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Feasibility Addendum Study Review

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Agenda

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    • Introduction - Kathleen, Greg
    • Cleanup Alternatives?- Greg
    • New Feasibility Addendum - Neil
    • Terrestrial Ecological Examination - Bernie
    • Environmental Covenants, Lawsuit Risk - Mike
    • Final Cleanup Action Plan Process - Kathleen
    • NFWF Grant - Bill
    • Proposed Input - Bill
    • Next Steps - Bill

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Meeting Purpose:

What do we want Ecology to do?

How do we get them to do it?

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  1. Introduction

a). What we will review:

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Revised Draft Feasibility Study: An evaluation of ways to clean up the Site and a recommended preferred cleanup alternative.

  • 2017 Draft Feasibility Study
  • New 2024 Draft Feasibility Study Addendum
  • New site specific Terrestrial Ecological Evaluation

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Next step is the Final Cleanup Action Plan

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b). The 2017 Feasibility Study

  • Alternative 1: Excavation and Monitored Natural Attenuation with ECs
  • Alternative 2: Groundwater Containment System Using Groundwater Extraction Wells, and Monitored Natural Attenuation with ECs
  • Alternative 3: Groundwater Containment System Using Groundwater Extraction Trench, and Monitored Natural Attenuation with ECs
  • Alternative 4: Excavation and Limited ECs (remove the pipelines, excavate the remaining 1929 fill, and re-install them)
  • Alternative 5: Excavation and In-Situ Solidification and Monitored Natural Attenuation with ECs
  • Alternative 6: Excavation, Dual-Phase Extraction Treatment and Limited ECs

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Alt 6 chosen as the preferred cleanup method.

NOT A GOOD CHOICE

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c. Unocal Cleanup

For more info:

EMEA website

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d. The SR104 Stormdrain

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2. Cleanup Alternative 7 and 8?

7. Excavation except for stormdrain

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8. Excavation of critical ares only

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No refill of excavated areas

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3. Feasibility Study Addendum

Cleanup Levels (CULs)

“Considering the possible end use of the Site as Open Space, the TEE identified CULs that are ecologically protective.”

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Cleanup Level change example:

Original Gasoline Range Organic CUL: 5,000 mg/kg

Updated Gasoline Range Organic CUL: 200 mg/kg

Increase in proposed engineered cover area is the result of a lowering of the CULs

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Why Alt 6 is a Poor Choice

      • Too much contamination left on site
      • Increases the cost of building a water connection between the Marsh and the Sound
      • Shifts the contamination burden to future landowners and future generations
      • Does not account for the potential future use of the site as estuary habitat
      • Could cause groundwater contamination as hydrocarbons move from the soil to the water

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Selection of the Recommended Alternative

Alt 4 rates highest in all categories except cost

Chevron proposes Alt 6 (engineered covers)

DCA is Disproportionate Cost Analysis, Baseline is Alt 4, Degree of Benefit rated 1 to 4

      • Operate the DPE for 1 year
      • Engineered covers in 22 locations

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Engineered covers in 22 locations

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Operate the DPE for 1 year

Alternative 6

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4. Terrestrial Ecological Examination (TEE)

      • The simplified TEE has been updated to a site specific TEE because the multimodal Ferry Terminal has not moved forward.
      • This new TEE has updated CUL and Protective Soil Values (PSV).
      • The Point of Compliance (POCs) is at a depth of 15 and 4-feet below ground depth in buffers.
      • Ecology has stated the potential future for the lower yard is open space.

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5. Environmental Covenants, Lawsuit Risk

What an environment covenant is.

Example - Harbor Square?

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Risk of pushing Alt 4 vs Alt 6

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Covenant does not prevent excavation, but it needs to be coordinated with Ecology

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6. Final Cleanup Action Plan Process

Feasibility Plan Update:

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Comments accepted:

        • Online at: Ecology’s eComment System1
                  • Or, Email to: Tanner Bushnell, Site Manager, Tanner.Bushnell@ecy.wa.gov

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Open house - Sept. 16, 2024

Edmonds City Hall, Brackett Room, 3rd Floor

Register for the online option:

www.go.ecology.wa.gov/UnocalEdmonds

Feasibility Plan Update followed by Draft Final Cleanup Action Plan

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Final Cleanup Action Plan

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“ Ecology will review the alternatives presented in this Draft Final FS Report and select a final cleanup remedy based upon the minimum requirements and procedures specified in Washington Administrative Code (WAC) 173-340-360,…”

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7. NFWF Grant

NOAA grant for Restoration Planning

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Blue Coast Engineering and Anchor QEA constultants

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Task 2. Contamination Impact Analysis

          • Collect and summarize available information regarding remaining contamination
          • McCulloch Hill to identify risk to future landowners
          • Indentify managment approaches to restoration dealing with remaining contamination

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8. Proposed Input

Short-term input to Ecology

          • Tell Ecology at the public meeting that Alternative 6 is not acceptable
          • Meet with Ecology to discuss adding other options for evaluation

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Long-term input to Ecology

          • Push for selection of another alternative during the public review
          • Include potential future site use in the evaluation (as per WAC)
          • Include future costs in the disproportionate cost analysis
  • Apply the stricter soil screening values to the whole site (not just buffers)
  • Use the standard Point of Compliance of 0-15’ bgs (not 0-4’)
          • What are the contingency plans?
          • Get input from NFWF/NOAA grant attorney
          • Coordinate Ecology input with the City.

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9. Next Steps

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Meet with Ecology to discuss new Alternatives?

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Sept 16 meeting - Draft suggested comments, send to Martians, participate in the meeting.

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Public comment period - Edit comments based on public meeting, send to Martians, submit EMEA and individual comments

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Appendices

More details

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Feasibility Methods Evaluated

  • Environmental Covenant
  • Groundwater Monitored Natural Attenuation .
  • Excavation
  • In-Situ Solidification
  • Enhanced Anaerobic Bio-Oxidation
  • Surfactant Flushing
  • Groundwater Containment System Using Groundwater Extraction Wells
  • Groundwater Containment System Using GroundwaterExtraction Trench
  • Light Nonaqueous Phase Liquid Barrier Trench with Reactive Core Mat
  • Funnel and Gate System with In-Situ Remediation
  • Funnel and Gate System with Groundwater Extraction
  • Soil and Groundwater Treatment using Dual-Phase Extraction

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Expanded Estuary Benefits

    • Puget Sound health
    • Salmon recovery
    • Other fish and wildlife
    • Water quality
    • Fundability
    • Recreation
    • Carbon storage mitigation
    • Contamination risk reduction

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NOAA Grant Application: Tasks

1. Hydrologic and hydraulic modeling to show flood elevations

2. Collect and summarize data on remaining contamination and identify risks

3. Identify a path forward and timeline

4. Public Involvement

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NOAA Grant Application: Timeline

    • Met with Mayor and offered help in February
    • Pre-application filed early April
    • Approved for full application end of May
    • Proposal due June 29th
    • Greg and I wrote application, input from Finance, Parks and Public Works Directors
    • Notification in late November: start January 2024
    • Project completion January, 2025

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Technical Issues

  • Flood risk (Marsh AND waterfront)
  • Site contamination
  • Erosion

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NOAA Grant Application

Budget

  • Total Project Cost: $226,000
  • Local Match: $91,000
    • Staff time in-kind match: $21,500
    • Citizen Cash donation: $35,000
    • Volunteer hours: $22,000
  • Consultant Contract: $170,000