at the Lockheed Shipyard, the
dredging contractor will need to overdredge up to 1 foot, based on the accuracy of their
equipment. This will increase the estimated dredging volume from 16,000 cubic yards (CY)
to roughly 19,000 CY. If underpier sediments are also impacted, it would be reasonable to
expect a 50 to 80 percent increase in overall removal volumes.
Response: Current estimated dredging depths are conservative but some overdredging
may be required. Such overdredging may increase dredged sediment volume by as much as
15-20%. The extent of dredging under piers will be determined during remedial design after
considering the depth to the chemical CSL under the piers, effects of dredging on pier
stability, the potential environmental benefit of dredging under piers, and the cost of
dredging under piers.
10
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25. Comment: The most cost-effective means to accomplish sediment removal or
confinement of under-pier sediments will vary depending on sediment thickness and extent
beneath the pier, pier construction, and long-term plans for the pier. Currently, there are
four options available, including:
a) Hydraulic dredging between the piling and under the pier,
b) Removing the pier decking, mechanically dredging the sediments, and replacing the
decking,
c) Jetting the sediments from under the pier to open water and mechanically removing the
sediments, and
d) Capping the sediments in place.
Response: All feasible methods of removing or containing contaminated under-pier
sediments, including the above four methods, will be evaluated during the remedial design.
The method which can remove the under-pier sediments most cost-effectively, and minimize
release of contaminants to the surrounding environment, would be selected by EPA after the
evaluation is completed.
26. Comment: We believe that the selection of a preferred alternative is, in fact, premature
pending clarification of Todd Shipyards's future dredging plans. Todd Shipyards may desire
to dredge within the proposed remediation area in order to accommodate larger vessels. It
would seem reasonable to design an alternative which would accommodate future needs and
avoid additional disturbances within the remediated area.
Response: The selected alternative (alternative 4) would not have an adverse impact
on current operations at Todd Shipyards because it would maintain current sediment depths
in the slips and would not require a reduction in the size of vessels which enter these slips.
After the selected remedy is constructed, the only future disturbances of the habitat in the
Shipyard Sediment OU would be periodic maintenance of the cap, which is expected to have
a minor, short-term impact on the habitat. One of the alternatives considered for Todd
Shipyards, Alternative 3, would have required dredging all contaminated sediments above the
SQS cleanup goals and would not have required a containment cap. This alternative was
considered to be the most compatible with future shipyard use because it would allow Todd
Shipyards to service vessels larger than the current maximum size. Based on remedial
investigation data, Alternative 3 is the least costreffective alternative because it would require
dredging a significantly larger volume of sediments than the preferred alternative. However,
Alternative 3 has been identified as a contingent remedy if it is demonstrated to be more
cost-effective than Alternative 4 based on remedial design data.
27. Comment: It appears that the best way to predict what will happen to the remaining
contaminants after capping under Alternatives 2 and 4 is to study core samples of what is
currently in place. It may be that capping the existing sediments without performing any
major excavation is a better, long term, solution than exposing the materials to aerobic
waters that will liberate more metal ions. A preferable scenario is to decompose the organic
11
-------
constituents of the sediment by land fanning followed by suitable additives and anoxic
conditions to promote heavy metal insolubility.
Response: Capping sediments without major excavation was evaluated in Alternative 2
of the Proposed Plan. This alternative was rejected because it leaves the highest levels of
contaminants in place with the potential for future release -to the environment if the cap is
eroded by ship traffic, storms, or other natural forces. This alternative would not work well
at Todd Shipyards where ships are constantly docking and there is a potential for cap erosion
due to prop-wash. Also, capping alone would potentially require restriction on future use of
slips on the north side of Todd Shipyards because it would increase bottom depths in this
area.
Landfarming may work well for decomposing organic contaminants in the sediments
but would require a large open area on the site for several months to spread out and aerate
the sediments. Such an open area is not available on Harbor Island. Also, landfarming has
been demonstrated not to be very effective at decomposing more complex organics such as
PCBs, which are present in the shipyard sediments. As for metals, the shipyard sediments
contain copper, lead, mercury, tributyl tin, and zinc. The use of additives and anoxic
conditions may not be successful in converting all these metals to insoluble forms- Also, this
technique is experimental in nature and has not yet been proven in a full-scale application.
28. Comment: It appears that additional sediment testing of mercury species, concentration,
and bioaccumulation effects may be required to determine the sources of mercury
contamination, the significance of anthropogenic contributions, and the effect upon marine
organisms of the bioaccumulation of sediment mercury.
Response: EPA does not intend to further investigate sources of mercury
contamination because evidence indicates that mercury in Harbor Island sediments comes
primarily from marine paints used on ships. In particular, sediment data indicate that the
highest concentration of mercury in Harbor Island sediments occur at Todd Shipyards. Ship
repair and maintenance activities at Todd Shipyards, which involved removing paint by
sandblasting, were likely the source of mercury found hi sediments at Todd Shipyards.
As for the bioaccumulation of mercury in marine organisms, the mussel
bioaccumulation study conducted during the Harbor Island RI showed that mercury
concentrations in all mussel samples were at or below the detection level, indicating that
mercury does not significantly bioaccumulate in mussels. In addition, benthic bioassay
methods required by the Sediment Management Standards are intended to test for acute and
chronic toxicity due to mercury.
29. Comment: The National Contingency Plan (NCP) requires that EPA identify operable
units during the scoping stage early on in the RI/FS process. The NCP requires that EPA
adequately address source control prior to any active remediation. The NCP also provides
that operable units should not be inconsistent with nor preclude implementation of the final
remedy.
12
-------
Response: a) The NCP does not require that EPA identify operable units during the
scoping stage.
b) Evidence indicates that Todd and Lockheed Shipyards were the most significant
sources of contamination to the shipyard sediments. Sources at these shipyards will be
adequately controlled prior to cleaning up the shipyard sediments (see response to #19).
c) The remedy selected in this ROD will be the final remedy for the Shipyard
Sediment OU. To the extent possible, the remedy for this OU will be designed so that it does
not preclude any appropriate remedies for the surrounding Harbor Island sediments.
30. Comment: Counsel for Todd Shipyards Corporation (Todd) submitted lengthy comments
arguing the Proposed Plan violates the National Environmental Policy Act (NEPA) and is
inconsistent with the National Contingency Plan (NCP), the regulations promulgated by EPA
under CERCLA. Todd noted that the U.S. Army Corps of Engineers (Corps) announced its
intent in December 1995, as a lead agency, to prepare a Programmatic Environmental Impact
Statement (EIS) in accordance with NEPA, to assess the environmental impacts of one or
more multiuser disposal facilities in Puget Sound for the disposal of contaminated sediments.
Todd then argued that until that EIS is completed, any and all dredging and disposal of
contaminated sediments for environmental cleanup, navigational, or other purposes, with
narrow exceptions, should be delayed because it will be inconsistent with, and consequently
undermine, the Corps' effort. Todd stated that "EPA staff have indicated that it may be
2002 before the analysis is complete."
It should be noted that since the submittal of these comments, Todd has proposed
using a portion of the slips it owns in the West Waterway for a confined nearshore disposal
facility. Such a facility could contain all sediments dredged from the Todd Shipyards portion
of the Shipyard Sediment OU. If this disposal facility is implemented, and all indications are
that it should be implementable, off-site disposal of sediments dredged from Todd Shipyards
may no longer be an issue. However, counsel for Todd, indicated that the comments were
not being withdrawn, notwithstanding that issues to which they are primarily addressed seem
likely not to be reached.
Response: EPA believes that Tddd's arguments regarding any alleged violation of
NEPA, or inconsistency with the NCP, are without merit. The establishment of one or more
large multiuser disposal facilities in Puget Sound for contaminated sediments is a joint goal
of the Corps, which is responsible for navigational dredging of navigable waters of the
United States, many of which are contaminated, EPA, the Washington State Departments of
Ecology and Natural Resources, and others in both the public and private sectors, including
the Washington Public Ports Association, who have been meeting and working regularly in a
spirit of partnership to resolve the complex issues facing the kind of multiuser facility the
EIS will analyze for environmental impacts. It should be emphasized that such a multiuser
disposal facility does not exist anywhere in the United States, despite a recognized need in
many areas, including Puget Sound, the Great Lakes, the Mississippi Delta and Gulf of
13
-------
Mexico generally, the Florida Everglades, and East Coast major port cities such as New
York, Boston, and others, which have very large quantities of contaminated sediments and
billions of dollars in water dependent industries. There is no guarantee that funding,
management, technical design and feasibility, siting, environmental, and other issues related
to the realization of one or more large multiuser disposal facilities in Puget Sound or any
other major American waterway be resolved in the next ten, twenty, or even fifty years. At
the very least, operational capacity for such a facility is certain not to occur for several
years.
Todd has argued that cleanup of significantly contaminated sediments adjacent to its
shipyard on Harbor Island, which come from its sandblasting and other shipbuilding
activities, must await the result of what Todd readily acknowledges will be a very lengthy
study, or the hopes and plans of the Corps and others, including EPA, for Puget Sound will
be compromised and undermined. Todd's apparent interest in deferring its cleanup expenses
has led its counsel to argue that NEPA, whose purpose is to evaluate environmental effects
of major federal activities, can be used to block a comparatively small scale, uncomplicated
environmental cleanup under Superfund. It has argued that the dredging and disposal of its
infinitesimal percentage of total Puget Sound contaminated sediments, is not only "directly
contrary" to the grand design of a large multiuser disposal facility, but will "make a mockery
(and) charade" of the public comment process under NEPA, notwithstanding that every
remedial action decision by EPA, including this ROD, has been subject to public comment.
Todd counsel's hyperbole continued in the NCP inconsistency arguments. For
example, it is stated on Todd's behalf that; "Incredibly, the agency's sole rationale for
creating a new operable unit is that remedial action can now proceed within the Shipyard
Sediment Operable Unit because no biological data exist to override the existing chemical
data." This argument makes reference to the Washington State Sediment Management
Standards under which chemical concentration data for contaminants in sediments above
specified levels triggers the need for sediment cleanup action, unless biological data from
such sediments indicates that the chemical concentrations are not having biological impacts
(perhaps, for example, because the contaminants are bound together in a manner which
makes them unavailable to marine organisms in the sediment environment).
As has been described elsewhere above, in 1995, after EPA completed its remedial
investigation of Harbor Island sediments, a group of potentially responsible parties, including
Todd, entered into a Consent Order with EPA to conduct biological testing of many Harbor
Island sediment areas where chemical data EPA had collected indicated cleanup might be
necessary. Todd elected not to perform such biological tests on the sediments next to its
shipyard (which are the subject of this ROD as it would affect Todd) because, as Todd's
representatives told EPA, they did not think the biological tests would remove these
sediments from the areas needing remediation. Todd felt the expense of the biological tests
would be wasted.
14
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Todd may have made this decision not to perform further biological tests because
there are, in fact, biological effects data indicating that adverse biological effects occur in
these sediments. The EBAP investigation revealed two stations at Todd Shipyards which
failed the biological CSL. In addition, two test stations in the area of Todd Shipyards which
were tested by responsible parties in 1995, failed the biological SQS, which is the site-
specific cleanup standard for the Shipyard Sediment OU. Based on the combined EBAP and
SRI biological data, EPA believes there is adequate evidence of adverse biological effects at
Todd Shipyards to include this area in the Shipyard Sediment OU. However, because the
current biological effects data within the Shipyard Sediment OU are not comprehensive, EPA
will allow Todd to conduct additional biological testing during the remedial design phase of
the cleanup to more accurately define sediment areas which requiring remediation.
With respect to other sediments around Harbor Island, as a result of the biological
data collected in 1995, which revealed less biological impact than EPA and Ecology
anticipated, and other factors, EPA has decided more study is needed to determine what
remedial action, if any, should be taken. Ecology, among others, has vigorously urged more
study of bioaccumulation effects of sediment contaminants in the food chain within Puget
Sound, and EPA is evaluating the best ways to address these concerns. There remained,
however, no basis to delay cleanup of the shipyard sediments. Consequently, EPA decided to
make separate operable units for sediments warranting further evaluation before the expense
of remediation would be undertaken, and those where delay for further study was not
warranted. Todd's argument that: "At the risk of stating the obvious, the NCP does not
include 'lack of data* as a rationale for the creation of new operable units or accelerated
cleanup schedules," misstates EPA's rationale. While it may well be understandable that
Todd would like to defer if not eliminate its cleanup costs, EPA finds that no valid argument
has been presented for allowing it to do so.
15
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APPENDIX B
ALTERNATIVE COST ESTIMATE TABLES
-------
Table 1- Northwest Harbor Island Alternative 2- Containment
Description
1.. Nearshore Dredging
A. Dredging
Dredging Mobilization
Transport and Placement (Pipeline)
Dredging. Hydraulic Volume
B. Disposal
Disposal Volume (20% expansion)
Nearshore Disposal
C. Short-term Monitoring
Water Quality Monitoring
Bathymetrlc/Sed. Profile Surveys
2. Nearshore Gapping
A. Cap
Silty Sand
Transport and Placement
B. Short-term Monitoring
Water Quality Monitoring
Surveys
Subtotal Construction Costs (Items 1 and 2)
Engineering Costs ( % of Construction Costs)
Contingency Allowances (% of Construction Costs)
Total Construction Costs
3 Long-term Monitoring
4 Maintenance
Subtotal O&M Costs (Items 3 and 4)
Administrative Costs (% of O&M Costs)
Total O&M Costs
Unit
LS
CY
CY
CY
CY
DAY
LS
CY
. CY
DAY
LS
• '
%
LS
LS
%
Quantity
1
45198
45198
54238
54238
4
1
160022
160022
13
1
15
10
1
1
15
Unit Cost
$300,000.00
i 11.50
I2.00
$30.00
$3,300.00
$35.000.00
: 3.00
! 3.00
$900.00
$35.000.00
$342.974.00
$500.064.60
Cost
i $300.000
$67.797
$90.396
$1.627.128
$13.200
$35.000
$480,066
$480,066
$11.700
$35.000
$3.140.353
$471.053
$314.035
$3.925.441
$342,974
$500.065
! 1843,039
II12JL456
i 1969,494
SUBTOTAL ) 4,894,936
TOTAL PRESENT WORTH VALUE J 4.895,000
The cost of this alternative is highly subject to change based on results from future preremedial design
Investigations. This is provided as a relative measure from which to compare the costs of different alternatives.
-------
Table 2- West Waterway Alternative 2-ContaJnmerrt
Description
1. Nearshore Areas
A. Dredging
Dredging Mobilization/Demobilization
Transport and Placement (Pipeline)
Volume (hydraulic)
-
B. Cap
Silty Sand
Transport and Placement
C. Disposal
Disposal Volume (20% expansion)
Nearshore Disposal
D. Short-term Monitoring - Dredging
Water Quality Monitoring
Bathymetrlc/Sed. Profile Surveys
E. Short-term Monitoring - Capping ' •
Water Quality Monitoring
Bathymetrlc/Sed. Profile Surveys
Subtotal Construction Costs (Items 1)
Engineering Costs ( % of Construction Costs)
Contingency Allowances (% of Construction Costs)
Total Construction Costs
2. Long-term Monitoring
3. Maintenance
Subtotal O&M Costs Items 2 and 3)
Administrative Costs % of O&M Costs)
Total O&M Costs
Unit
LS
CY
CY
CY
CY
CY
CY
DAY
LS
DAY
LS
%
LS
-LS
%
Quantity
1
20512
20512
22791
22791
24614
24614
2
1
2
1
• 15
10
1
1
15
Unit Cost
$300.000.00
! 11.50
! 12.00
! 3.00
!3.oo
$30.00
$3,300.00
$35,000.00
$900.00
$35,000.00
$342.974.00
$113.910.08
Cost
$300.000
! 30.768
! 41 .024
$68.373
$68.373
$738.432
$6.600
$35.000
$1.800
$35.000
$1.325.370
11198.806
S132.537
$1.656.713
$342.974
$113.910
$456.884
$68.533
$525.417
-'SUBTOTAL ! 12,182,129
TOTAL PRESENT WORTH VALUE ) 12,182^000
The cost of this alternative Is highly subject to change based on results from future preremedlal design
Investigations. This Is provided as a relative measure from which to compare the costs of different alternatives.
-------
Table 3- Northwest Harbor Island Alternative 3- Dredge to SQS
Descriotion
1. Nearshore Areas
A. Dredging
Dredging Mobilization/Demobilization
Transport and Placement (Pipeline)
Dredging. Hydraulic Volume
Confirmation Sampling
3. Disposal
Disposal Volume (20% expansion)
Nearshore Disoosal
C. Short-term Monitoring
Water Quality Monitoring
Bathvmetric/Sed. Profile Surveys
Unit Quantity Unit Cost Cost
LS
CY
CY
1/4000 CY
CY
CY
DAY
LS
1
204978
204978
51
245974
245974
17
1
$300.000.00
J1.60
!2.00
$1.000.00
$30.00
$3.300.00
$35.000.00
: 300.000
! 307.467
i 409.956
$51 .000
$7.379.208
! 156,1 00
! 35.000
Subtotal Construction Costs (Items 1)
Engineering Costs ( % of Construction Costs)
Contingency Allowances (% of Construction Cost)
Total Construction Costs
%
15
10
: 8.538.731
!i1. 280.810
$853.873
MO.673.414
SUBTOTAL ... M 0,673.41 4
TOTAL PRESENT WORTH VALUE Ji10,673.000
The cost of this alternative is highly subject to change based on results from future preremedial design
investigations. This is provided as a relative measure from which to compare the costs of different alternatives.
-------
Table 4-West Watetway Alternative 3-Dredge to SOS
Description
1 . Entire Cleanup Area
A. Dredqlng
Dredging Mobilization/Demobilization '
Transport and Placement (Pipeline)
Dredging, Hydraulic Volume
Confirmation SampBna
B. Disposal
Disposal Volume (20% expansion)
Nearshore Disposal
C. Short-term Monitoring
Water Quality Monitoring
Bathymetric/Sed. Profile Surveys
Subtotal Construction Costs (Items 1)
Engineering Costs ( % of Construction Costs)
Contingency Allowances (% of Construction Costs)
Total Construction Costs
Unit
LS
CY
CY
1/4000 CY
CY
CY
DAY
LS
%
Quantity
1
31817
31817
8
38180
38180
3
1
Unit Cost
$300.000.00
ill .50
!2jQO
$1.000.00
$30.00
$3.300.00
$35,000.00
15
10
Cost
$300.000
! 47.726
! 63,634
$8.000
$1.145.412
$9.900
$35.000
$1.609,672
! 1241 .451
! H 60.967
$2.012.089
SUBTOTAL . •' $2,012,089
TOTAL PRESENT WORTH VALUE S2.012.0OO
The cost of this alternative Is highly subject to change based on results from future preremedlal design
investigations. This Is provided as a relative measure from which to compare the costs of different alternatives.
-------
Table 5- Northwest Harbor Island Alternative 4- Dredge to CSLs and Cap
Description
1 . Nearshore Dredglna
A. Dredging
Dredging Mobilization/Demobilization
Transport and Placement (Pipeline)
Volume (hydraulic)
Confirmation Sampling
B. Short-term Monitoring
Water Quality Monitoring
Bathymetric/Sed. Profile Surveys
C. Disposal
Disposal Volume (20% expansion)
Nearshore Disposal
2. Nearshore Area Capping
A. Cap
Silty Sand
Transport and Placement
B. Short-term Monitoring
Water Quality Monitoring
Bathymetric/Sed. Profile Surveys
Subtotal Construction Costs (Items 1 and 2)
Engineering Costs ( % of Construction Costs)
Contingency Allowances (% of Construction Costs)
Total Construction Costs
3 Long-term Monitoring
4 Maintenance
Subtotal O&M Costs (Items 3 and 4)
Administrative Costs (% of O&M Costs)
Total O&M Costs
Unit
LS
CY
CY
1/4000 CY
DAY
LS
CY
CY
CY
CY
DAY
LS
%
LS
LS
%
Quantity
1
116415
116415
20
10
1
139698
139698
80011
80011
7
1
15
10
1
1
15
Unit Cost
$300.000.00
!1J60
!2JOO
$1.000.00
$3.300.00
$35.000.00
$30.00
$3.00
$3.00
$900.00
$35.000.00
$342,974.00
$500.064.60
Cost
4
{
1
300,000
.174.623
232.830
$29,104
! 33 ,000
! 35,000
$4
190.940
$240.033
$240.033
$6.300
$35.000
$5516.862
4
!
5827.629
551.686
$6396,078
$342.974
$500.065
)
I
. 4
$843,039
1126,456
969.494
SUBTOTAL $7.865.572
TOTAL PRESENT WORTH VALUE $7466.000
The cost of this alternative Is highly subject to change based on results from future preremedlal design
Investigations. This is provided as a relative measure from which to compare the costs of different alternatives.
-------
Table 6- West Waterway Alternative 4- Dredge to CSLs and Cap
' Description
1 . Cleanup Area - Dredging
A. Dredging
Dredging Mobilization/Demobilization
• Transport and Placement (Pipeline)
Dredging, Hydraulic Volume
Confirmation Sampling
B. Short-term Monitoring
Water Quality Monitoring ' .
Bathymetric/Sed. Profile Surveys
C. Disposal
Disposal Volume (20% expansion)
Nearshore Disposal
2. Cleanup Area - Capping
A. Cap
Siltv Sand
Transport and Placement
B. Short-term Monitoring
Water Quality Monitoring
Bathvmetric/Sed. Profile Surveys
Subtotal Construction Costs (Items 1 and 2)
Engineering Costs ( % of Construction Costs)
Contingency Allowances (% of Construction Costs)
Total Construction Costs
3 Long-term Monitoring
4 Maintenance
Unit
LS
CY
CY
1/4000 CY
DAY
LS
CY
CY
CY
CY
DAY
LS
%
. . s--
LS
LS
Quantity
1
18153
18153
5
2
1
21784
21784
11395
11395
1
1
15
10
1
1
Unit Cost
$300.000.00
<
4
1.50
2.00
$1.000.00
•
$3.300.00
$35.000.00
$30.00
(
(
3.00
3.00
$900.00
$35.000.00
$342.974.00
$113.910.08
Subtotal O&M Costs (items 3 and 4)
Administrative Costs (% of O&M Costs) .
Total O&M Costs
. %
15
Cost
$300.000
! I27.230
! 36.306
$4.538
$6.600
$35.000
$653.508
i 34,1 85
134.185
$900
$35.000
$1.167.452
! 11 75,1 18
M 16.745
$1.459.315
$342.974
$113.910
SUBTOTAL
$-56.884
! 68.533
$525.417
$1.984.731
TOTAL PRESENT WORTH VALUE $1.985.0001
The cost of this alternative is highly subject to change based on results from future preremedial design
Investigations. This Is provided as a relative measure from which to compare the costs of different alternatives.
-------
Table 7-Northwest Harbor Island Alternative 2- Containment with OnsKe Nearshore Disposal
Description
1. Nearshore Dredging
A. Dredging
Dredging Mobilization
Transport and Placement (Pipeline)
Dredging, Hydraulic Volume
B. Disposal
Disposal Volume (20% expansion)
Onslte Nearshore Disposal
C. Short-term Monitoring
Water Quality Monitoring
Bathymetric/Sed. Profile Surveys
2. Nearshore Capping
A. Cap
SlltySand
Transport and Placement
B. Short-term Monitoring
Water Quality Monitoring
Surveys
Subtotal Construction Costs (Items 1 and 2)
Engineering Costs ( % of Construction Costs)
Contingency Allowances (% of Construction Costs)
Total Construction Costs
3 Long-term Monitoring
4 Maintenance
Subtotal O&M Costs (Items 3 and 4)
Administrative Costs (% of O&M Costs)
Total O&M Costs
Unit
US
CY
CY
CY
CY
DAY
LS
CY
CY
DAY
LS
%
LS
LS
*
-
%
Quantity
1
45108
45198
54238
54238
4
1
160022
160022
13
1
15
10
1
1
15
Unit Cost
^aoOjOoo.oo
111.50
)2.00
$16.00
$3,300.00
$35,000.00
$3.00
$3.00
$900.00
$35,000.00
$342.974.00
$500.064.60
Cost
$300.000
167.797
190.396
$867.802
13.200
35.000
!
!
480,066
480,066
!t1 1.700
i 35.000
$2.381.027
!
i
357.154
238.103
$2.976.283
$342.974
$500.065
!
!
!
843,039
126,456
969.494
. .- SUBTOTAL 13,945.778
TOTAL PRESENT WORTH VALUE ! 3,946.000
The cost of this alternative Is highly subject to change based on results from future preremedial design
investigations. This is provided as a relative measure from which to compare the costs of different alternatives.
-------
Table 8-Northwest Harbor Island Alternative 3- Dredge to SQS with Onsite Nearshore Disposal
Description
1. Nearshore Areas .
A. Dredging ' .
Dredoina Mobilization/Demobilization
Transport and Placement (Pipeline)
Dredging. Hydraulic Volume
Confirmation Sampling
3. Disposal
Disposal Volume (20% expansion)
Onsite Nearshore Disposal
Offshe Nearshore Disposal
3. Short-term Monitoring
Water Quality Monitoring
Bathymetric/Sed. Profile Surveys
^^^•tRfTBHH ki* {I f Ti 1 1 1 !V HHITi^T^T^BI
. . - - -
LS
CY
CY
1/4000 CY
CY
CY
CY
DAY
LS
..
1
204978
204978
51
245974
140000
105974
17
1
. .j • .
$300.000.00
:1.50
I2.00
$1.000.00
. ! 16.00
! 30.00
$3.300.00
$35.000.00
Cost
(
I
I
300.000
307.467
409.956
$51.000
! 2.240.000
! 3.1 79.208
i 56.100
! 35.000
Subtotal Construction Costs (Items 1)
Engineering Costs (.% of Construction Costs)
Contingency Allowances (% of Construction Cost)
Total Construction Costs
%
15
10
$6.578.731
<
i
.986.810
657.873
$8.223.414
SUBTOTAL ! 8.223,414
TOTAL PRESENT WORTH VALUE J 8.223.000
The cost of this alternative is highly subject to change based on results from future preremedial design
investigations. This is provided as a relative measure from which to compare the costs of different alternatives.
-------
Table 9-Northwest Harbor Island Alternative 4- Dredge to CSLs (with Onslte Nearshore Disposal) and Cap
Description
1 . Nearshore Dredging
A. Dredging
Dredging Mobilization/Demobilization
Transport and Placement (Pipeline)
Volume (hydraulic)
Confirmation Sampling
B. Short-term Monitoring
Water Quality Monitoring
Bathymetrlc/Sed. Profile Surveys
C. Disposal
• Disposal Volume (20% expansion)
Onslte Nearshore Disposal
2. Nearshore Area Capping
A. Cap
Silty Sand
Transport and Placement
B. Short-term Monitoring
Water Quality Monitoring
Bathymetric/Sed. Profile Surveys
Subtotal Construction Costs (Items 1 and 2)
Engineering Costs ( % of Construction Costs)
Contingency Allowances (% of Construction Costs)
Total Construction Costs
3 Long-term Monitoring
4 Maintenance
Subtotal O&M Costs Items 3 and 4)
Administrative Costs % of O&M Costs)
Total O&M Costs
Unit
LS
CY
CY
1/4000 CY
DAY
LS
CY
CY
CY
CY
DAY
LS
%
LS
LS
%
Quantity
1
116415
116415
29
10
1
139698
139698
80011
80011
7
1
15
10
1
1
15
Unit Cost
$300.000.00
S1.50
SiZOO
$1.000.00
$3.300.00
$35,000.00
$16.00
1
$3.00
$3.00
$900.00
$35.000.00
$342.974.00
$500.064.60
Cost. .
! 300,000
11174,623
! 1232,830
$29.104
$33,000
$35,000
$2.235.168
! 1240,033
! !240,033
$6.300
$35.000
$3561.090
$534.164
$356,109
$4451.363
$342,974
$500.065
$843.039
! 1126,456
! 1969,494
SUBTOTAL $5.420.857
TOTAL PRESENT WORTH VALUE - $5421000
The cost of this alternative Is highly subject to change based on results from future preremedlal design
Investigations. This is provided as a relative measure from which to compare the costs of different alternatives.
-------
APPENDIX C
ADMINISTRATIVE RECORD INDEX
-------
(HIA05) HARBOR ISLAND - Shipyard Sediments Administrative Record INDEX
HEADING: 0. 0. . . INDEX/TABLE OF CONTENTS
US Environmental Protection Aaencv. Reaion 10
-------
(HIAO5) HARBOR ISLAND - Shipyard Sediments Administrative Record INDEX
HEADING: 1. 0. . . REMEDIAL INVESTIGATION/FEASIBILITY STUDY
SUB-HEAD: 1.1. . . Vol.1- See Harbor Island Sediments AR Section 1.0
SUB-HEAD: 1.2. . . Vol. 1 - Technical Memoranda
1,2. . . Vol.1 - 1050687 DOC ID: 48887
DATE: 11/3/95 PAGES: 50
AUTHOR(S): ADDRESSEE(S):
WESTON DESIGNER/CONSULTANTS Unknown Unknown/EPA
DESCRIPTION: TECHNICAL MEMORANDUM, HARBOR ISLAND REVISED SEDIMENT REMEDIAL
ALTERNATIVES.
1. 2. . . Vol.1- 1050691 DOC ID: 67321
DATE: 11/13/96 PAGES: 7
AUTHOR(S): ADDRESSEE(S):
WILLIAM J. ENKEBOLL/Landau Associates, Inc. Roland H. Webb/Todd Pacific Shipyards Corp.
Dennis R. Stettler/Landau Associates, Inc. Roland H. Webb/Todd Pacific Shipyards Corp.
DESCRIPTION: TECHNICAL MEMORANDUM REGARDING CONCEPTUAL EVALUATION OF NEARSHORE
FILL ALTERNATIVE, TODD SHIPYARDS.
11/27/96 U.S. Environmental Protection Agency, Region 10 Page
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(HIAO5) HARBOR ISLAND - Shipyard Sediments Administrative Record INDEX
HEADING: 2. 0. . . PUBLIC PARTICIPATION
SUB-HEAD: 2. 1. . . Vol.1 - Proposed Plan
2. 1. . . Vol.1 - 1050690 DOC ID: 67307
DATE: 10/31/95 PAGES: 14
AUTHOR(S): ADDRESSEE(S):
EPA Unknown
DESCRIPTION: PROPOSED PLAN, SHIPYARD SEDIMENTS OPERABLE UNIT. HARBOR ISLAND, SEATTLE,
WA.
SUB-HEAD: 2. 2. . . Vol. 1 - Public Comments
2.2. . . Vol.1 - 1050692 DOC ID: 67322
DATE: 11/8/95 PAGES: 2
AUTHOR(S): ADDRESSEE(S):
Richard J. Brooks/Brooks Rand, Ltd. Keith A. Rose/EPA
DESCRIPTION: LETTER REGARDING HARBOR ISLAND SEDIMENT CLEAN-UP, FOCUSING ON MERCURY
LEVELS.
2. 2. . . Vol.1 - 1050693 DOC ID: 67323
DATE: 12/18/95 PAGES: 24
AUTHOR(S): ADDRESSEE(S):
James J. Valenti/United Steelworkers of America Keith A. Rose/EPA
DESCRIPTION: LETTER SUBMITTING COMMENTS ON THE PROPOSED PLAN FOR REMEDIAL ACTION,
HARBOR ISLAND, SHIPYARD SEDIMENTS OPERABLE UNIT.
2. 2. . . Vol.1 - 1050694 DOC ID: 67324
DATE: 12/21/95 PAGES: 85
AUTHOR(S): , , ADDRESSEE(S):
R N. HELGERSON/LOCKHEED CORPORATION Keith A. Rose/EPA
DESCRIPTION: LETTER SUBMITTING COMMENTS ON THE PROPOSED PLAN FOR REMEDIAL ACTION,
HARBOR ISLAND. SHIPYARD SEDIMENTS OPERABLE UNIT EXPRESSING TWO
FUNDAMENTAL CONCERNS WITH EPA'S PROPOSED PLAN.
2. 2. . . Vol.1 - 1050695 DOC ID: 67325
DATE: 12/27/95 PAGES: 56
AUTHOR(S): *= ADDRESSEE(S):
Alan B. Jones/Brooks Rand, Ltd. Keith A. Rose/EPA
DESCRIPTION: LETTTER REGARDING ADDITIONAL SEDIMENT MERCURY ANALYSIS AT HARBOR ISLAND
SEDIMENT OPERABLE UNIT. *
2.2... . Vol.1 r, ' 1050696 DOC ID: f 67326
DATE: 12/28/95 PAGES:' 7
AUTHOR(S): , ADDRESSEE(S):
Francis P. Sweeney/Washington State Department of Keith A. Rose/EPA
Natural Resources
DESCRIPTION: LEfTER TRANSMITTING WASHINGTON STATE DEPARTMENT OF NATURAL RESOURCES'
COMMENTS ON THE PROPOSED PLAN FOR THE SHIPYARD SEDIMENTS OPERABLE UNIT.
2. 2. . . Vol.1 - 1050697 00010:^67327
DATE: 1/2/96 PAGES: ' 3
AUTHOR(S): ADDRESSEE(S):
James J. Valenti/United Steelworkers of America Keith A. Rose/EPA
ESCRIPTION: LETTER TRANSMITTING COMMENTS ON THE PROPOSED PLAN FOR REMEDIAL ACTION,
SHIPYARD SEDIMENTS OPERABLE UNIT.
11/P7AV? IIFt Fm/ironmental Protection Aoencv Reoion 10 Paoe
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(HIAO5) HARBOR ISLAND - Shipyard Sediments Administrative Record INDEX
2. 2. . . Vol.1 - 1050698 DOC ID: 67328
DATE: 1/8/96 PAGES: 24
AUTHOR(S): ADDRESSEE(S):
Charles R. Blumenfeld/Bogle & Gates Keith A. Rose/EPA
Leonard H. Sorrin/Bogle & Gates Keith A. Rose/EPA
DESCRIPTION: LETTER REGARDING COMMENTS ON THE SHIPYARD SEDIMENTS OPERABLE UNIT
PROPOSED PLAN.
2. 2. . . Vol.1 - 1050699 DOC ID: 67329
DATE: 1/8/96 PAGES: 1
AUTHOR(S): ADDRESSEE(S):
Margaret Duncan/Suquamish Tribe Keith A. Rose/EPA
DESCRIPTION: LETTER REGARDING EPA'S PREFERRED ALTERNATIVE FOR THE SHIPYARD SEDIMENTS
OPERABLE UNIT.
2. 2. . . Vol. 1 - 1050700 DOC ID: 67330
DATE: 1/30/96 PAGES: 2
AUTHOR(S): ADDRESSEE(S):
James J. Valenti/United Steelworkers of America Keith A. Rose/EPA
DESCRIPTION: LETTER SUPPLEMENTING PREVIOUS COMMENT ON THE HARBOR ISLAND SUPERFUND
SITE DATED 12/18/95 WITH SOME ADDITIONAL INFORMATION RECENTLY LOCATED.
SUB-HEAD: 2. 3. . . Vol. 1 - Public Hearing Proceedings
2. 3. . . Vol.1- 1050688 DOC ID: 67306
DATE: 12/6/95 PAGES: 17
AUTHOR(S): ADDRESSEE(S):
Clint D. Hutchison/Bayside Reporters Unknown
DESCRIPTION: PROCEEDINGS/PUBLIC HEARING, ENVIRONMENTAL PROTECTION AGENCY. HARBOR
ISLAND SUPERFUND SITE.
11/27/96 U.S. Environmental Protection Agency, Region 10 Page
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(HIAO5) HARBOR ISLAND - Shipyard Sediments Administrative Record INDEX
HEADING: 3. 0. . . ENFORCEMENT
SUB-HEAD: 3. 1. . . Vol.1 - Administrative Order on Consent
3. 1. . . Vol.1 - 0001 DOC ID: 67308
DATE: 2/13/95 PAGES: 40
AUTHOR(S): ADDRESSEE(S):
Unknown Unknown/EPA Unknown
DESCRIPTION: ADMINISTRATIVE ORDER ON CONSENT FOR ADDITIONAL SAMPLING AND ANALYSIS FOR
SEDIMENT OPERABLE UNIT.
This document is included by reference only. The actual document is located in the Harbor Island
Sediments Administrative Record section 4.1.
11/77/as u s Fnvironmental Protection Aoencv Ranion 1.0
-------
(HIAO5) HARBOR ISLAND - Shipyard Sediments Administrative Record INDEX
HEADING: 4. 0. . . RECORD OF DECISION
SUB-HEAD: 4. 1. . . Vol. 1 - State Concurrence Letter
4. 1. . . Vol.1 - 1050707 DOC ID: 67334
DATE: 11/26/96 PAGES: 1
AUTHOR(S): ADDRESSEE(S):
Mary E. Burg/Washington Dept. of Ecology Michael F. Gearheard/EPA
DESCRIPTION: CONCURRENCE TO THE REVISED HARBOR ISLAND SHIPYARD SEDIMENT RECORD OF
DECISION.
SUB-HEAD: 4. 2. . . Vol. 1 - Record of Decision
4. 2. . . Vol. 1 - DOC ID: 67335
DATE: PAGES: 100
AUTHOR(S): ADDRESSEE(S):
DESCRIPTION: HARBOR ISLAND SHIPYARD SEDIMENT RECORD OF DECISION. (This entry will be edited
when the document is received]
11/27/96 U.S. Environmental Protection Agency. Region 10 Page
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