lockheed west seattle appendix b · lockheed west seattle uao statement of work for rd/ra appendix...

Lockheed West Seattle VAO Statement of Work for RD/RA Appendix B

I. PURPOSE

The purpose of this Statement of Work (SOW) is to identify requirements for implementation of the remedial action at the Lockheed West Seattle Superfund Site (Lockheed West Site or Site) set forth in the Record of Decision (ROD), which was signed by the Regional Administrator of the United States Environmental Protection Agency (EPA), Region 10 on August 28, 2013, for the Site. The ROD identifies the cleanup standards and the cleanup area of the in-water portion of the Lockheed West Site of what formerly was known as Lockheed Shipyard No.2, located near the confluence of the West Waterway and Elliott Bay, west of the city of Seattle, Washington (Figure 1). The Site includes the in-water marine sediments where the former Lockheed Shipyard No. 2 was located (the shipway and dry docks were located in the water over the sediments). The Site is impacted by tides with additional influence from the Lower Duwamish Waterway (LOW) that flows into the West Waterway. The Site also includes a narrow shoreline bank defined as areas extending from plus [+] 11.3 feet mean higher high water (MHHW) to intertidal sediments at minus[-] 10 feet mean lower low water (MLLW} along the northern and eastern shorelines, and subtida l sediments that extend to minus [-] 40 to -50 feet (MLLW) in historically dredged areas. The Site also includes numerous pilings that remain within the footprint of the former shipway and pier structures in the northwestern portion of the Site.

This SOW defines the work to be accomplished in remedial design and remedial action. This SOW is Appendix B to the Unilateral Administrative Order (UAO) for the remedial action of the Site. The remedial design is generally those activities to be undertaken to develop the final plans and specifications, general provisions, and special requirements necessary to implement the ROD. The Work is genera lly the implementation phase of the ROD, including necessary long-term monitoring and maintenance, performance monitoring, and implementation of special requirements such as institutional controls. The remedial action is based on the EPA approved remedial design.

In conduct.ing work specified in the SOW, Lockheed Martin Corporation (Respondent) shall follow the existing documents: the 2013 ROD and any explanations of significant difference (ESDs), including ESD 2015 (Order, Appendix D), the UAO, this SOW, EPA Superfund Remedial Design and Remedial Action Guidance, and any additional EPA guidance listed in Attachment 1, in submitting deliverables for designing and implementing the remedial action at the Site. The Respondent shall also follow the preremedial design and design documents provided by the Respondent and approved by the EPA. Implementation of this SOW shall result in achieving the Site remedial action objectives and the cleanup levels.

II. DESCRIPTION OF REMEDIAL ACTION

In the Lockheed West ROD, the EPA selected a remedy comprised of 4 (four) key elements to address contaminated sediments at the Site1:

1. Removal of debris and pilings

2. Sediment remedial action, including dredging2 and disposal, backfill, residuals management and/or thin cover/enhanced natural recovery (ENR) layer placement. The extent of the sediment removal action is shown in Figure 2.

1 A fu ll listing of Selected Remedy elements is provided in Attachment 2 to this SOW. 2 While dredging is identified as the means for sediment removal in the ROD, contaminated sediments along the bank and intertidal portion of the Site may be removed using land-based excavators.

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Lockheed West Seattle UAO Statement of Work for RD/RA Appendix B

3. Institutional controls

4. Long-term monitoring and maintenance

The cleanup strategy for the Site has been to eliminate or reduce ongoing sources of problem contaminants to the extent practicable before implementing in-water cleanup actions. Source control activities were completed previously by others under a separate Order with the Washington State Department of Ecology (Ecology) and are not part of this SOW._The UAO does not require prevention of releases of hazardous substances originating outside the boundaries of the Site and not attributable to Respondent (i.e., recontamination from offsite sources, as defined in the UAO).

The remedial action objectives (RAOs) to protect human health and the environment as listed in the ROD are as follows:

• Human Health Risks:

RAO 1- Reduce human health risks associated with the consumption of resident seafood by adults and children with the highest potential exposure.

RAO 2 - Prevent human health risks from direct exposure (skin contact and incidental ingestion) to contaminated sediments during netfishing, clamming, and beach play.

• Ecological Risks:

RAO 3- Prevent risks to benthic invertebrates from exposure to contaminated sediments.

RAO 4 - Prevent risks to crabs, fish, and birds from exposure to contaminated sediments.

The expected outcome of the Selected Remedy Is removal of the most highly contaminated sediments at the Site with concentrations of total polychlorinated biphenyls (PCBs), arsenic, copper, lead, mercury, carcinogenic polycyclic aromatic hydrocarbons (cPAHs), trlbutyltin (TBT) and all other contaminants of concern (COCs) that exceed the Cleanup Levels for RAO 1through43. Residual risks from these and other COCs would be mitigated through placement of 6- to 9-inch layer of clean imported sediment and institutional controls (ICs). Following implementation of the remedy, the Site would be suitable for its current and anticipated future use, which includes a navigation channel. However, due to potential ongoing presence of other contaminant sources throughout Elliott Bay, the Site will not be suitable for unrestricted consumption of fish.

The Selected Remedy is expected to meet applicable or relevant and appropriate requirements (ARARs). However, a technical impracticability (Tl) waiver of the Federal ambient water quality criteria (AWQC) for arsenic is part of the Selected Remedy because it is technically impracticable for remediation of contaminated sediments at this Site to measurably improve the overall water quality for arsenic within the larger Elliott Bay. To the extent there is movement of contaminated water onto the Site, originating outside the boundaries of the Site and not attributable to Repondent, a Tl waiver of the AWQC for other chemicals of concern, may also be needed.

Ill. PERFORMANCE STANDARDS

The Respondent shall adhere to the following performance standards for the design and implementation of the cleanup work:

3 RAO-specific Cleanup Levels for all COCs are listed In Attachment 3 to this SOW

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Lockheed West" Seattle UAO Statement of Work for RD/RA Appendix B

• Construction Performance Standards - Quality assurance standards and checks to ensure that remedial construction methods are carried out as planned. These standards are defined in the Construction Quality Assurance Plan (CQAP} and associated documents and may include material and equipment certification requirements, field quality control measurements, and numeric criteria . The numeric construction performance standards for the Lockheed West remedial action include the following:

Cleanup Levels- Contaminant concentrations to be achieved at the sediment surface (upper 10 cm in subtidal zone, upper 45 cm in intertidal zone) after dredging or excavation and placement of the dredge residual management/ENR layers or intertidal backfill. The Cleanup Levels are directly related to the RAOs for the Site, as defined in the ROD. The Cleanup Level for each contaminant is the lowest of the applicable human health and ecological threshold concentrations (RBTCs) or the natural background concentration, if it is higher than the lowest RBTC. RAO 1 (human consumption of seafood caught or gathered at the site} has the lowest RBTCs, with many of the contaminants having RBTCs below the natural background levels. Therefore, the most conservative (i.e., lowest) and ultimate Cleanup Levels for sediment at the Site consist of RBTCs associated primarily with RAO 1 and natural background concentrations. These Cleanup Levels are listed in Attachment 3.

Construction Activity Limits- Defined limits on environmental impacts related to construction activities, including ambient water quality criteria (AWQC) and other applicable or relevant and appropriate requirements (ARARs) to be defined in the CQAP and associated documents (e.g., water quality monitoring plan).

Remedial Action levels - Contaminant concentrations to be achieved at the bottom of the :. dredge prism after dredging or excavation is complete and before placement of the dredge

residual management/ENR layer or intertidal backfill. The Remedial Action Levels are based primarily on the sediment quality standards (SQS) and the cleanup screening levels (CSLs). The SQS and CSL values are related to RAO 3 (protection of the benthic invertebrate community); the more stringent SQS values correspond to sediment quality that has no acute or chronic adverse effects on benthic marine organisms, the less stringent CSL values are levels above which minor adverse effects may occur in benthic marine organisms. The Remedial Action Levels and locations where they will be applied are listed in Attachment 4.

• long term Monitoring Performance Standards - Quality assurance standards and checks to verify that the objectives of the Work (including post-construction institutional controls} have been maintained over time. These standards are verified by measuring or monitoring environmental conditions and interpreting the results using decision processes that will be defined in the long-terrn monitoring and maintenance plan (LTMMP).

These performance standards are consistent with the cleanup objectives and are necessary to ensure that the remedy is protective of human health and the environment, and complies with ARARs.

The performance standards to be achieved during each component of the Work are outlined in Paragraphs A through F below.

A. Debris and Piling Removal and Disposal and Bank Evaluation

The primary purpose of this activity will be to remove pilings and debris where such structures may hinder dredging and/or placement of the dredge residuals management/ENR layers in the former shipway. Additional debris, riprap, failing wooden bulkheads and pilings may also be removed, as

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Lockheed West Seattle UAO Statement of Work for RD/RA AppendixB

necessary. An evaluation shall be performed to determine whether these materials are necessary to stabilize the bank or support current upland activities. The removed debris, piles, and other materials will be disposed of in an approved off site location. Performance standards for debris and piling removal shall be consistent with the ROD and ARARs, including the Resource Conservation and Recovery Act (RCRA), Clean Water Act, Rivers and Harbors Act, and Endangered Species Act requirements. All materials removed from the Site must be managed or disposed in accordance with the Off-Site Rule (CERCLA Section 121(d)(3)).

The methods for achieving the performance standards for removal and disposal of all materials shall be set forth in the Remedial Design Report and the CQAP. In addition, all in-water work at the Site will be subject to Construction Activity Limits and other short-term monitoring standards, which will be defined in the CQAP and associated planning documents. Verification that performance standards have been achieved shall be documented in the Remed ial Action Construction and Completion Report. This report will provide descriptions of the remova l activities, monitoring results, and disposal information for all material removed from the Lockheed West Site.

B. Sediment Removal and Disposal

The primary purpose of excavation 4 and dredging performed under this SOW will be to remove contaminated sediment in specific areas of the Site. As shown in Figure 2, the shoreline bank and intertidal zone, shipway and the navigational channe l will be dredged to the SQS Remedia l Action Level, and Dry Docks 1, 2 and 3 and other localized subtidal areas throughout the Site will be dredged to the CSL Remedial Action Level. Performance standards for sediment remova l shall be consistent with the ROD and ARARs including the Clean Water Act, Rivers and Harbors Act, and Endangered Species Act requirements, and the Remedial Action levels listed in Attachment 4. The contaminated sediment shall be disposed of in an approved upland disposal site. All materials removed from the Site must be managed or disposed in accordance with the Off-Site Rule (CERCLA Section 121(d)(3)).

The methods for achieving the performance standards for dredging, excavation, and disposal of all materials shall be set forth in the Remedial Design Report and the CQAP. The achievement of performance standards for dredging and excavation will account for generated residuals (sediment disturbed by the cleanup action) and undisturbed residuals. In addition, all in-water work at the Site will be subject to Const ruction Activity Limits and other short-term monitoring standards, which will be defined in the CQAP and associated planning documents. Verification that performance standards have been achieved shall be documented in the Remedial Action Construction and Completion Report. This report will provide monitoring results, "as-builts" of all excavated and dredged surfaces, quant ities of removed sediment (in-place volumes), and the disposal location for material dredged and removed from the Lockheed West Site.

C. Intertidal Backfill Placement

The purpose of placing backfill is to bring the dredged or excavated intertidal area back to grade with clean imported backfill material (e.g., sand, silty sand) that promotes colonization by aquatic organ isms. This material may incorporate soft or organic-rich substrates beneficial to salmon ids and ot her Sitespecific aquatic organisms (e.g., "fish mix" or a silt-sand mix). Performance standards for backfill placement shall be consistent with the ROD and ARARs, including the Clean Water Act, Rivers and Harbors Act, and Endangered Species Act requirements. In addition, contaminant concentrations of

4 While dredging Is Identified as the means for sediment removal in the ROD, contaminated sediments along the bank and Intertidal portion of the Site may be removed using land-based excavators.

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import materia l for the backfill placed within the intertidal zone sha ll meet the Cleanup Levels listed in Attachment 3 and that placed material shall meet the specified design thickness. These are the criteria for determining completion of construction in the intertidal areas.

The methods for achieving the performance standards for backfill placement shall be set forth in the Remedia l Design Report and the CQAP. As with the other elements of construction, any in-water work will be subject to Construction Activity Limits and other short-term monitoring standards, which will be defined in the CQAP and associated planning documents. Verification that performance standards have been achieved shall be documented in the Remedial Action Construction and Completion Report. This report will provide monitoring results, "as-builts" of the backfilled area, and information about the source and quantity of the backfill material.

0 . ENR Layer and Dredge Residuals Management Layer Placement

The primary purpose of placing the ENR and dredge residuals management layer is to provide a clean 6 to 9-inch layer of imported material that promotes colonization by aquatic organisms. This material may incorporate soft or organic-rich substrates beneficial to salmonids and other Site-specific aquatic organisms (e.g., "fish mix" or a silt-sand mix). In subtidal areas where dredging will occur (see 111.B), the layer will address potential redeposition of suspended or dislodged contaminated sediment onto nearby or adjacent sediments during dredging operations. In areas where dredging does not occur (i.e., the remainder of the subtidal area), the layer will promote ENR. Performance standards for the ENR and dredge residual management layers shall be consistent with the ROD and ARARs, including the Clean Water Act, Rivers and Harbors Act, and Endangered Species Act requirements. In addition, contaminant concentrations of import material(s) for the ENR and dredge residuals management layer placed within the subtidal zone shall meet the Cleanup Levels listed in Attachment 3 and that placed material shall meet the specified design thickness. These are the criteria for determining completion of construction in the intertidal areas.

The methods for achieving the performance standards for placement of the ENR/dredge residuals management layer shall be set forth in the Remedial Design Report and the CQAP. As with the other elements of construction, any in-water work will be subject to Construction Activity Limits and other short-term monitoring standards, which will be defined in the CQAP and associated implementation documents. Verification that performance standards have been achieved shall be documented in the Remedial Action Construction and Completion Report. This report will provide monitoring results, " asbuilts" of the ENR/dredge residuals management layer, and information about the source and quantity of the material that was used.

E. Institutional Controls

The Respondent shall draft and, upon approval from the EPA place institutional controls {ICs) in the form of a proprietary control that runs with the property and that requires coordination with the EPA and management of any residual surface contamination (above Cleanup Levels) that is disturbed or encountered in the event of future dredging or piling removal within the boundaries of the Site. In add ition, the current fish advisory for Recreational Marine Area 10 (Elliott Bay) under the Puget Sound Fish Consumption Advisory, established by the Washington State Department of Health, or any modification thereto by the EPA, to reduce human exposure from ingestion of contaminated seafood will continue t o be posted at the Site. Monitoring and reporting on the efficacy of the fish advisory will not be part of the long-term monitoring program.

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The methods for achieving the performance standards for placement of ICs shall be set forth in the Remedial Design Report and the Institutional Control Implementation and Assurance Plan (ICIAP). Implementation of the I Cs shall be documented In the Remedial Action Construction and Completion Report and in the Final Close-out Report.

F. Long-term Monitoring and Maintenance

Under this SOW, the Site will be subject to long-term monitoring to ensure that the long term objectives of the remedy are met. Since recontamination of the sediment surface from offsite sources may occur due to ambient conditions in Elliott Bay and the Lower Duwamish Waterway, sampling and numeric performance standards such as Cleanup Levels will not be the only criteria for evaluating the performance of the remedy. Sampling methodology will be used to evaluate surface sediment recontamination from off-site sources ("top-down" contamination) and to evaluate potential mixing of the clean surface sediment layer with underlying sediment that has contaminant concentrations greater than the Cleanup Levels ("bottom-up" contamination). The sampling will take place in the biologically active zone of the subtidal (10 cm) and intertidal (45 cm) zones. If sampling demonstrates that "topdown" contamination has occurred and commensurately, "bottom-up" contamination has not occurred, and concentrations in the sediment surface layer exceed Cleanup Levels, then sediment quality monitoring will be discontinued unless bathymetric surveys indicate there have been substantial changes to the surface of the Site.

In addition to sediment sampling, long-term monitoring is expected to include sitewide bathymetry, and other assessment techniques to ensure that dredge residuals management/ENR layer and other components of the Selected Remedy are undisturbed and/or functioning as designed. Samples of surface water, fish, and/or shellfish tissue will not be collected as part of the long-term monitoring program. The performance standards for long-term monitoring, including sampling intervals (e.g., upper surface, interior, and bottom of layer), target analytes, and bathymetric survey resolution will be detailed in the LTMMP, which will be submitted as part of the Remedial Design Report. The LTMMP also will outline performance expectations and potential courses of action to be taken based on the Influence of marine activities including any marine construction, passage of time, recontamination from off-site sources, or the occurrence of natural phenomena such as earthquakes or significant weather events ..

The results of the long-term monitoring program will be documented in long-term monitoring and maintenance reports prepared by the Respondent and in 5 Year Review Reports prepared by the EPA. The 5 Year Review reports will also include file reviews and interviews with the landowner(s) pertaining to any development that has occurred at the Site since remediation was completed.

IV. WORK TO BE PERFORMED BY THE RESPONDENT

This Statement of Work requires the Respondent to complete a remedial design and conduct remedial action for the Lockheed West Site. The scope of work for remedial design and remedial action includes the following key components:

• Design and construct shoreline bank and intertidal sediment remedial actions: debris, riprap, failing bulkheads and pilings removal, excavating or dredging sediment to the SQS and backfill to grade with clean sediments that promotes colonization by aquatic organisms which may incorporate soft or organic-rich substrates beneficial to salmonids and other Site-specific aquatic organisms (e.g., "fish mix'' or a silt-sand mix).

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• Design and construct subtida l sediment remedial actions: removing sediments to the SQS or CSL depending on the Selected Remedy description, disposal and placement of a 6- to 9-inch dredge residuals management layer in dredged areas or placement of an ENR layer in remaining subtidal areas.

• Handle/transport/dispose of dredged sediments to an upland disposal facility that is consistent with the nature and concentrations of the contaminants found In the materials to be disposed of.

• Perform construction monitoring and long-term monitoring.

To accomplish this scope of work, the remedial design and remedial action shall consist of the following four phases and be followed by long-term monitoring:

A. Remedia l Design Work Plan

B. Remedia l Design

C. Remedial Action Work Plan

D. Remedial Action Construction

The Respondent shall be responsible for implementing additional work elements, If necessary, for successful implementation of the Lockheed West remedial action. All plans are subject to the EPA's approval.

Additiona l details on each phase are provided below. All documents, including work plans, reports and ,, memoranda, and schedules required under this SOW are subject to EPA, State, Muckleshoot and

Suquamish Tribes review and EPA approval. Unless otherwise specified by EPA, a draft version of each tt document shall be submitted to the EPA, State, Muckleshoot and Suquamish Tribes for review and ~ comment. Unless directed otherwise in EPA's comment letter, within thirty (30) calendar days of receipt

of EPA's comments on a draft document, the Respondent shall submit to the EPA a revised final document that incorporates the EPA's modifications or summarizes and addresses the EPA's concerns. All deliverables submitted in response to the EPA's comments shall include a transmittal that responds directly to each comment, and identifies how the comment was addressed in the deliverable. This SOW also specifies submittal of certain documentation (e.g., construction progress reports, monthly progress reports) that will be used by the EPA for information purposes, but wi ll not be formally approved by the EPA.

A. Remedial Design Work Plan

Within sixty (60) days after notice of authorization to proceed, the Respondent shall submit a Remedial Design Work Plan in accordance with Section X (Work to be Performed) and Paragraph 30.a. (Remedial Design) of the UAO and Section V (Schedule) of this SOW. The Remedial Design Work Plan shall document the overall management strategy for performing the design, construction, maintenance, and monitoring of remedial actions for the EPA, State, Muckleshoot and Suquamish Tribes to review and for the EPA to approve. The Remedial Design Work Plan sha ll include a brief summary of the work completed during the remedial investigation, identifying key documents, and summarizing key conclusions and sampling results, and should also identify additional data needs or retesting necessary to initiate or complete the remedial design and implement the remedial action.

The following elements of remedial design shall be recognized and noted in the Remedial Design Work Plan to be addressed in later design submittals:

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1. Sampling and analysis plan for pre-remedial design activities (including, but not limited to, a remedial design quality assurance project plan [QAPP], field sampling plan [FSP], health and safety plan [HSP] and data analysis plan).

2. Remedial action basis of design, which may include preliminary, intermediate, pre-final, and final design submissions.

3. Short-term environmental control measures.

4. Permitting and site access.

5. Construction sequence, scheduling and cost estimate.

6. Long-term monitoring and maintenance.

7. Environmental green and sustainable remediation.

8. Climate control adaptation plan.

9. Water quality monitoring.

10. Biological assessment.

11. Geotechnical basis of design.

12. Sediment excavation prism verification.

13. Archaeological monitoring and discovery.

14. Transportation analysis.

15. Construction quality assurance.

16. Institutional control implementation and assurance.

17. Community relations.

18. Schedule for completion of the Remedial Action Work Plan.

The Remedial Design Work Plan shall also document the responsibility and authority of all organizations and key personnel involved with the remedial design, including contractor personnel. Contact information (addresses, phone numbers, and e-mail) and general responsibilities for key personnel shall be provided.

In addition, the Respondent shall address scheduling and coordination of work under this SOW with other in-water work or navigation that may occur near the project area. The Respondent shall identify any known development projects anticipated on or near bank and intertidal or subtidal areas that are subject to work under this SOW.

B. Remedial Design

The remedial design ls generally defined as those activities to be undertaken to develop the final plans and specifications, general provisions, special requirements, and all other technical and contractor documentation necessary to fully implement the remedial action at this Site as described in the ROD and this SOW. The Respondent shall prepare construction plans and specifications to implement the remedial actions at the Site as described in the ROD, ESD and this SOW. Plans and specifications shall be submitted in accordance with the schedule set forth in Section V of this SOW and further defined regarding how the remedial design elements wlll be completed. Subject to approval by the EPA, the

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Respondent may submit more than one set of design submittals reflecting different components of the remedial action. All remedial design work, including plans and specifications, shall be developed in accordance with the EPA's Superfund Remedial Design and Remedial Action Guidance (OSWER Directive No. 9255.0-4A) and shall demonstrate that the remedial action shall meet all objectives of the ROD, UAO, and this SOW, including all performance standards. The Respondent shall meet regularly with the EPA to discuss design issues. These meetings must occur at least monthly, unless an alternate schedule is agreed to by the EPA.

The remedial design will consist of iterative submittals for EPA review. It is assumed that EPA comments of each submittal will be addressed in the next submittal and only the final (100%) remedial design will be formally approved by the EPA.

1. Pre-Remedial Design Field Sampling

The Respondent shall implement pre-design work in accordance with the final RD Work Plan. The results of the pre-design studies sha ll be submitted to EPA in a Pre- Remedial Design Data Report after receipt and data validation.

2. General Requirements for Deliverables

a. As provided in paragraph 54 of the UAO, all deliverables under this SOW must be in writing unless otherwise specified.

b. All deliverables must be submitted by the deadlines in the SOW, Remedial Design or Remedial Action Schedule. Respondent shall submit all deliverables to EPA in electronic form. If any deliverable includes maps, drawings, or other exhibits that are larger than 8.5'' by 11", Respondent sha ll also provide EPA with paper copies of such exhibits.

3. Technical Specifications for Deliverables

a. Sampling and monitoring data should be submitted in standard regional Electronic Data Deliverable (EDD) format. The RlO Data Deliverable Guidance fo r data submittal shall be used. The Respondent shall be responsible for directly loading the data into the public Water Quality Exchange (WQX) database. The Respondent will provide the EPA with a copy of the files created to load data into the WQX database. Data to be loaded into the publicly available database will include monitoring data-including concentrations of contaminants. The EPA will provide the Respondent with electronic examples of electronic data submittal templates and additional guidance on the form of the submissions. Contact Sue McCarthy at {206) 553-2598 or Matt Gubitosa at (206) 553-4059 if the Respondent has questions or needs assistance.

b. GIS data shall also be submitted to the EPA following the procedures in the "U.S. EPA Region 10 Geographic Information Systems (GIS) Data Deliverable Guidance for External Parties", which is provided in Attachment 1. The GIS data should be submitted at the same time as the final reports are submitted to the EPA. This includes sampling plans, Quality Assurance Project Plans, monitoring reports, studies, pre-remedial design sampling reports, where GIS and mapping programs were used to generate maps, diagrams, and other visual aids. Discs containing this information shall be sent to the EPA Project Manager. Contact Matt Gubitosa at (206) 553-4059 with questions or to request assistance for GIS submission requirements.

c. Each file must include an attribute name for each site unit or sub-unit submitted. Consult http://www.epa.gov/geospatial/policies.html for any further available guidance on attribute identification and naming.

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d. Spatial data submitted by Respondent does not, and is not intended to, define the boundaries of the Site.

4. Preliminary Design (30%)

The Respondent shall submit the Preliminary Design per Section V (Schedule). The Preliminary Design submittal shall include or discuss, at a minimum, the following:

a. Results of additional field sampling

b. Preliminary plans, drawings, and sketches, including an outline of required specifications not otherwise provided in detail and a list of all final drawings to be included in pre-final and final design.

c. Basis for Design Report, with detailed design assumptions, parameters, design restrictions and objectives, Including but not limited to:

General Elements:

• Descriptions of the analyses conducted to se lect the design approach, including a summary and detailed justification of design assumptions.

• Order in which debris and pile removal and replacement, dredging, backfill, disposal, dredge residual management layer, and ENR layer will occur.

• Technical parameters and essential supporting calculations (at least one sample calculation presented for each significant or unique design calculation) upon which the design will be based, including but not limited to design requirements for each activity (e.g., removing debris along shoreline, dredging).

• Access and easement requirements, including an evaluation of the most appropriate institutional and/or proprietary controls for each element of the remedial action to ensure longterm effectiveness.

• Coordination of Lockheed Martin's remedial activities_ with other in-water work, treatyprotected uses or navigation and commerce, property owner (i.e., Muckleshoot Indian Tribe, Suquamish Tribe, Port of Seattle and Washington State Department of Natural Resources).

• Permit requirements or substantive requirements of permits.

• Preliminary construction schedule, including contracting strategy.

• Plans and protocols for pulling pilings and/or placing ENR layer around pilings and other structures.

Debris, Riprap, Pilings Removal Elements:

• Identify debris, bulkheads, riprap and pilings to be removed.

• Provide geotechnical calculations demonstrating bank stability after removal of debris, bulkheads, riprap and pilings.

• Identify which, if any, piling(s) need to be reinstalled

• Identify upland disposal locations for debris, bulkheads, riprap, and pilings.

Excavation and Dredging Elements:

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• Methods and requirements for how excavated and dredged sediments will be removed, handled, dewatered, transported, disposed.

• Design removal depths and overcut allowances.

• Refine material volumes and removal techniques.

• Analysis of excavations and dredge cuts to ensure contaminated side slopes do not remain exposed after removal.

• Backfill of the bank and intertidal area.

• Identification of upland landfill location for disposal of dredged sediments.

• Method and location for dewatering dredged sediments disposed of upland and disposal of associated water.

• Other performance standards in Section 111.B. of this SOW.

ENR Layer/Dredge Residuals Management Layer Elements:

• Appropriate physica l and chemical characteristics of materials to be used for sediment ENR layer and dredge residuals management layer.

• Method for Identifying and testing clean source materia l{s), including acceptance criteria for such sediment.

• ENR layer and dredged management residual layer placement techniques.

• Selection of ENR layer material and dredge residuals management layer material suitable for colonization by aquatic organisms.

• ENR placement calculations for clean material.

Verification and Long Term Monitoring Elements

• Description/outline of proposed cleanup verification methods for remedial action construction, including compliance with ARARs that will be addressed in Construction Quality Assurance Plan (CQAP) and LTMMP and identify the conclusion of the CQAP activities and beginning of LTMMP activities.

More information about the expected contents of the CQAP, LTMMP and other plans associated with remedial action design and construction is provided in Attachment 1.

5. Intermediate Design Deliverables (60%}

If approved by the EPA, the Respondent may submit Intermediate Design Deliverables in the form of agreed-upon deliverables or technical memoranda to facilitate the efficient review and approval of the final remedial design by the EPA. Intermediate Design Deliverables may include a draft CQAP, draft LTMMP, draft QAPP/FSP for remedial action construction, or may address other specific technical or design issues. Any remedial design data not available for submission as part of the Preliminary (30%) Design sha ll be submitted as an intermediate design deliverable.

If submitted, the Intermediate Design may include or discuss the following:

a. Results of additional field sampling.

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b. Plans, drawings, and sketches, including an outline of required specifications not otherwise provided in detail and a list of al l final drawings to be included in pre-final and final design documents.

c. Design assumptions, parameters, design restrictions and objectives for riprap/concrete/bulkhead and pile removal and replacement, excavation, dredging ENR and dredge residual management layer.

More Information about the expected content of the CQAP, LTMMP and other plans associated with remedial action design and construction is provided in Attachment 1.

6. Pre-final (90%) and Final (100%} Designs

The Respondent shall submit the Pre-final Design when the design effort is ninety percent (90%) complete and shall submit the Final Design when the design effort is one hundred percent (100%) complete. The Pre-final Design shall fully address all comments made to the preceding design submittal(s). The Final Design shall fully address all comments made to the Pre-final Design and shall include reproducible drawings and specifications.

The Pre-final and Final Design submittals shall include those elements listed for the Preliminary Design, as well as the fol lowing (un less previously submitted as an Interim Design Element approved by the EPA}:

a. Final plans and specifications.

b. Draft CQAP.

c. Draft Water Quality Monitoring Plan.

d. Draft QAPP/HSP/FSP for remedial action construction activities.

e. Draft Permitting and Site Access Plan.

f . Draft Site Management Plan (includes Contingency Plan, Pollution Control Plan, Transportation and Disposal Plan, Green and Sustainable Remediation Plan, and Climate Change Adaptation Site Plan).

g. Draft ICIAP.

h. Draft LTMMP.

i. Draft Biological Assessment.

j. Draft Capital and Operation and Maintenance Cost Estimate.

k. Final Construction Project Schedule.

I. Any additional plans identified in the Remedial Design Work Plan.

More Information about the expected content of plans associated with remedial action design and construction is provided in Attachment 1.

C. Remedial Action Work Plan

The Respondent shall submit a Remedial Action Work Plan in accordance with the schedule set forth in Section V of this SOW. The Remedial Action Work Plan shall provide a detailed description of the remediation and construction activities, including how construction activities (e.g., site-monitoring, material staging and handling) are to be implemented by the Respondent and coordinated with the EPA. When describing implementation of the remedial action, the Respondent shall identify discrete elements of the remedial action for purposes of monitoring construction activities as they occur. The

12


following shall be considered examples of discrete elements of the remedial action under this SOW: removing debris, riprap, bulkheads and pilings, excavating or dredging sediments, backfill, placement of ENR layer and/or dredge residual management layer, and disposal of removed sediments, debris, bulkheads, riprap and pilings.

The Remedia l Action Work Plan shall include, but not be limited to:

• The schedule for completion of the remedial action.

• Method for selection of the contractor.

• Schedule for developing and submitting other required remedial action deliverables.

• Methods for satisfying permitting requirements.

• . Tentative formulation of the remedial action team and lines of communication.

• Methodology for implementing the Contingency Plan(s).

• Project Schedule.

The Remedial Action Work Plan also shall include the methodology for implementation of the CQAP and a schedule for implementation of all remedial action tasks Identified in the final design submittal and shall identify the initial formulation of the Respondent's remedial action project team (including but not limited to, the Supervising Contractor).

After the contractor has been selected, the Respondent shall submit the fol lowing deliverables with submission of the Remedial Action Work Plan (unless previously submitted and approved by the EPA):

1. Final CQAP.

2. Final Water Quality Monitoring Plan (with specific QAPP/FSP).

3. Final QAPP/Final HSP/Final FSP for remedial action construction activities.

4. Final LTMMP.

5. Final Permitting and Site Access Plan.

6. Fina l Site Management Plan (includes Contingency Plan, Pollution Control Plan, Transportation and Disposal Plan, Green and Sustainable Remediation Plan, and Climate Change Adaptation Plan).

7. Final ICIAP (including draft or completed Proprietary Control Plan).

8. Final Biological Assessment.

9. Final Capital and Operation and Maintenance Cost Estimate.

10. Final Project Implementation Schedule.

11. Final Construction Quality Management Plan.

12. Erosion and Sedimentation Control Plan.

13. Survey Plan.

14. Archeo logical Monitoring and Discovery Plan.

15. Dredge and Debris/Piling Removal Support System Plan.

16. Dewatering Plan.

13


17. Construction Water Management Plan.

18. Settlement Monitoring Plan.

19. Excavation, Dredging and Backfill Plan.

20. Vessel Management Plan.

21. Equipment Decontamination Plan.

More information about the expected content of plans associated with remedial action design and construction is provided in Attachment 1.

D. Remedial Action Construction

The Respondent shall implement the remedial action as detailed in the approved Final Design and Fina l Remedial Action Work Plan. The following activities shall be completed in constructing the remedial action.

1. Performance Monitoring and Construction Quality Assurance

Performance monitoring shall be conducted to ensure that all performance standards are met, including cleanup verification methods and methods for determining compliance with performance standards and ARARs. The CQAP under this task shall address all performance standards related to the remedial action construction, including the criteria described in Section Ill of this SOW. Supporting documents shall provide a mechanism to ensure that all performance standards for the remedial action construction are met. Supporting documents to the CQAP shall include QAPPs, HSPs, and FSPs for sampling during all phases of future Site work. The expected contents of these plans are described in Attachment 1.

2. Preconstruction Inspection and Meeting

The Respondent shall participate with the EPA, the State, and the Tribes in a preconstruction inspection and meeting to:

a. Review methods for documenting and reporting inspection data, and compliance with specifications and plans including methods for processing design changes and securing EPA review and approval of such changes as necessary.

b. Review methods for distributing and storing documents and reports.

c. Review work area security and safety protocols, including that safe zone, contaminant reduction zone and hot zone are set up and clearly delineated and project signage is in place.

d. Demonstrate the construction management is in place, and discuss any appropriate modifications of the construction quality assurance plan to ensure that Site-specific considerations area addressed.

e. Conduct a Site walk-about/boat tour to verify that the design criteria, plans, and specifications are understood and to review materia l and equipment storage locations.

All inspections and meetings shall be documented by the Respondent's designated contact and minutes shall be transmitted to all parties within seven (7) working days of the inspection or meeting.

3. Remedial Action Progress Meetings

The Respondent shall conduct remedial action progress meetings on a regular basis throughout the remedial action. The meetings shall be held at least monthly unless a less frequent schedule is agreed to by the EPA. At a minimum, the Respondent shall address the following at progress meetings:

14


a. General progress of construction w ith respect to remedial action schedule.

b. Project health and safety, including monitoring activities, remova l and backfill activities, water quality monitoring and site security.

c. Project Status, including work hours, temporary erosion control, and community outreach.

d. Problems encountered and associated action items.

e. Pending design, personnel or schedule changes requiring EPA review and approval.

f. Results of any remedial action ver.ification sampling and associated decisions and action items.

4. Pre-final Construction Inspections

Within thirty (30) days after the Respondent makes preliminary determinations that construction is complete for each discrete element of the remedial action, as defined in the Fina l Remedial Action Work Plan, the Respondent shall notify the EPA, the State and the Tribes for the purposes of conducing a prefinal inspection.

The pre-final inspections shall consist of a walk-through/boat tou r inspection of the entire complete remedial act ion element with the EPA. The inspection is to determine whether each project element is complete and consistent with the contract documents and the Remedial Action Work Plan, to review compliance with the CQAP, and to review field changes and change orders, and verify that the construction performance standards for each element of the remedy have been achieved. The Respondent shall certify that each discrete element ofthe remedy has been constructed to meet the purpose and intent of the specifications. Retesting shall be completed by the Respondent where deficiencies are revealed. Within seven (7) days of the inspection, a pre-final construction inspection report shall include both a summary of the major CQAP results and field changes, as well as minutes fro"l t he inspection. The Pre-fina l Construction Inspection Report shall outline the outstanding construction items, actions required to resolve items, completion date for these items, and a proposed date for final inspection. The completion dates for the items identified in the Pre-Final Construction Report shall be within thirty (30) days of the pre-final construction inspection unless otherwise agreed to by the EPA.

5. Final Construction Inspections

Within thirty (30) days after completion of any work identified in the Pre-final Inspection Report, the Respondent shall notify the EPA, the State, and the Tribes for the purposes of conducting a final inspection of each discrete remedia l action element. The final inspection sha ll consist of a walkthrough/boat inspection of each discrete element of the remedial action by the EPA and the Respondent. The pre-final inspection reports shall be used as a checklist with the final inspection focusing on the outstanding construction items identified in the pre-final inspections. Confirmation shall be made that outstanding items have been resolved. Resolution of all outstanding items shall be documented in a letter or report within 30 days of the final inspection.

6. Reports

The Respondent shall follow the U.S. EPA guidance for preparing Remedial Action Reports, described in "Close Out Procedures for National Priorities list Sites," OSWER Directive 9320.2-22, May 2011, in submitting the following reports :

a. Remedial Action Construction and Completion Report

15

Lockheed West Seattle UAO Statement of Work for RO/RA Appendix B

Within 90 days of the last successful final construction inspection and demonstration that all construction performance standards have been attained, Respondent shall submit a Remedial Action Construction and Completion Report. The report shall include a summary of all information demonstrating that all of the performance standards, including the Cleanup Levels and RALs listed in Attachments 3 and 4, have been attained.

The report shall provide as-built drawings, signed and stamped by a professional engineer, showing the area and depth of the location remediated, and other supporting information to document that the CQAP was followed .. The final report shall include a good faith estimate of total costs or a statement of actual costs incurred in complying with the UAO, a listing of quantities and types of material removed off-site or handled on-site, known concentrations above Cleanup Levels and location they are left onSite, a listing of the ultimate destination(s) of those materials, a presentation of the analytical results of all sampling and analyses performed (including a map showing the locations of any confirmatory samples), and accompanying appendices containing all relevant documentation generated during the remedial action (e.g., manifests and chains of custody), final green and sustainable tracking categories and volumes and lessons learned. All analytical data collected under the UAO shall be provided electronically to EPA in a format compatible with that used for the Rl/FS at the Site. The final Water Quality Monitoring report may be submitted as an appendix to the report. In addition, the report shall contain the following statement, signed by a registered professional engineer and a responsible corporate official of the Respondent:

"To the best of my knowledge, after thorough investigation, I certify that the information contained In or accompanying this submission is true, accurate, and complete. I am aware there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations."

When submitting the final Remedial Action Construction and Completion Report to the EPA, the Respondent shall identify the Work that has been fully performed in accordance with the UAO, and shall identify all continuing obligations, including post-remedial ICs and monitoring, required by the UAO, as approved by the EPA. The Respondent shall also identify a time line for continuing obligations, with "to be determined" identified for all obligations for which a time line cannot reasonably be fixed.

The Remedial Action Construction and Completion Report shal l also contain a description of ICIAP implementation, including draft or completed proprietary controls, to date, with all copies of all implementing documentation, a schedule for completion of all outstanding ICIAP tasks, and a proposed submittal date for a final ICIAP documenting complete implementation of the ICIAP.

If, after review of the written report, the EPA, after reasonable opportunity to review and comment by the State and the Tribes, determines that any portion of the Work has not be completed in accordance with the UAO, the EPA will notify the Respondent in writing of the activities that must be undertaken by the Respondent pursuant to the UAO to complete the Work provided. However, the EPA may only require Respondent to perform activities to the extent that such activities are consistent with the "scope of the remedy set forth in the ROD." The EPA will set forth in the notice a schedule for the performance of such activit ies consistent with the UAO and the SOW or require the Respondent to submit a schedule to EPA. The Respondent shall perform all activities described in the notice in accordance with the specifications and schedule established therein.

b. Request for Close Out

16

Lockheed West Seattle UAO Statement of Work for RD/RA AppendixB

Site completion signifies the end of all Work at the site. When this occurs, Respondent may request final Site Close Out. The criteria for determining completion include:

• All remedial decision documents have been completed and the selected remedy is consistent with CERCLA, the NCP, and EPA policy and guidance.

• All Work has been completed and appropriately documented in the site file.

• All ICs and proprietary controls are in place (Order, Section XIII),

• All criteria for discontinuing sediment quality monitoring for LTMM have been met.

c. Final Close Out Report

The site completion designation generally means that the response actions at the site were completed and it is anticipated that no further response is necessary to protect human health and the environment. The criteria for determining completion include:

• All remedial decision documents have been completed and the selected remedy is consistent with CERCLA, the NCP, and EPA policy and guidance.

• All Work has been completed and appropriately documented in the site file .

• All !Cs and proprietary controls are in place.

The ePA typically prepares a Final Close Out Report to document site completion. However, the Respondent may be requested to provide data to support the justification for site completion.

E. long-Term Maintenance, Monitoring, and Institutional Controls and Proprietary Controls

Long-term performance standards to be achieved after remedial action construction is completed shall be atldressed in the LTMMP and the ICIAP. The expected contents of these plans are described in Attachment 1. The resu lts of these monitoring programs will be reported in long-term monitoring reports and 5 Year Review Reports.

V. SCHEDULE

The schedule for notification to EPA or submission of major deliverables to the EPA is listed below. If the date for submission of any item or notification required by this SOW occurs on a weekend or state (Washington) or federal holiday, the date for submission of that item or notification is extended to the next working day following the weekend or holiday.

17


Schedule for Submission of Major Deliverables # Submission Due Dat e•·b

1 Selection of the Supervising Remedial Design 10 days after the Effective Date of the UAO Contractor and Submittal of quality assurance system that complies with Quality Systems for Environmental Data and Technology Programs: Requirements with Guidance for Use per Section IX of the UAO (Designation of Contractors and Project Coordinators)

2 Remedial Design Work Plan including Remedial f>raft within sixty (60) days after notice of authorization Design QAPP/HSP/FSP to proceed pursuant to Paragraph 10 of UAO

3 Monthly Progress Reports As specified in Section XVI, Paragraph 31 of the UAO

4 Pre-Remedial Design Field Work Initiated within thirty (30) days of EPA's approval of the final Remedial Design Work Plan

s Preliminary Design (30%) Sixty (60) days after submittal of the Pre-Remedial Design Data Report to EPA

6 Intermediate Design Deliverables 60 days after EPA conditional approval of Preliminary Design or as specified in the approved RD Work Plan

7 Pre-fina l Remedial Design (90%) One hundred and eighty (180) days after the EPA's approval of the Preliminary Design or the Intermediate Remedial Design submittal (If submitted) - assuming design build path forward. 90 days If conventional path forward.

8 Final Remedial Design (100%) Forty-five (45) days after the EPA's approval of Pre-final Design

9 Remedial Action Work Plan Within forty-five (45) days after approval of the Final Remedial Design submittal

10 Award Remedial Action Construction Contractor(s) Within thirty (30) days after approval of the Final Remedial Design submittal

11 Notificat ion for Remedial Action Start Provide notification to the EPA forty-five (45) days prior to Initiat ion of fieldwork to allow the EPA to coordinate field oversight activities

12 Pre-Construction Inspection and Meeting Fifteen (15) days after award of remedial action construction contract(s)

13 Initiate Construction of Remedial Action Within thirty (30) days after approval of the Remedial Action Work Plan, consistent with environmental windows for in-water work. EPA shall not approve the Remedial Action Work Plan untll the UAO has been

entered.

14 Completion of Construction As approved by the EPA in remedial action construction schedule

15 Pre-final Construction lnspection(s) /Meeting(s) No later than thirty (30) days after completion of construction for each discrete element of the remedial action

16 Pre-final Construct ion Inspection Letter/Report{s) W ithin seven (7) days after the pre-final construction inspection for each discrete element of the remedial action

18

Lockheed West Seattle UAO Statement of Work for RD/RA · Appendix B

Schedule for Submission of Major Deliverables I# Submission Due Date•i,b

17 Final Construction lnspection(s) Within thirty (30) days after completion of work identified ln each pre-final construction inspection letter

18 Final Construction Letter/Report(s} Within fifteen (15) days after each final construction Inspection/meeting

19 Remedial Action Construction and Completion Within 90 days after last final construction inspection Report (including Request for Certification of has been completed EPA and remedial action Completion of the Remedial Action) .objectives, including performance standards, have

been obtained

20 Request for Close-out Upon meeting criteria in Section B.6.4.b

21 Close Out Report To be prepared by the EPA

22 Long-term Monitoring Reports No later than sixty (60) days after LTMM sampling conducted

23 Completion of ICs and Proprietary Controls Within sixty (60) days after the Remedial Action Construction Report

a) Due dates shown are for Initial draft dellverables. Revised deliverables are due 30 days from the date of the EPA's comments, unles.s otherwise indicated by the EPA. Documents become final upon approval by the EPA.

b) Consistent with Section Ill of the UAO, days shall mean calendar days. If due dates fa ll on a weekend or holiday, deliverables will be submitted to the EPA on the next business day.

19


Figures

20

LOCKHEED WEST SEATTLE SOW FIGURE 1

Location Map

Ell1ot1Bay #

~~\ Seattle

Lockheed West Site

\

~n--- ... -Former Shipyard Uplands

Legend

D

Duwamish Head ,

Greenbelt .

Approximate Site Boundary: --Site boundaries will be finalized rn the Record or Decision. Highway

LSSOU Major Road

Local Road TS SOU

RA5 - Former Shipyard Uplands OU ES1005t:2034318S£A

Port of Seattle Terminal 5 .,

Creek Railroad

Greenbelt

Lockheed Shipyard Sediment Operable Unit Todd Shipyard Sediment Operable Unit Operable Unit

:::> 0 >-

! s ~ .. •

Elliott Bari

'E • !) >.

0 .e. rn s::. U) "' ._

'tJ 'tJ

~

~· _.....----Harbor Island

:::>

·~ 0

j :II.

:::> :; 'tJ ~ u c

0 _g! I I

JI rn i U> :::> _, .. I in

T SW Spokane Sf

Figure 1 Lockheed West Site Location and Vicinity Map

0 500 1,000 ( 11:] TETRA TECH Foot

LEGEND

§

CJ CJ

D Q D CJ

LOCKHEEDWE$TSTUDYAREA

REMOVAL TO CSL

REMO\/AI.. 10 SOS (WEST W•iTEl>;WAY NAVIGATION CHANNEi.) FOU.O~D BY PLACEMENT OF THIN LAYER OF CLEAN lllATERIAL TO lllANl\GE DREDGE RESIDUALS

RBI.OVAL TO SOS IN SHORELINE/INTERTIDAL. AND FORMER SHIPWAY AREAS

ENR TO STUDY AAEA BOUNDARY

FORMEll DRY DOCK AREAS

HABITAT SOFTENINGIENHANCEMENT IN EXISTING RIPRAP AREAS

H;t.8!TAT MIX. PlACEMENT

RIPAAP ;t.RMOR STABILIZATION

BACKFILL lo EXISTING ELEVATIONS

REMNANT PILING AREAS (OTHER S~1AU.ER AREAS OF RBINANT PILINGS ARE EXCWOED)

Notes· N:; • Acre SQS = &edlmen1 QualHy Standard CSL.c. Cleanup sc·ree-ning Level CY e Cubic Yard ENR = Enhanced Natural Recovery

•-==---==------- Feel 12 5 250 500

Removal-Focus Alternative 3C Plus Alternative Description: Removal of sediment with coooentralions above the CSL within the fonner Ory Dock areas and remaining CSL footprint, and ENR to the Study Area Bounda.ry. Removal to SQS in portions of the West Waterway navigation Cl\annet. shoreline/intertidal, area. and former shipway area.

Remediation Below -10 ft MLLW

Removal ENR Dredge Residual Management Layer

Area IACl 11.6 28.4

11.6

Volume CC'() 151 ,650 45,900

14,000

Former Shipway Area Remediation

Removal Backfill/Habitat Mix

~ Volume tCYl 0.8 6,500 , 9,850

Shorelinallntertldal Remediation

Removal Bad<fill/Habltat Mix Riprap

Are,alACl 1.2 1.2 0.06

Volume ICY\ 9,300

13,100 1,900

Remediation acreages Identified for former shipway and shoreline/Intertidal areas. are a subset of the tolal site area ol 40acres.

RA5 · Former Sl\ipyard Uplands

Area 5 - locafll:ed Subtidal Areas

So1J1ce: Adapled from Tetta Tt.--ch, May 2012.. Fll\al RllFS.

Figure 2 Selected Remedy-Alternative 3C Plus Lockheed West Superfund Stte Sea~. WA

Attachment 1 Expected Contents of Deliverables and EPA

Guidance

Attachment 2

ATTACHMENT 1

Expected Contents of Deliverables and EPA Guidance This attachment provides descriptions, content requirements, and associated guidance documents for the major deliverables identified in the Statement of Work, as well as references for general guidance documents. The documents covered in this attachment include:

1. Construction Quality Assurance Plan 2. Water Quality Monitoring Plan 3. Quality Assurance Project Plans 4. Field Sampling Plans s. Health and Safety Plan 6. Permitting and Site Access Plan 7. Site Management Plan (including Contingency Plan, Pollution Control and Mitigation Plan.

Transportation and Disposal Plan, Green and Sustainable Remediation Plan, and Climate Change Adaptation Plan)

8. Biological Assessment 9. Capital and Operation and Maintenance Cost Estimate 10. Construction Quality Management Plan 11. Construction Project Schedule 12. Long~term Monitoring and Maintenance Plan 13. Institutional Controls Implementation and Assurance Plan

This attachment does not include descriptions or content requirements for certain other plans listed in the Statement of Work because they are specific to details of the remedial action and will need to be developed in accordance with design and engineering specifications. The plans not covered in this attachment include:

• Archeological Plan • Erosion and Sedimentation Control Plan • Survey Plan • Earthwork Plan • Dredge and Debris/piling Removal Support System Plan • Dewatering Plan • Construction Water Management Plan

• Settlement Monitoring Plan • Excavation, Dredging, and Backfill Plan • Vessel Management Plan • Equipment Decontamination Plan (may be part of the Pollution Control and Mitigation Plan) .

1

1. Construction Quality Assurance Plan

Attachment 1

Expected Contents of Deliverables and EPA Guidance

The Construction Quality Assurance Plan (CQAP) describes the Site-specific components of the performance methods and quality assurance program which shall ensure that the completed project meets or excess all performance standards and design criteria, plans, and specifications, including achievement of Cleanup Levels.

The CQAP shall contain, at a minimum, the following elements:

• Responsibilities and authorities of all organizations and key personnel involved in the design and construction of the remedial action, including the EPA and other agencies.

• Qualifications of the Construction Quality Assurance (CQA) Official. Establish the minimum training and experience of the CQA Officer and supporting inspection personnel.

• Performance Standards and Methods. Describe all performance standards and methods necessary to ensure implementation of the remedial action construction, in compliance with ARARs and identified site-specific performance standards. Performance monitoring requirements shall be stated to demonstrate that best management practices have been implemented for dredging operations, transportation or dredged material, and proper cap placement techniques.

• Inspection and verification activities. Establish the observations and tests that will be required to monitor the construction and/or installation of the components of the remedial action. The plan shall include the scope and frequency of each type of inspection to be conducted. Inspections shall be required to measure compliance with environmental requirements and ensure compliance with all health and safety procedures.

• Sampling activities. Establish requirements for quality assurance sampling activities including the sampling protocols, sample size, locations, frequency of testing, acceptance and rejection data sheets, problem identification and corrective measures reports, evaluation reports, acceptance reports, and final documentation.

• Documentation. Reporting requirements for CQA activities shall be described in detail in the CQAP. This shall include such items as daily summary reports, inspection data sheets, problem identification and corrective measures reports, design acceptance reports, and final documentation /storage. A description of the provisions for final storage of all records consistent with the requirements of the Consent Decree shall be included.

• Field Changes. Describe procedures for processing design changes and securing EPA review and approval of such changes to ensure changes conform to performance standards, ARARs, requirements of this SOW, are consistent with the Cleanup Levels and are protective of human health and the environment.

• Final Reporting. Identify all final CQAP documentation to be submitted to EPA in the Remedial Action Construction Report or Remedial Action Completion Report.

Guidance: Construction Quality Assurance for Hazardous Waste Land Disposal Facilities (EPA/530(S)SW-86-301, 1987) and Quality Assurance and Quality Control for Waste Contaminated Facilities (EPA/600/R-93/182, 1993). Note - these guidance documents primarily address landfills and related waste containment facilities.-

2. Water Quality Monitoring Plan

The Water Quality Monitoring Plan shall detail water quality monitoring requirements to confirm compliance with water quality standards (as defined by substantive requirements of Clean Water Act

2

Attachment 1


Section 401 Water Quality Certification} during dredging, ENR placement, bank soil excavation and backfill, dredged material dewatering and loading, removal of pilings, and other potential water disturbances during remedial action construction. The plan shall describe the specific water quality monitoring requirements, sampling design and rationale, applicable water quality standards and points of compliance, team organization and responsibilities, sampling schedule, monitoring and sampling methods, data management and reporting, and procedures for responding to water quality exceedances. A quality assurance project plan (QAPP} and field sampling plan (FSP) specific to water q,uallty monitoring, as well as a health and safety plan, shall be included in this deliverable. A 401 Memo which identifies the Clean Water Act,§ 401 substantive water quality requirements for the CERCLA action will be written by the EPA.

3. Quality Assurance Project Plans

The Respondent shall develop Site-specific QAPPs covering sample analysis and data handling for sampling during all phases of future Site work, including sampling during remedial design, remedial construction, and long-term monitoring.

Guidance: Requirements for Quality Assurance Project Plans (QA/R-5) (EPA/240/B-Ol/003f March 2001 [Reissued May 2006]). EPA Quality Manual for Environmental Programs (EPA CIO 2105-P-01-0, May 2000). EPA Requirements for: Quality Management Plans (QA/R-2) (EPA/240/B-01/002, March 2001). Specifications and Guidelines for Quality Systems for Environmental Data Collection and Environmental Technology Programs (American National Standard, January 5, 1995).

4. Field Sampling Plans

The Respondent shall develop FSPs describing sample collection activities associated with each QAPP. The FSP should supplement the QAPP and contain all relevant elements described in Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA (EPA/540/G-8?/004 OSWER Directive 9355.3-01, October 1988).

5. Health and Safety Plan

The Respondent shall develop HSPs which are designed to protect on-Site personnel and area residents from physical, chemical, and all other hazards posed by the remedial action and associated sampling activities.

The HSPs shall follow the EPA guidance, Health and Safety Roles and Responsibilities at Remedial Sites {EPA OEER 9285.1-02, July 1991) and all OSHA requirements as outlined in 29 C.F.R. 1910 and 1926. The Respondent may utilize existing project HSPs or other company/contractor HSPs provided that the Respondent demonstrates the HSPs have been modified, as necessary, or otherwise sufficiently address the activities covered by this SOW.

6. Permitting and Site Access Plan

The Respondent shall prepare a Permitting and Site Access plan to demonstrate how the design plans will comply with the permitting requirements identified in the Remedial Design Work Plan and shall address any real property and easement requirements. The Plan shall provide a strategy and appropriate information for obtaining agreements for access to the Site or associated areas as necessary for the implementation of the remedial action.

7. Site Management Plan

The Site Management Plan describes how access, security, contingency procedures, management responsibilities, and waste disposal are to be handled. These additional elements may be incorporated

3

Attachment 1


into other deliverables or delivered separately and will include, but not be limited to: (a) Contingency Plan, (b) Pollution Control and Mitigation Plan, (c) Transportation and Disposal Plan, (d) Green and Sustainable Remediation Plan, and (e) Climate Change Adaptation Plan. General descriptions and relevant guidance for these plans are described below.

7 .1 Contingency Plan

The Contingency Plan is written to protect the local affected population in the event of an accident or emergency and shou ld contain the following elements:

• Name of person responsible for responding in the event of an emergency incident;

• Plan and date for meeting with the local community, including local, State and Federal agencies Involved in the cleanup, as well as local emergency squads and hospitals;

• First aid and medical information including names of personnel trained in first aid; clearly marked map with the locations of medical facilities; all necessary emergency phone numbers; fire, rescue, local hazardous material teams; and National Emergency Response Team;

7.2 Pollution Control and Mitigation Plan

The Pollution Control and Mitigation Plan will provide contingency measures for potential spills and discharges from materials handling and/or transportation. It describes methods, means, and facilities required to prevent contamination of soil, water, atmosphere, uncontaminated structures, equipment or material from the discharge of wastes due to spills; provides for equipment and personnel to perform emergency measures required to contain any spillage and to remove and properly dispose of any media that become contaminated due to spillage; and provides for equipment and personnel to perform decontamination measures that may be required to remove spillage from previously uncontaminated structures, equipment, or material.

7.3 Transportation and Disposal Plan

The Transportation and Disposal plan will describe the procedures to be followed in transporting sediment and debris removed from the Lockheed West Site to the selected upland disposal facility. The plan will include descriptions of the waste materials to be transported, the destinations of the wastes, transportation means and routing, on-site traffic control and loading procedures, recordkeeping requirements, health and safety considerations, and contingency plans for spills that might occur during handling, loading, and transportation

7.4 Green and Sustainable Remediation Plan

The Respondent shall submit for EPA approval a plan to promote sustainable technologies and practices for executing the remedial action. A report will be provided at the end of the project as part of the closeout reports. The five goals of the Green and Sustainable Remediation Plan are to:

1. Reduce total energy use and increase the percentage of renewable energy

2. Reduce air pollutants and greenhouse gas emissions

3. Reduce water use and negative impacts on water resources

4. Improve materials management and waste reduction efforts

5. Protect land and ecosystems.

4

Attachment 1


The Green Remediation metrics shall include "materials and waste", "water", "energy", "air'' and "land and ecosystem." And the methods to track GSR performance shall be identified. Use of local materials, facilities and environmentally sustainable business practices shall also be incorporated.

The Green and Sustainable Remediation Plan shall contain all relevant elements described in Methodology for Understanding and Reducing a Projects Environmental Footprint (EPA/542/R12/002 OSWER and OSRTI Directive, February 2012).

7.5 Climate Change Adaptation Plan

The EPA is in the process of developing policies and guidelines for implementation of climate change adaptation protocols to ensure continuing protectiveness of current and future remedies. There is no current guidance detailing the expected content of Climate Change Adaptation Plans. See http:ljepa.gov/climatechange/impacts-adaptation/fed-programs/EPA-impl-plans.html for the most current information.

8. Biological Assessment

The Respondent will prepare a Biological Assessment to ensure compliance with the Endangered Species Act by identifying the presence of threatened, endangered, proposed, or candidate species, or their habitat within the vicinity of the cleanup action. The Biological Assessrnent will characterize baseline conditions of the existing habitat, address potential project impacts the remedia l action may have on these species, their habitat and food stocks. The Biological Assessment will also identify best management practice·s and conservation measures designed to avoid or minimize potential impacts.

Guidance: A Primer on Using Biological Assessments to Support Water Quality Management (EPA 810-R-11-01, October 2011).

9. Capital and Operation and Maintenance Cost Estimate The Pre-final and Final Design submittals shall include an updated cost estimate for completion of remedial action and long-term maintenance and monitoring. This cost estimate sha ll refine the feasibility study cost estimate to reflect the detail presented in the Final Design, with an accuracy of plus 15 percent and minus 10 percent.

Guidance: A Guide to Developing and Documenting Cost Estimates during the Feasibility Study (EPA 540-R-D0-002, OSWER No. 9355.0-75, July 2000).

10. Construction Quality Management Plan

The Respondent shall demonstrate that the proposed contractor has a quality assurance system that complies with ANSI/ ASQC E4-1994, Specifications and Guidelines for Quality Systems for Environmental Data Collection and Environmental Technology Programs (American National Standard, January 5, 1995), by submitting a copy of the proposed contractor's Quality Management Plan (QMP). The QMP should be prepared in accordance with EPA Requirements for Quality Management Plans (QA/R-2) (EPA/240/B-01/002, March 2001, re-issued May 2006) or equivalent documentation as determined by EPA.

11. Construction Project Schedule A final project schedule for the construction and implementation of the remedial action which identifies timing for initiation and completion of all critical path tasks will be submitted as part of the Final Design. The project schedule shall include specific dates for major milestones and completion of the project. The final project schedule will address the Site remedial activities and all other relevant factors that could impact scheduling such as commerce in this vicinity, fish windows, and/or Tribal treaty-protected fishing rights.

5

12. Long-Term Maintenance and Monitoring Plan

Attachment 1


The Respondent shall submit for EPA approval a post-remedial action LTMMP and QAPP (or amendments to the remedial design QAPP) to cover implementation and long-term maintenance and monitoring of the remedial action. The LTMMP sha ll include:

1. Long-term confirmation of maintaining the Cleanup Levels in the intertidal and subtidal portions of the Site.

2. Confirmation sampling in the ENR layer and dredge residuals management areas to ascertain the effectiveness of these remedial actions.

3. Evaluation of the bank excavation and replacement and placement of fish mix.

4. Define triggering weather and/or seismic events that will require monitoring and/or sampling after they occur.

5. Identification of monitoring measures that will be taken after a triggering weather and/or seismic events.

6. Identification of monitoring activities, including file reviews and interviews with the landowner(s) pertaining to any development that has occurred at the Site since the remediation was complete in order to support five-year reviews.

7. Surface water and fish tissue samples will not be collected as part of the five-year review.

The LTMMP shall evaluate and include the following types of monitoring as appropriate, to achieve the monitoring objectives of each element of the remedial action, and will be used for EPA Five-Year Reviews:

• Bathymetry • Sediment chemistry • Sediment bioassays, if necessary • Sediment profile cameras Guidance: Guidance for Monitoring at Hazardous Waste Sites, Framework for Monitoring Plan Development and Implementation {OSWER Directive No. 9355.4-28, January 2004). Contaminated Sediment Remediation Guidance for Hazardous Waste Sites (EPA-540-R-05-012, OSWER 9355.0-85, December 2005).

13. Institutional Controls Implementation and Assurance Plan (including Proprietary Controls Plan)

The Respondent shall submit for EPA approval an ICIAP that follows EPA guidance A Guide to Preparing Institutional Control Implementation and Assurance Plans at Contaminated Sites (OSWER 9200.0-77, EPA-540-R-09-002, December 2012) in order to establish and document the activities associated with Implementing and ensuring the long-term stewardship of ICs and to specify the persons/and/or organizations that will be responsible for conducting these activities. The details of how the Uniform Environmenta l Covenant Act (UECA) covenant and the Elliott Bay fish consumption advisory shall be specifically implemented, maintained, enforced, modified, and terminated (if applicable) at the Site shall also be included.

14. General Guidance

• Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA (EPA/540/G-89/004 OSWER Directive 9355.3-01, October 1988).

6

Attachment 1


• EPA Oversight of Remedial Designs and Remedial Actions Performed by Potentially Responsible Parties (EPA 540 G-90.001, April 1990).

• Contaminated Sediment Remediation Guidance for Hazardous Waste Sites (EPA-540-R-05-012, OSWER 9355.0-85, December 2005).

• Remedial Design/Remedial Action (RD/RA) Handbook (OSWER 9355.0-048, EPA 540/R-95/059, June 1995).

• Close out Procedures for NPL Sites. (OSWER Directive 9320.2-22 May 2011).

15. Data Submittals

Sampling and monitoring data should be submitted in standard regional Electronic Data Deliverable (EDD) format. The RlO Data Deliverable Guidance for data submittal shall be used. The Respondent will be responsible for directly loading the data Into the public Water Quality Exchange (WQX) database. The Respondent will provide the EPA with a copy of the files that were created to load data into the WQX database. Data that will be loaded into the publicly available database w ill include monitoring data-including concentrations of contaminants. Examples of electronic data submittal templates and additional guidance on the form of t he submissions will be provided by the EPA. Contact Sue McCarthy at (206-553-2598 or Matt Gubitosa at (206) 553-4059 with questions or to request assistance.

GIS data shall also be submitted to the EPA following the procedures in the "U.S. EPA Region 10 Geographic Information Systems (GIS) Data Deliverable Guidance for External Parties", which is provided at the end of this attachment. The GIS data should be submitted at the same time as the final reports are submitted to the EPA. This includes sampling plans, Quality Assurance Project Plans, monitoring reports, studies, pre-remedial design sampling reports, where GIS and mapping programs were used to generate maps, diagrams, and other visual aids. Discs containing this information should be sent to the EPA Project Manager. Each file must include an attribute name for each site unit or sub-unit submitted. Consult http://www.epa.gov/geospatial/policies.html for any further available guidance on attribute identification and naming. Contact Matt Gubitosa at {206) 553-4059 with questions or to request assistance for GIS submission requirements.

7

Attachment 2

Attachment 2 Description of Selected Remedy

Attachment 2

Description of Selected Remedy

The Selected Remedy for the Lockheed West Site addresses unacceptable human health risks associated with seafood consumption, net fishing, clamming, and beach play, and ecological risks posed to benthic invertebrates, fish, and birds. This cleanup is a fina l action.

The Selected Remedy is expected to achieve substantia l long-term risk reduction and allow the Site to be used for the current and reasonably anticipated future uses. This ROD documents the final remedial action for the Site.

The Selected Remedy includes the fol lowing elements:

• Dredge the former shipway area (westernmost portion of the Site} to remove sediments with contaminants of concern (COC) concentrations above the sediment quality standards (SQS}, which are the lower of the two sediment comparison criteria under the Washington State sediment management standards (SMS) 5. A thin layer (6 to 9 inches} of clean material will then be placed to cover dredge residuals and promote enhanced natural recovery (ENR}.

• Dredge the Navigation Channel in the West Waterway to remove sediments with COC concentrations that exceed the SQS, and place a thin layer of clean material to cover dredge residuals and promote ENR.

• Dredge the former Dry Docks 1 through 3 area and other localized areas throughout the Site to remove sed iments with COC concentrations above the cleanup screening levels (CSLs), which are the higher of the two SMS comparison va lues. A thin layer of clean materia l will then be placed to cover dredge residuals and promote ENR.

• Place a thin layer of clean material to promote ENR over the remainder of the subtidal area.

• Dredge the shoreline bank and intertidal zone (defined as areas extending from mean high higher water at plus[+] 11.3 feet mean lower low water (MLLW) to minus[-] 10 feet MLLW) to remove sediments with COCs at levels above the SQS, as structurally practicable, and backfill with clean material to grade.

• Remove debris, riprap, failing wooden bulkheads, and pilings as necessary or directed by the EPA, and dispose ofthem offsite.

• Dispose of dredged sediments and other related remediation materials by truck or rail transport to an appropriate offsite upland facility permitted to accept these materials.

• Place institutional controls (ICs) in the form of a proprietary contro l that runs with the property and that requires coordination with the EPA and management of any residual contamination (above Cleanup Levels) that is disturbed or encountered in the event of future excavation or dredging within the boundaries of the Site. In addition, the current fish advisory for Recreational Marine Area 10 (Elliott Bay) under the Puget Sound Fish Consumption Advisory, established by the Washington

s The Washington State SMS (Washington Administrative Code (WAC) 173-204) provide a basis for the management and reduction of pollutant discharges and guide contaminated sediment cleanup efforts for the protection of benthic receptors. The standards include regionally developed numerical sediment criteria that protect the benthic (that ls, bottom-dwelling) invertebrate community. The·benthic invertebrate numerical criteria are not intended to be protective of human health with regard to consumption of bloaccumulative contaminants in seafood. There are two levels of chemical and biological SMS. The rnore stringent level, the SQS, is the sediment cleanup objective and corresponds to a sediment quality that has no acute or chronic adverse effects on benthic marine OFganisms. The less stringent level, the CSL, is the level above which minor adverse effects may occur in benthic marine organisms.

1

Attachment 2

Description of Selected Remedy

State Department of Health, to reduce human exposure from ingestion of contaminated seafood will continue to be posted at the Site. The EPA can revise the fish advisory as warranted.

• Conduct post-remedial confirmation sampling of sediment and surface water.

• Conduct long-term monitoring at the Site. The monitoring interval and other criteria will be defined in the Long-term Monitoring and Maintenance Plan (LTMMP). Additional monitoring, following identified triggering weather and seismic events, also will be defined in the LTMMP. If such events occur, bathymetric monitoring will be implemented to determine whether one or more components of the Selected Remedy are affected.

• Conduct five-year reviews, which will include sediment sampling for risk-driver COCs, bathymetric surveys to ensure that the thin cover/ENR layer remains in place, file reviews, and interviews with the landowner(s) pertaining to any development that has occurred at the Site since remediation was completed. Surface water and fish tissue samples will not be collected as part of five-year reviews.

A technical impracticability (Tl) waiver of the Federa l ambient water quality criteria (AWQC) for arsenic is part of the Selected Remedy. As described in the Tl waiver rationale memorandum (EPA, 2013), it is technically impracticable for remediation of contaminated sediments at this small, 40-acre Site to measurably improve the overall water quality for arsenic within the larger Elliott Bay, and there are no treatment technologies capable of surface water treatment for arsenic at the scale of Elliott Bay (approximately 5.42 x 1011 gallons, assuming no replenishment from Puget Sound). It is expected that arsenic concentrations in Elliott Bay would remain the same after Site cleanup. All Site-related arsenic sources are or will be cont rolled after sediment remediation. The Tl waiver would apply only to AWQC exceedances at the Site and would not prevent the EPA or other regu latory agencies from taking actions re lated to AWQC exceedances.

The NCP establishes the expectation that treatment will be used to address the principal threats posed by a site whenever practicable, in accordance with Federal regulations (40 CFR 300.430[a] [1] [iii] [A]). In general, principal threat wastes are those source materials considered to be highly toxic or highly mobile that generally cannot be contained in a reliable manner.

There is no source or other material at this Site that constitutes principal threat waste. Contaminants identified at the Site are considered low-level threats and are not highly mobile or highly toxic. For example, the maximum polychlorinated biphenyl (PCB) sediment concentration at the Site Is 3 parts per million (ppm), with an average of 0.42 ppm. These values are well below the SO-ppm threshold for designation as a Toxic Substances Control Act (TSCA) waste. Similarly, the maximum dioxins/furans level expressed as the tetrachlorodibenzodioxin (TCDD) toxicity equivalent (TEQ) is 13.8 parts per t ri llion (ppt), as compared to the background concentration of 2 ppt. Metals concentrations also do not trigger principal threat waste issues, and no Resource Conservation and Recovery Act of 1976 (RCRA)-listed hazardous wastes will be generated during Site remediation.

2

Attachment 3 Summary of Compliance Zones and Cleanup

Levels for Contaminants of Concern

LOCKHEED WEST SEATTLE SOW ATTACHMENT 8 Attachment 3 Oeanup levels to be Achieved in Surface Sediment at tlie End of Construttion

Lowest Applicable Cle•n~p Level for

coc Risk Driver? Compliance Bas-ls• c,omptiante Zone CompUance Zone

Totll PO!s ' Yes Subtid•I Surfaoo S.diment (SWAC) Oto!Ocm 2 lntett.iol Surra.,.. S•dlr™'11l (SWAC) Oto45 cni 2

12 Subtidal surf.a Sed1ment (polntl OtolOcm

ISO

cPAHs Y•• Subild•I SurfKc Sedlm•nt (SWACJ OtolOc:rn 9

Intertidal Surfoc<> Scdl-nt (SWAC) Oto4Scm 9

Subtld• I SUrf•ce Sediment (point)

Ar,.,nlc Ye> Subtldal Surface Sedlm•nl (SWACI Oto !Dem 7

Intertidal Surface Sediment (SWAC) Dto45cm 7

SubUd•I Surfoce Sediment (point! o to !Dem 57

Lcod y., Subtidal SurliK,e Sedlm•nt (SWACI OtoJ.Ocm u lnterlld•I Sumco Scdimont (SWAt1 Oto45cm 11

Subtldal SUrfaco Sediment {point)

Trlhu1yifln Yes Subti<fal 5'Jrf>ce Sedlmont (SWACJ 010 lO c.m 150

lntDrtldal Surrac. S..dirnonl (SWACJ Oto4S cin 2,000

Subtld• l 5'Jr100! Sedl1tienl {pofnt)

Copper Yes Sub1idol ~rf0<e Sediment (SWACJ Oto IO cm 400

lntortid)I Surfaco Sediment (SWACI 0 lo4S cm 400

SUbtid•I SUrfoce Sediment (point) Oto lOcm 390

Mem.irv Yes Subtldai Surface Sediment (SWACJ 0 to lOc:m 0.41

Intertidal Surface Sedimenl (SWAC) Dto45cm 0.17

Subtidol surface Sediment (polnO Oto lDcm 0.41

Oknlns/furans YM Sublidal 5'Jrface SOdiment {SWACJ OtolOem 2

Intertidal Sumco Sediment (SWACJ Oto4Sc:m 2

Subtld•I surface Sediment (point)

Anllmonv No Subtkial s • .,r • .., Sediment (SWACJ

ln!ertldal Surf•c• Sediment (SWAC)

Subtidal Surface Sediment (point! D to !Dem 150

Cadmium No Sublfdal Surla<e Sediment {SWAC) Oto lOcm 0.398

Intertidal Surface Sediment (SWAC) Oto4Scm 0.398

Subtldal Surfa«>S.dlment (point)

Chromlum No Subtld>I SUrf•«i Sediment (SWAC)

intertidal Surface Sediment (SWACI

Subtidol Surf'"'° Sediment {point! D to !Dem 260

Cob•ll No 5ubtidol 5'Jrf.,;0Se<lirnent (SWACJ

intortldal Surra<• SedlmMl (SWAC)

Sub1id•l 5'Jrf- 5odimen1 (pom1) 0 to lO cm 10

llifckel No Subtldol Surfa<A> s.dlment (SWAC)

lnmtidal Sumco Sediment (SWAC)

Subtid•I SUrfoce Srldlment{pointj 0 \o lDcm l•O

Selenium No Subtidol SUrf0<0 Sediment (SWAC)

lntertklctl Sui face Sediment (SWAq

Subtid~I Surffll«! sedime11l {pofn1) o to to ' '" 1

Varu1dfum No Subtidal Surface Sedimen~ {SWACJ

inlM.ldal Surf.Ice Sediment (SWACI

Subtkfal .SUrfiKM Sedim~nt {pqinl) OtolO cm S7

Zinc No Subtidal Surfac.e Sediment (SWAC)

lntortldol Surf•ce Sedimcnt (SWACI

Subtldal surfaa. Sediment (point! Oto lOc:m 410

Pentachlorophenol No Subtidol Surf•ce Sediment (SWAC) 0to10 cm SB

intenld•I 5'Jrfoc.t1 s.dlment (SWACJ

Subtld•I Sui race Sediment (point) 01.010crn 360

B1o(Z-<>thylhCJryl)·phtholate No Sublld•i Surface Sediment (SWAC)

lnt.rlldal Surface Sediment (SWAC)

Subtld•l S<Jrf..., Sedlm•nl {point) o tl'.'l 1Qcm 47

710

Atenaphthcne No Subti~a l SurliKle Sl!dimenl (SWAq

lnt<rtld•i Surfaco S.dfment (SWACI

SUbtid•I Surfaoe Sediment (point) OtolDcrn 16

240

eenzO{it)·anthfitene No Sublfdal Surf""" Sediment (SWAC)

lntertidol Sur[ace Sedlmenl (SWACI

uo 5'Jblfdal Surface S..dlmont (po!nl) otolo cm

1,700

Benzo(•lpyrene No Sublirl•I Surfa.;e Sediment (SWAC)

lnte,tlda1 Sm race Sedlmenl (SWAq

S<Jbtidal Surf Ke Sediment (point) OtolOcm 99

l,SOO

Benzo(s.h.i)-pery!e-ne No SUbtldol Surface Sediment (SWAC)

lnttrtldal Surf•ee S<ldimem (SWACI

31 SUblldol SUrf•oe Sediment (point) 0 \olO cm

470

h'ot;,I Beruofluoranthene.s No Subudal surface sad1rneM (SWACI

Intertidal Surface Sediment (SWACJ

subUdal surface Sediment (poinl) o to l O cm 1,800

d lr\'Hne No Subtidol 5'Jrface Sediment (SWAC)

lnl·ertldal Surf•.., Sediment (SWACJ

110 5'Jbtidal Surfaoe Sediment (point) OloJOcm

J,700

Diben•(•.h)·•nthraceno No Subtldol Surface Sediment (SWAC)

lntortldal Surface S..dimenl (SWACJ

12 Subtidol SUrfa<e Sediment (point) OtolOcm

180

F-luoranthene No SUbtldal Surfoce Sediment (SWAC)

lnlert:ldal surf.tce Sediment ( SWAC)

160 Subtldol Surfatll S..dlment (point) O tolO cm

2,400

lnqono( 1,2,3-cd)pyrone No Subtld•I Surface Sedfm•nt (SWAC)

Intertidal surface Sedimant (SWAC)

SUbtidal Surface Sediment (point) Otol.Ocm 34

510

Pl",eni1n1hrene No Subtldal Surfac• S..dim•nt ISWAC)

intertfdol S<Jrl•ee s.dlment {SWAC)

100 Subtldal Surface S..dlment (po1ot) o told cm

1,500

Total ~IPAH No SUbllcfaJ Surfac.. Sediment ISWAC)

int•rtlds l Surf- Sediment {SWACI

Subtidol Surface Sedlmenl lpolnt) 0to10 cm %0

14,400

fiotes.

mg/leg dw = milligrams per kilogrom dry weight cPAH1 • <•r<inogonic polycytlk: •rom•lic hydroorbons

CSL= deanup SO'ttfming level

lAFr/SL.:;: lowest apJ»rl!nteffects threshold/screenlns level

N>t 8k&d • natural b•cl<ground

ng TEO/ka dw .:; nanograms- to>1Jdty equtvalents-pcr kilogram dry w~lg:ht

µs TEQ/ka dw = micrograms ·roxlelty Equlvalenh per kilogram dry wtilghl

J.tg/lcg dw • micrograms per kifosrc1m dry weigh PCBs • polychlonnated bipherwl:s

RAO • remed~l •r;tlon ~bfoct..,_

RBTC =risk based th1.,hold concentfatlon

SQ5 = 1edfmen1 quality stondard

SWAt: = spatlallv·welghted averng• coqcentratlon

cm=- centimeters

OC = Oreanlc C•rbon (l.5%)

RAO for Lowes1 Appli<able Source of lowes't Uni!$ Cleanup level Applltllblo de;inup Level"

1•s/ke..cfw Rl\01 N•tllkgd

µg/kg..cfw RAO 1 NatBkcd

lli/kg·OC RA03 SQS

~g/kg-dw

~ TEQ/l<g dw RAO I Nat Bkgd

•'ll Tta/l<g·dw RAOl N•tBkgd

Not •pplk:.lble

mg/kg-dw RAO 1 Nst8kgd

rng/lqi..cfw AAOl Nat Ri:cd

rng/kg·dw RA03 SQS

mg/kg..cf w RAO 1 N•t6kgd

""1g/i<g-dw RAO l N•l 8kgd

Not •PPllC»ble

mg/kgdw RA04 ROTC-fish

mgfkg-dw RA02 RBTC-ctind

Not apptQble

m&/l<,e-clw RAO! R8TC-ch0d

mu/ka-dw RAO! RBTC-chnd

mg/ke·dw AA03 SQSand CSL

mg/kg-dw AAOl RBTC-c.hild

rr•g/kg·dw RAO! RBrC - chlld

mg/~.a-clw RA03 SQS

nc rEQ/kc-dw RAO I N•t Skgd

ng THl/kg-dw AAOl Not 8kgd

Not •PPli<>hl•

Not •pplit>ble

l'!ol opplicable

mgff<e-dw AA03 LA£T/Sl

mg/kg-<lw RAOl Nol 6l<jid

ms/kg-<lw RAOl Nat Bl<gd

Not applicablo

Not •ppfio.ble

Not ;ipplicable

mg/kg-dw AA03 SQS

Not at>1>lk:abl~

Not applltabl•

ma/kg,dw RA03 LAET/Sl

Not applk.abl&

Not applbbl~

mg/kg-dw RA0 3 LAET/Sl

Not •ppllcobl•

Nol af>plicablt!

mg/kg-dw l\A03 LAET/Sl

Not applicable

NOi ipplic;oble

mg/~g-dw M03 LAET/Sl

Not iipplitAhlP

Not oppllcoble

m&/kg-dw RA03 SQS

mg/kg-dw RBTC

Not apptialble

ms/k&-dw RA03 SQS

Not •PPlit•ble

Not applicable

mell<l!-OC µe/kg-dw

Rl\03 SQS

Nol appli~ble

Not appll1;3ble

ms/l<e-OC

µg/kg-dw RAO) SQS

Nol appllC.ble

Not applicable

111t1/lli·OC RA03 SQS

µsJl<g·dw

Not appUcable

Not appll.,.ble

1118Ai!·OC I pg/kg-dw

RA0 3 SQS

Not oppli<Jble

Not appllcoble

ma/~s-OC I 1•s/1<g-dw

RA03 sos

Not appllcobk!

Not applicable

µg/l<g-dw RA03 SQS

Not applicable

Not appllc;;able

mg/kU·OC

µg/kg-dw AA03 sos

Not applie>blo

Not applitllble

JTit/l<g·OC

µg/kg-dw AA03 sos

Not appllable

Not appUcoble

mg/~g-OC

µg/kg.dw RAO 3 sas

No'l apf)lie<1bfe

Not appUcabl~

mg/kg-OC

IJl!/ke-ctw l\AO 3 SQS

Not applrcable

N<>l of>pl.,.blt!

mg/kg·OC

IJ&/kg-dw RA03 SQS

No\ 1pplicable

Not applicable

mg/q·OC RA03 SQS

[Jg/kg.clw

Attachment 4 Remedial Action Levels for Removal of

Contaminated Sediment

LOCKHEED WEST SEATTLE SOW ATTACHMENT 4

Attachment 4 Remedial Action levels to be Achieved at Sediment Surface Following Excavation and Dredging

Comi:>liance coc Risk Driver? Compliance Basis" Zone RAL Units Source

Remedial Action levels for Shoreline Bank and Intertidal Zone (Area 1), Shipway (Area 2), and Navigation Channel (Area 3) Tota l PCBs Yes Subtidal Surface Sediment (point) Oto 10 c:m 12 mg/kg-QC

I SQS

180 µg/kg-dw

cPAHs Yes Subtidal Surface Sediment (point) Not applicable

Arsenic Yes Subtidal Surface Sediment (point) Oto 10 cm S7 mg/kg-dw sos Lead Yes Subtidal Surface Sediment (point) Oto 10cm 530 mg/kg-dw CSL

Tributyltin Yes Subtidal Surface Sediment (point) Not applicable

Copper Yes Subtidal Surface Sediment (point) Oto lOcm 390 mg/kg-dw sos and CSL

Mercury Yes Subtidal Surface Sediment (point) 0lo10 cm 0.41 mg/kg-dw SQS

Dioxins/Furans Yes Subtidal Surface Sediment (point) Not applicable

Chromium No Subtidal Surface Sediment (point) 0to10 cm 260 mg/kg-dw sos Cobalt No Subtidal Surface Sediment (point) Oto lOcm 10 mg/kg-dw LAET/Sl

Nickel No Subtidal Surface Sediment (point) Oto 10 cm 140 mg/kg-dw LAET/SL

Selenium No Subtldal Surface Sediment (point) Oto lOcm 1 mg/kg-dw LAET/SL

Vanadium No Subtidal Surface Sediment (point) Oto lOcm 57 mg/kg-dw LAET/Sl

Zinc No Subtidal Surface Sediment (point) OtolOcm 410 mg/kg-dw sos Pentachlorophenol No Subtidal Surface Sediment (point) OlolOcm 360 mg/kg-dw SQS

Bis(2-ethylhexy1)-phthalate No 47 mg/kg-DC Subtidal Surface Sediment (point) Oto lOcm sos

710 µg/kg-dw

Acenaphthene No 16 mg/kg-OC Subtidal Surface Sediment (point) Oto lOcm SQS

240 µg/kg-dw

Benzo(a)anthracene No 110 mg/kg-OC Subtidal Surface Sediment (point) Oto 10cm sos

1,700 µg/kg-dw

Benzo(a)pyrene No 99 mg/kg-OC Subtidal Surface Sediment (point) 0 to 10 cm SQS

1,500 µg/kg-dw

Benzo(g, h,i)perylene No 31 mg/kg-OC Subtidal Surface Sediment (point) Oto 10 cm SQS

470 µg/kg-dw

Total Benzofluoranthenes No Subtidal Surface Sediment (point) OtolOcm 1,800 µg/kg-dw sos Chrysene No 11.0 mg/kg-OC

Subtidal Surface Sediment (point) Oto lOcm SQS 1,700 µg/kg-dw

Dibenz(a,h)anthracene No 12 mg/kg-DC Subtidal Surface Sediment (point) Oto lOcm SQS

180 µg/kg-dw

Fluoranthene No 160 mg/kg-OC Subtidal Surface Sediment (point) Oto 10cm SQS

2,400 µg/kg-dw

lndeno(l,2,3-cd)pyrene No 34 mg/kg-OC Subtidal Surface Sediment (point) Oto lOcm sos

510 µg/kg-dw

Phenanthrene No 100 mg/kg-OC Subtidal Surface Sediment (point) Oto lOcm sos

1,SOO µg/kg-dw

Total HPAH No 960 mg/kg-QC Sublidal Surface Sediment (point) Oto lOcm SQS

14,400 µg/kg-dw

Remedial Action levels for Dry Docks (Area 4) and localized Subareas (Area 5) Total PCBs Yes Subtidal Surface Sediment (point) OtolOcm 65 mg/kg-OC CSL

960 µg/kg-dw

cPAHs Yes Subtidal Surface Sediment (point) Not applicable

Arsenic Yes Subtldal Surface Sediment (point) Oto lOcm 93 mg/kg-dw CSL

Lead Yes Subtidal Surface Sediment (point) Oto 10tm 530 mg/kg-dw CSL

Tributyltin Yes Subtidal Surface Sediment (point) Not applicable

Copper Yes Subtidal Surface Sediment (point) Oto lOcm 390 mg/kg-dw SQSandCSL

Mercury Yes Subtidal Surface Sediment (point) Oto lOcm 0.59 mg/kg-dw CSL

Dioxins/Furans Yes Subtidal Surface Sediment (point) Not applicable

Chromium No Subtidal Surface Sediment (point) Oto lOcm 270 mg/kg-dw CSL

Cobalt No Subtidal Surface Sediment (point) OtolOcm na mg/kg-dw

Nickel No Subtidal Surface Sediment (point) Oto 10cm na mg/kg-dw

Selenium No Subtidal Surface Sediment (point) Oto lOcm na mg/kg-dw

Vanadium No Subtidal Surface Sediment (point) Oto lOcm na mg/kg-dw

Zinc No Subtidal Surface Sediment (point) OtolOcm 960 mg/kg-dw CSL

Pentachlorophenol No Subtidal Surface Sediment (point) Oto lOcm 690 mg/kg-dw CSL

Bis(2-ethylhexyl)-phthalate No 78 mg/kg-OC Subtidal Surface Sediment (point) 0to10 cm CSL

1,200 µg/kg-dw

Acenaphthene No 57 mg/kg-OC Subtidal Surface Sediment (point) OtoWcm CSL

860 µg/kg-dw

Benzo(a)anthracene No 270 mg/kg-QC Subtidal Surface Sediment (point) Oto lOcm CSL

4,100 µg/kg-dw

Benzo(a)pyrene No 210 mg/kg-OC Subtidal Surface Sediment (point) Oto lOcm CSL

3,200 µg/kg-dw

Benzo(g,h,i)perylene No 78 mg/kg-OC Subtidal Surface Sediment (point] Oto lOcm CSL

1,200 µg/l(g-dw

Total Benzofluoranthenes No 450 mg/kg-QC Subtidal Surface Sediment (point) Oto lOcm CSL

6,800 µg/kg-dw

Chrysene No 460 mg/kg-OC Subtidal Surface Sediment (point) Oto 10cm CSL

6,900 µg/kg-dw

Dibenz(a,h)anthracene No 33 mg/kg-OC Subtidal Surface Sediment (point) 0 tolOcm CSL

500 µg/kg-dw

Fluoranthene No 1200 mg/kg-DC Subtidal Surface Sediment (point) Oto10cm CSL

18,000 µg/kg-dw

lndeno(l,2,3-cd)pyrene No 88 mg/kg-OC Subtidal Surface Sediment (point) OtolOcm CSL

1,300 µg/kg-dw

Phenanthrene No 480 mg/kg-OC Subtidal Surface Sediment (point) Oto lOcm CSL

7,200 µg/kg-dw

Total HPAH No 5300 . mg/kg-OC Subtidal Surface Sediment (point) 0to10 cm CSL

79,500 µg/kg-dw