EPA's Comments on the Preliminary (30 Percent) Design for ... · October 31, 2016. The comments are compiled from the project stakeholders and are provided in a tabular format. Lockheed

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10

Mr. Bill Bath Lockheed Martin 2550 North Hollywood Way Suite 406 Burbank, CA 91505-5047

1200 Sixth Avenue, Suite 900 Seattle, WA 98101-3140

January 3, 2017

OFFICE OF ENVIRONMENTAL

CLEANUP

Re: Preliminary (30%) Remedial Design -Lockheed West Seattle Superfund Site, Seattle, Washington (U.S. Region 10, CERCLA Docket No. 10-2015-0079)

Dear Mr. Bath:

Enclosed are the U.S. Environmental Protection Agency's (EPA) comments on the Preliminary (30%) Remedial Design for the Lockheed West Seattle Superfund Site, dated October 31, 2016. The comments are compiled from the project stakeholders and are provided in a tabular format. Lockheed Martin's responses are due in 30 days (February 2, 2017).

If you have any additional questions, please call me at (206) 553-4951 or send me an email at [email protected].

Enclosure

cc: Gary Braun, Tetra Tech Kelly Cole, EPA Marilyn Gauthier, CH2M Hill Jing Liu, Ecology Alison O'Sullivan, Suquamish Tribe Erika Shaffer, DNR Brick Spangler, Port of Seattle Glen St. Amant, Muckleshoot Tribe Denice Taylor, Suquamish Tribe

Sif elyl ~ P~Peterson Remedial Project Manager

Compiled Comments on Preliminary (30 Percent) Design Lockheed West Seattle Superfund Site Remediation Project (October 31, 2016)

Section Page Comment EPA Notes

TOC Add a sub-section 1.4(?) Previous Remedial Action Lesson Learned- LSSOU Yard 1. Add to Section 1

Section 8. If a transloading facility is built nearby T5/LW sediment site, then a Traffic Add to Section 8

Management Plan will be required as well. Capture ail the plans required for a new transloading facility somewhere in the 30% design and a timeline for approving/constructing one.

1 1-1 Second paragraph, second sentence - Delete these sentences. Not necessary to state this in a design document; but if the work continues in the way, that is good.

1 1-1 Second paragraph, last sentence - Insert "and other guidance identified in the SOW" or don't call this out specifically because it is in the SOW as well.

1 1-2 Third paragraph, first sentence - Delete. It doesn't ID methods for this. A Construction QAPP will do this.

1 1-2 Fourth paragraph, fourth sentence - Change "is" to "will be"

1 1-2 Fourth paragraph, last sentence - Include wording to the effect of "as per agreement with the Port of Seattle, date XXXX."

1.3.1 1-4 First paragraph, first sentence - Revise to read as the "Port 'T-5 Pile Removal and Disposal' project. Includes the removal of existing piles from Pier 23 and 24, removal of piles and decking from Pier 25 and 26 and removal of piles form the former shipway area between the Inner and Outer Harbor area."

1.3.1 1-5 First paragraph, first sentence - change "mid-2017" to "mid-2018."

1.31 1-S First paragraph, last sentence - In future design iterations, clearly ID what these are. They may be beyond what the EPA requires. If this is agreed to between LM and the Port and LM agrees to do the work, that is great. But this needs to be made clear.

1.31 1-5 Second paragraph, third sentence - Reconcile depth with Page 3-3, Section 3.1.2 which states -5 to -55 MLLW.

1.31 1-5 Second paragraph, third sentence - Add a sentence about how this might impact the remedial action - that if COCs are located to -57 ft, above the RVALs, then the selected

1



remedy would be applied to this depth. If Lockeed knows that there aren't RVAL exceedences to this depth, then state this.

1.3.3 1-5 First paragraph, first sentence - Clarify that LM is responsible for the whole project as per the UAO. This is who the EPA has the cleanup order with, not the performing contractor.

1.4 1-6 First bullet, second sentence - this sentence seems awkward, revise using the same tense

for each activity.

1 Figure 1-2 Please confirm the locations of the Inner and Outer Harbor Lines shown on this figure -the Inner Line appears to extend over land north of the former shipway.

1 Figure 1-3 Figure 1-2 includes estimated acreages and volumes for the remedy. Identify the updated values on Figure 1-3 or elsewhere so we can see what changed with the new pre-RD data

(July 2016).

1 Figure 1-3 1.ID the location of deeper NAPL thought to be from PSR on this map/legend.

2. Determine if the RNA has to have a buffer, and if so how wide, from the location of the contaminants it is intended to protect.

3. Clarify that the Navigation Channel is also the Outer Harbor Line at this site.

2 2-1 First paragraph, first sentence - insert UAO before Scope of Work (SOW).

2 2-1 Third paragraph, second sentence - Delete "EPA Order" - This was all done under an Ecology Order.

2 2-1 Third paragraph, end of second sentence- Replace "SOW" with "selected remedy."

2 2-1 Third paragraph, end of last sentence - Add that the SOW states "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 aeanup Levels will not be the only criteria for evaluating the performance of the remedy.•

2 2-2 First paragraph, last sentence - Might be better stated as, "If it is determined that surface water exceeding AWQC concentrations is within the site boundaries after the remedial

2

Compiled Comments on Preliminary (30 Percent) Design Lockheed West Seattle Superfund Site Remediation Project {October 31, 2016)


actions are completed, a Tl waiver of the AWQC for other contaminants may also be necessary and will be discussed with the EPA and Ecology.

2.1 2-3 Second bullet under numeric construction performance standards - I recommend switching the order of these bullets (RALs before construction activity limits).

2.2 2-4 Bullets - State the laws in a bold format like they are in Section 2.3

2.2 2-4 Fourth bullet (ESA), fourth sentence - Add "and the US Fish and Wildlife Service" after "(NMFS)."

2.2 2.4 Fourth bullet. "Habitat mitigation" - Be cautious with this term. Mitigation in the cleanup sense is not required on this project. However, the Services may require RPMs (remedial project measures, RPMs) during the cleanup.

2.3 2-4 List of Other ARARS - Do CWA 402 and 40 CFR Parts 122 and 153 also need to be included here? Also include the Marine Mammal Protection Act.

2.4 2-6 Second bullet (Solid Waste Disposal Regs)-last sentence - Add a statement or footnote what the ARARS, state laws or TBCs are if the contractor decides to build its own transloading facility.

2.5.2 2-7 First sentence- Write out "SMP."

2 Table 2-1 Use consistent font in table and make sure table fits within margins of page.

2 Table 2-2 Edit for SQS in several locations, add 230 mg/K-OC for Total Benzofloranthenes. The 2nd half of this table should be consolidated on 1 page and the same "heading/font" should be used.

2 Figure 2-2 Confirm the locations of the Inner and Outer Harbor Lines shown on this figure - the Inner Line appears to extend over land north of the former shipway.

2 Figure 2-3 Confirm the locations of the Inner and Outer Harbor Lines shown on this figure - the Inner Line appears to extend over land north of the former shipway.

3



3.1 3-1 Last paragraph -third bullet, first sub-bullet (Todd Shipyard). Add "currently known as Vigor Shipyard" somewhere in this description.

3.1 3-2 First paragraph, last sentence -Add "and contaminated subsurface soil" after "groundwater."

3.1 3-2 Second paragraph, last sentence (before bullets) Add a footnote that describes the RNA for the PSR site that is on the LW site.

3.1.1 3-2 First paragraph, first sentence, before "by" - Insert "typically" and that this area is undergoing renovations and improvements by the Port until 20XX [insert date].

3.3 3-4 Third paragraph, first sentence - Insert "an" before "evaluation."

3.6 3-6 First paragraph, second and fourth sentences-these two sentences appear to contradict each other. Clarify.

3.7.3 3-9 First paragraph - Cite the references as to who performed the testing, whether it was done by a lab or field test and when. The pre-RD report can be cited, but identify the basics in this design report too.

3 Figure 3-1 Confirm the locations of the Inner and Outer Harbor Lines shown on this figure -the Inner Line appears to extend over land north of the former shipway.

3 Figure 3-2 Need to reorder layers in figure so that outlines of dredge area do not cover labels for sample locations.

Also, confirm the locations of the Inner and Outer Harbor Lines shown on this figure -the Inner Line appears to extend over land north of the former shipway.




4.1 4-1 First bullet - Is the debris primarily over riprap, or will there be exposed soil/sediment matrix under some of the debris? State how Lockheed will ensure that this material isn't

4



contaminated and won't be released into the environment -visual, olfactory, sampling, other. As precaution, a geotextile barrier could be placed in some locations if necessary.

4.1 4-2 Third bullet - Are there any discharges from the FL street outfall?

4.2 4-2 Heading - The assumption in this title is that the utilities are operational and therefore need protection. However, the term "remnants" is also used, which usually denotes something that isn't functional. Clarify.

The Port has identified that all but the Florida Street outfall are not operational and there is no need to protect these outfalls and they can be removed or cut off. Lockheed Martin shall coordinate these activities with the Port.

4.4.1 4-3 First paragraph - Describe how the piles will be removed in the shipway (e.g., west to east to minimize sheetpile wall deflection, other). If piles break, describe what Lockheed will do to dredge this area to the identified dredge depths.

Coordinate with the Port -they note that their pile removal project only requires the removal of piles north of the Inner Harbor Line just to the existing mud line and if the piles break during removal then Lockheed is required to remove the rest of the piles down to the dredge limits. Identify the incentive the Port has to not just break the piles at the mudline.

4.5.1 4-4 Last sentence ("are likely")- ls this determination based on the 2016 sampling or just an assumption THAT leaving the pilings in place doesn't materially affect the remedial action in this location?

4.5.2 4-5 Last sentence - State the conclusion based on the information these tables.

4.6 4-5 Use consistent terminology throughout the report referring to shipyard-related wastes which include both slag and sandblast grit. The terms "amalgamated sandblast grit" and sometimes "sandblast grit" are used in addition to "sandblast grit and slag debris."

5 5-1 ID if any access to the site from the Port's property may be necessary. And, identify any limits on the use of land-based equipment, either from a property-ownership, access or structural/stability basis.

5 5-1 Second paragraph, first sentence - State the elevation.

5



5.1 5-1 First paragraph before bullets - In general, what are the remaining sediment concentrations in the next core interval after the RAL depth is determined.

5.1 5-1 Second bullet, second sentence-Add "and EPA approved" after "permitted."

5.1 5-2 First bullet - Address the potential bath-tubbing effect and how this will be minimized or prevented. Several excavation areas appear to have bathymetric contours that show areas in the dry dock areas potentially resulting in a bathtub like final grade. Discuss.

5.2 5-2 First paragraph, last sentence ("Sediment properties within the dredge areas and the required dredge depths are summarized in Table 5-1.") - Include a discussion of what this means for the means and methods of dredging sediments.

5.2 5-2 Second paragraph, last sentence ("The results indicated that shipway sediment has 59 percent to 62 percent solids, and dry dock sediment 67 percent to 79 percent solids. Refer to Tables 3-1 and 3-3 for detailed data.") - Include a discussion stating what this means for design and Construction Management Plans.

5.3.1 5-3 First paragraph, second sentence. Add a statement about the reasons for discrepancies between the mudline and sample elevations listed in Appendix A (Table A-2) and the elevations shown in Appendix B drawings.

5.3.1 5-3 First paragraph, second sentence (after "prism"). Add a description of the geotechnical properties and how they were "utilized to assist in developing the prism."

5.3.1 5-3 Second paragraph, third sentence - During the November 2017 monthly meeting a 1.SH:l V slope in a few locations was mentioned as being necessary. Clarify.

5.3.2 5-3 First paragraph, third sentence - Suggest adding color or another field to Table A-2 to indicate which borings/sample depths are in or out of dredge prisms.

5.5 5-4 First paragraph, second sentence ("We .... ")- Odd first person wording. Suggest deleting since full evaluation is described in Section 5.7.2 or restate without the "we"- "The stability of the existing sheet pile wall located on the western side of the former shipway after removal of 6 to 13 feet of sediment was analyzed."

6



5.6 5-5 First paragraph, second sentence ("surface protrusions") -What are these? Sediment outcroppings, other? How many?

5.7.1 5-5 First paragraph, third sentence ("therefore .. .'') - Provide a reference that this is true. Seems like native material would be more stable than recently placed backfill material.

5.7.1 5-6 Last paragraph - If the post-<lredged/riprapped slopes are still less than a FoS of 1, even if they meet or exceed the FoS before dredging, these slopes must be stable according to a FoS reqired by seismic codes.

5.7.2 5-6 First paragraph, last sentence -The Port of Seattle is also conducting a stability analysis of the bulkhead regarding its remaining service life and capacity after pile removal up to the existing mudline. Lockheed and the Port shall continue discussing this and identify any

conclusions and changes in the 60% design document.

5.7.2 5-6 Second paragraph, last sentence - Make a statement that either the piles can be removed, have to be removed in a certain way, a certain percentage of the piles can be removed/need to stay in place, etc. State the crux of the information cited in the Sections, tables, and appendices.

S.B 5-7 First paragraph, first partial sentence ("the Contractor work plans ... ")- Add, "EPA approved ... " before "Remedial Action Work Plan."

5.8.2 5-8 First paragraph, first sentence ("dredge units")- Clarify who is determining dredge units on this project. So far, this terminology is not in this design report.

5.8.2 5-8 First paragraph, last sentence (after "progress surveys")- Add, "and oversight by the EPA and Lockheed Martin." Also state that no area will be excavated that cannot fully remove all of the contamination before the area is inundated again, or geotextile fabric will be placed over the dredging area if it isn't verified to be clean yet by post-ainstruction data analysis.

5.8.2 5-9 Last paragraph, first sentence ("400 to 800 cy per day") - Provide the assumptions and calculations that led to these dredge production rates. State the general assumptions; the

7

CompUed Comments on Preliminary (30 Percent) Design Lockheed West Seattle Superfund Site Remediation Project (October 31, 2016)


up time efficiency ratio(s), hours per day of operation, average cy/hour, etc. Without this context, these rates are considered a low production rate.

5.9 5-9 First paragraph - State that a 401 Water Quality Memorandum will be written by the EPA that will regulate this via BMPs and sampling protocols and standards.

5.9.1 5-9 First paragraph, fourth sentence ("Water release from ... ") - State that the objective(s) for the discharge water and the configuration and type/specs of the geotextile cloth and other BMPs on the barge that will filter the water before released to surface water will be identified in the 401 Memo.

5.9.3 5-10 First paragraph, first sentence - Delete "and some degree of" and add "treatment to meet Water Quality Standards .... "

5.9.3 5-10 First paragraph, third sentence - Clarify if this is referring to an existing, permitted transloading facility or if it also may apply to a transloading facility constructed for this project. Regardless, state the objectives of water treatment in the design reports and state that a 401 Water Quality Memo is required and will also identify the treatment process (i.e., filtration only, clarification followed by separation and filtration, etc.) BMPs and standards such a facility needs to meet.

5.10.1 5-11 First paragraph, last sentence. There are a lot more considerations for building a transloading facility that just these Items. Refer to a comprehensive list, guidance, existing permit or other that specifies the requirements the facility has to meet.

5.11 5-12 First paragraph, sixth sentence ("sediment management units") - These were referred to as dredge units earlier. Reconcile and be consistent.

5 Table5-1 Use consistent font in table and make sure table fits within margins of page.


s TableS-3 Use consistent font in table and make sure table fits within margins of page.

8

Compiled Comments on Preliminary (30 Percent) Design Lockheed West Seattle Superfund Site Remediation Project (october 31, 2016)


5 Table 5-4 Identify whether there are any measures to limit deflection or repair upland areas if there is deflection of the sheet pile walls and include relevant specifications regarding to address the situation if movement occurs.

Identify if there are any stability checks necessary for the concrete bulkhead wall or southern sheet pile wall in the Shipway area.

5 Table 5-4 Use consistent font in table and make sure table fits within margins of page and notes are not cut off.

5 Figure 5·1 Confirm the locations of the Inner and Outer Harbor Lines shown on this figure -the Inner Line appears to extend over land north of the former shipway.

6.2.2 6-3 First paragraph, third sentence ("Leveling .... ")- This should be kept to a minimum and

preference is to place it carefully at the outset.

6.2.2 6-3 First paragraph, fourth sentence ("5ubtidal backfill ... ")- Revise this sentence to state, "Subtidal backfill in the former shipway will be placed by low-energy methods controlling the mass rate and velocity of the material delivery so it minimally disturbs the substrate. Clarify that this is the only location subtidal backfill is being placed.

6.3 6-3 First paragraph, first sentence - Insert "layer (RML) ... • after "management"

6.5 6-5 Second paragraph, last sentence -Add, "in the compliance zone." after "clean-up levels"

6 Table 6-1 Use consistent font in table and make sure table fits within margins of page

7.1 7-1/7-2 State that the requirements for sampling and standards will be in the 401 Water Quality Memorandum (delete "certification")

7.1.1 7-2 Change "contaminates" to "contaminants"

7.2 7-3 Second paragraph, first sentence (regarding turbidity curtains) - How long are these and do they really work? Does Lockheed think the curtains will be necessary?

9



7.2 7-3 Third paragraph, after third bullet - Add a bullet stating intertidal dredging will be completed in 1 tidal cycle or covered with geotextile fabric if dredging cannot be completed, or if the sample results are outstanding.

7.3 7-5 First paragraph, last sentence (regarding light emissions) - Based on the location of the residences, is this expected to be an issue?

7.4.1 7-5 Last bullet - Clarify if this is required as each pile is removed or at the end of pile removal in specific areas or across the site.

7.4.1 7-6 First bullet, third sub-bullet - State that these areas have been pre-determined in pre-RO sampling and analysis. Also, state how Lockheed proposes to address areas thought to be stable and then shows signs of being instable once work in the field begins.

7.4.1 7-6 First bullet, eighth sub-bullet, first sentence ("pneumatic underwater") - Clarify that this is a pneumatic underwater bucket or another type of device.

7.4.1 7-6 First bullet, eighth sub-bullet, last sentence ("will be capped")-State "covered." A "cap" is a term ofart and need ICs.

7.4.2 7-7 Heading - There are 2 sets of bullets in this section. ID with underline titles such as "Dredge BMPs" and "In-Water Material Placement BMPs."

7.4.2 7-7 First paragraph, last sentence - Address barge tie offs and that barges may not spud in contaminated sediments. Or confirm that Section 7.4.4, bullet 2 addresses this issue.

7.4.2 7-7 First bullet - define "dredging treatments."

7.4.2 7-7 Second bullet - Indicate there is an allowable turbidity range they need to stay below and/or reference the 401 Memo .

7.4.3 7-9 First paragraph, first sentence - State any potential measures based on tidal cycles (e.g., dredge on outgoing tides).

7.4.5 7-10 Second paragraph, fourth bullet - Add ''West Waterway." Also, if water is mixed in with contaminated sediments it may not be possible to prevent "contaminated water does not enter ... • if material is being moved in a clamshell from the barge to the transloading area.

10



There are aprons that catch any sediments that may spill from a bucket, but I am not sure this contains any and all water. Contaminant levels are measured in the surface water at the zone of compliance (usually 150 and 300 feet)

7.4.5 7-12 First bullet, second sentence - Truck loads require covers in the City of Seattle. Not sure if railcars also need to be covered. If using an existing transloading facility this issue will already be addressed.

7.4.5 7-12 Second paragraph after bullets, fourth sentence ("Wastes from each site ... ") - Indicate that only "like waste" can be co-mingled and site material shouldn't be mixed with TSCA waste, etc.

8 8-1 Heading - Determine and state if access agreements or permission is needed from the Coast Guard to work in the RNA area.

8.3 8-2 First paragraph, second sentence-After "December" - add "for up to 2 work seasons." Include that there will be a communication plan with the Tribes and that the objective is to avoid and minimize the potential disruption to Treaty fishing activities that includes scheduling of construction activities to avoid specific fishing periods and controlling the location and timing of construction activities as well as the advance sharing of vessel arrivals and departures during fishing periods to avoid and minimize the potential net and vessel conflicts. There needs to be an identified communication process in place prior to construction activities occurring and a plan of how impacts that occur will be mitigated.

8.4 8-2 First paragraph, last sentence - Also include coordinating with Vigor Shipyard and the Port or their leasees.

8 Table8-1 Use consistent font in table and make sure table fits within margins of page

9.1.2 9-1 Second paragraph, first sentence (re: 30 to 60 percent)- State 45% instead of 30% as this is the 30% design and it is not likely ready for solicitation of bids.

9.2 9-2 Heading - Note, the RAWP and related documents have to be finalized 1 month before any on-site work begins to ensure that the project isn't rushed and final details aren't being figured out at the last minute before on-site work begins. Some site mobilization may be allowed.

11

-----------------------



9.2.2 9-3 Heading ("Site Restoration and Demobilization") - Clarify what this refers too. Appears that restoring the site (backfill, ENR, ORM layers are in the previous set of bullets and the 1 bullet here only addresses demobilization.

9.3 9-3 First paragraph, first sentence - Clarify if Lockheed believes it will finalize its design, or move from approximately 60% design into the RAWP documents_

10 10-1 Heading - Depending on the path forward for the elevated PAHs in the subsurface near the shipway (and potentially in other areas), the RNA area may need to be expanded if the Coast Guard requires a buffer area is required adjacent to a cap, the project boundary may need to be changed and/or a cap may need to be identified.

11 11-1 First paragraph, second sentence -A draft LTMMP can be developed during design (e.g., 60% design), but I suggest finalizing it after the remedy has been implemented in the event the remedy changes and/or new information is gathered during remedy implementation.

11 11-1 First paragraph, fourth sentence - Delete "fairly."

11 11-1 First paragraph, fourth sentence (re: "Year 5") Sampling is done approximately 1 year before the 5-year review is due so that there is time to gather the samples and analyze them to determine protectiveness of the remedy.

11 11-1 First paragraph, fifth sentence (after "natural background concentrations") - Insert "or risk based threshold concentrations .... "

11 11-1 First paragraph, fifth sentence - Delete "of human consumption of seafood". There are several exposure endpoints cleanup levels are set for in order to be protective.

11 11-1 First paragraph, sixth sentence and remainder of paragraph - This language needs to be re-worked. The "recontamination" language used in the SOW should be used here and the description revised to reflect the sequence of events - remediation meets the cleanup levels and the RAOs, time will bring elevated concentrations of COCs onto the site via sediments/surface water. if determined that the remedy is still intact and sediment concentrations are increasing only on the surface then this will be determined to be from off-site sources and not a failure of the remedy.

12



"from" - replace with "in"

Not all cleanup levels area based on natural background, some are based on RBTCs. The point here is that we know that the cleanup levels will only be met immediately after the remedial action.

13.3.5 13-7 Heading (Climate Change Adaptation Plan) - May be best to refer to this as a Sustainability and Resiliency Plan.

13.3.8 13-8 Indicate that the Draft Biological Assessment will be submitted to NOAA and USFWS as well.

13.4 13-9 Next Steps - Remedial Action - Include in the 30% design a section that identifies any changes made thus far from the selected remedy (e.g., the deeper PSR characteristic PAHs and a potential cap over it (then reference Appendix A). Overall there shouldn't be anything in an Appendix that isn't discussed in the primary design document and the "so what" is identified in the design document as well. All the details and data can then be included in an appendix if necessary.

13.4.1 13.9 First paragraph, first sentence - In future design plans, include the schedule within the document.

Appendix A-2 Elliott Bay is spelled with 2 "t's." A

Appendix A-4 Include the data for Horizontal extent of Contamination in the appendix, not just on a disc. A

Appendix A-4 Add a statement about the level of accuracy for the 3-D kriging model. A

Appendix A-5 4" paragraph. Clarify how Lockheed drew the line between a clean station and one with A elevated COCs (e.g., half way, polygons, other).

Appendix A-5 Section A.5. Clarify if core refusal also indicates dredge refusal. A

Appendix A-6 1" paragraph. State the depth of "upper zone", "deeper" "at depth below intervals ... " etc. A

13

Compiled Comments on Preliminary (30 Percent) Design Lockheed West Seattle Superfund Site Remediation Project {October 31, 2016)


Appendix A-6 Section A.S, first paragraph on page, last sentence - revise to "The vertical extent of the A contamination in the shipway related to the former shipyard activities is limited to the

upper zones, whereas other sources appear to have contributed to the deeper PAH contamination."

Appendix A-6 Section A.6 -this section focuses on PAHs at PSR and elevated PAHs at depth in the A shipway borings. However, the analytical data in Table A-2 also shows elevated mercury at

depth in the borings. Is the elevated mercury also related to PSR releases?

Appendix A-6 It would be helpful to have a table of PSR analytical data used to generate the PAH profile A figures.

Appendix TableA-2 Suggest adding field or colors to the table indicating whether a sample is within or outside A of a dredge prism so drawings in App B can be more readily checked.

Appendix TableA-2 Table A-2 - include a footnote indicating that the elevations are based on field A measurements rather than bathymetry and may differ from elevations depicted on

Appendix B drawings.

Appendix Figure A-1 Need to reorder layers in figure so that outlines of dredge area do not cover labels for A sample locations.

Appendix RgureA- Sample location labels are not legible on the scanned map - please circle, highlight, or A 9 otherwise indicate the locations of PSR samples cited in the appendix.

Appendix Drawings Please fix the -10' elevation designations to eliminate upside-down numbers. B that show

elevation

Appendix Drawings General - Indicate extents of existing sheet pile walls comprehensively in plan drawings (see B "Structural Condition Assessment" report, plan sheet with aerial view and sheet pile section

dimensions).

Appendix Drawings Comments on drawings from Port of Seattle: B

G-02 - Construction Note" #2: revise last word ("structure") to "facility" or other term that encapsulates utilities, fences, etc. as listed in the rest of the note.

14

Compiled Comments on Preliminary (30 Percent) Design Lockheed West Seattle Superfund Site Remediation Project (October 31, 2016}


OWG C-01- Show drawing after Port Pile Removal Project? Or at least show boundary of Port project limits.

OWG C-12 TO C14 - Consider overlaying dredge boundary to help delineate debris removal area

OWG C-13 & C-14 - Indicate general areas where debris removal will be by others (Port) as the existence of that debris may change during the duration of design and construction. Link Note 3 to plan view in some manner

OWG C-19 -Clarify whether piles on "PILE REMOVAL LIMITS" line are removed by Contractor or Port

OWG C-20 - Are volumes in Shipway, Pier 23 & Pier 24 areas affected by removal of piles prior to dredging?

OWG C-22 TO C-39 - Consider highlighting section cuts in key plan with different color or other more visible means

OWG C-4S- Show sheet pile wall height and limits along profile.

OWG C-46- Indicate sheet pile wall location. Indicate proposed side slopes. Label piers to be demolished by the Port on sections 04 and 05

OWG C-46- Note existing and/or Contractor-provided slope stabilization features where slopes are steeper than 2:1.

OWG C-61- Note 4: specify average and min/max thicknesses

OWG C-61- Provide depth of backfill on section E4

OWG C-65- Note 2: provide photos and/or other information defining existing pier to remain

Appendix Overall, for calculation of sheet pile wall capacity, provide values using a minimum B thickness, such as 1 standard deviation below the mean, or similar. This can be used to

better understand the range of conditions.

15

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10

Mr. Bill Bath Lockheed Martin 2550 North Hollywood Way Suite 406 Burbank, CA 91505-5047

1200 Sixth Avenue, Suite 900 Seattle, WA 98101-3140

January 3, 2017

OFFICE OF ENVIRONMENTAL

CLEANUP

Re: Preliminary (30%) Remedial Design -Lockheed West Seattle Superfund Site, Seattle, Washington (U.S. Region 10, CERCLA Docket No. 10-2015-0079)

Dear Mr. Bath:

Enclosed are the U.S. Environmental Protection Agency's (EPA) comments on the Preliminary (30%) Remedial Design for the Lockheed West Seattle Superfund Site, dated October 31, 2016. The comments are compiled from the project stakeholders and are provided in a tabular fonnat. Lockheed Martin's responses are due in 30 days (February 2, 2017).

If you have any additional questions, please call me at (206) 553-4951 or send me an email at [email protected].

Enclosure

cc: Gary Braun, Tetra Tech Kelly Cole, EPA Marilyn Gauthier, CH2M Hill Jing Liu, Ecology Alison O'Sullivan, Suquarnish Tribe Erika Shaffer, DNR Brick Spangler, Port of Seattle Glen St. Amant, Muckleshoot Tribe Denice Taylor, Suquamish Tribe

Sincerely,

Piper L. Peterson Remedial Project Manager

Documents

EPA's Comments on the Preliminary (30 Percent) Design for ... · October 31, 2016. The comments are compiled from the project stakeholders and are provided in a tabular format. Lockheed