REMOVAL ACTION COMPLETION REPORT RESIDENTIAL YARDS CLEANUP. LDW Superfund Site Terminal 117 Early Action Area

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1 REMOVAL ACTION COMPLETION REPORT RESIDENTIAL YARDS CLEANUP LDW Superfund Site Terminal 117 Early Action Area November 4, 2013

2 REMOVAL ACTION COMPLETION REPORT Residential Yards Cleanup Lower Duwamish Waterway Superfund Site Terminal 117 Early Action Area Submitted to U.S. Environmental Protection Agency, Region Sixth Avenue Seattle, WA Submitted by City of Seattle Prepared by 411 1st Avenue S. Suite 550 Seattle, WA November 4, 2013

3 CONTENTS LIST OF APPENDICES... v LIST OF FIGURES... vii LIST OF TABLES... viii LIST OF REPRESENTATIVE PHOTOGRAPHS... ix ACRONYMS AND ABBREVIATIONS... x REPORT CERTIFICATION...xii EXECUTIVE SUMMARY... xiii 1 INTRODUCTION REPORT ORGANIZATION SITE BACKGROUND REMOVAL ACTION OBJECTIVES REMOVAL DESIGN AND WORK PLAN DOCUMENTS PROJECT TEAM ORGANIZATION Agency Personnel Construction Management and Oversight Personnel Removal Action Contractor SUMMARY OF REMOVAL ACTION CONSTRUCTION ACTIVITIES OVERVIEW OF CLEANUP PROCESS Resident Communication, Access Agreements Mobilization Pre-construction Surveying and Utility Locating Clearing and Demolition Site Controls Excavation, Transport, and Disposal of Contaminated Soil Backfill Restoration CHRONOLOGY OF EVENTS S. Cloverdale Street S. Cloverdale Street S. Cloverdale Street S. Cloverdale Street Integral Consulting Inc. iii

4 S. Cloverdale Street S. Donovan Street S. Donovan Street Dallas Avenue S S. Cloverdale Street Planting Strips Southern Alleyway DEVIATIONS FROM ORIGINAL DESIGN CONCURRENT ACTIVITIES PERFORMANCE STANDARDS AND CONSTRUCTION QUALITY CONTROL CQA/CQC PROTOCOLS CQA/CQC Documentation and Reporting Weekly Progress Meetings Inspections, Sampling, and Verification Activities Submittal Management Field Change Documentation Post-Construction Documentation SUMMARY OF CQA/CQC OBSERVATIONS Material Handling, Quantities, and Disposal Health and Safety Stormwater Management Community Outreach and Coordination FINAL INSPECTION AND CERTIFICATIONS WARRANTY LONG-TERM MAINTENANCE AND MONITORING REFERENCES Integral Consulting Inc. iv

5 LIST OF APPENDICES Appendix A. Removal Action Construction Documentation (Provided on CD) Attachment 1. Attachment 2. Attachment 3. Attachment 4. Attachment 5. Attachment 6. Attachment 7. Attachment 8. Attachment 9. Attachment 10. Attachment 11. Attachment 12. Attachment 13. Attachment 14. Attachment 15. Attachment 16. Attachment 17. Attachment 18. Attachment 19. Attachment 20. Attachment 21. Attachment 22. Attachment 23. Attachment 24. Attachment 25. Attachment 26. Attachment 27. Weekly CQA Reports Meeting Minutes Field Memorandums Daily Work Reports Daily CQC Reports NRC Health and Safety Documentation Subcontractor Submittals Material Submittals Requests for Information Photo Documentation Signed Landscape Drawings Post-excavation Surveys Special Waste Profile Off-Site Rule Verification and Approval Soil Disposal Receipts Metal Recycling Receipts Wastewater Analytical Testing and Receipts Concrete Recycling Receipts Mulching Receipts NRC Disposal Log Import Material Analytical Results Compaction Testing Results Import Material Receipts Subgrade Surveys Concrete Testing Results Final Surveys Annotated Drawings Integral Consulting Inc. v

6 Attachment 28. Health and Safety Monitoring Attachment 29. As-Built Drawings Attachment 30. Pre-Final Walkthrough Documentation Appendix B. Statement of Costs Integral Consulting Inc. vi

7 LIST OF FIGURES Figure 1-1. Figure 1-2. Figure 1-3. T-117 Early Action Cleanup Site Overview Soil Excavation Boundaries for Residential Yards Design and Construction Management Team Organization Integral Consulting Inc. vii

8 LIST OF TABLES Table 1-1. Table 1-2. Table 2-1. Table 2-2. Table 2-3. Table 2-4. Table 2-5. Table 3-1. Table 3-2. Table 3-3. Table 3-4. Project Documents Project Team Contact Information Removal Action Chronology Disposal Facilities Material Import Facilities Field Memorandums Pilot Infiltration Test Excavation and Investigation Derived Waste Sample Summary Construction Quality Assurance/Quality Control Monitoring Requests for Information Excavation Depths, Elevations, and Residual Concentrations Lessons Learned Integral Consulting Inc. viii

9 LIST OF REPRESENTATIVE PHOTOGRAPHS Photo 2-1. Photo 2-2. Photo 2-3. Photo 2-4. Photo 2-5. Photo 2-6. Photo 2-7. Photo 2-8. Photo 2-9. Photo Photo Photo Photo Photo Photo Photo Photo Photo Photo Photo Photo Photo Photo Clearing at 1410 S. Cloverdale Street Site Controls at 1410 S. Cloverdale Street Excavation at 1440 S. Cloverdale Street Vactor Excavation at 1445 S. Cloverdale Street Utility Protection at 1425 S. Cloverdale Street Survey Confirmation at 1418 S. Donovan Street Backfill at S. Cloverdale Street Planting Strips Compaction at Southern Alleyway Placed Concrete at 1440 S. Cloverdale Street New Fence at 1445 S. Cloverdale Street, Backyard Sod Installation at 1425 S. Cloverdale Street Planting Beds at 1430 S. Donovan Street 1410 S. Cloverdale Street, Before and After 1421 S. Cloverdale Street, Before and After 1425 S. Cloverdale Street, Before and After 1440 S. Cloverdale Street, Before and After 1445 S. Cloverdale Street, Front Yard, Before and After 1445 S. Cloverdale Street, Back Yard, Before and After 1418 S. Donovan Street, Before and After 1430 S. Donovan Street, Before and After 8523 Dallas Avenue S., Before and After S. Cloverdale Street Planting Strips, Before and After Southern Alleyway, Before and After Integral Consulting Inc. ix

10 ACRONYMS AND ABBREVIATIONS BMP CERCLA City CQA CQAP CQC CRZ DHA dioxin DU EAA EE/CA EPA furan HASP IDW Integral J.A. Brennan LDW MarVac NRC NTCRA OSR Otto Rosenau PCB PIT Port best management practice Comprehensive Environmental Response, Compensation, and Liability Act City of Seattle construction quality assurance construction quality assurance plan construction quality control contamination reduction zone Duane Hartman & Associates, Inc. polychlorinated dibenzo-p-dioxin decision unit early action area engineering evaluation and cost analysis U.S. Environmental Protection Agency polychlorinated dibenzofuran health and safety plan investigation derived waste Integral Consulting Inc. J.A. Brennan Associates, PLLC Lower Duwamish Waterway Marine Vacuum Services, Inc. National Response Corporation non-time critical removal action off-site rule Otto Rosenau and Associates, Inc. polychlorinated biphenyl pilot infiltration testing Port of Seattle Integral Consulting Inc. x

11 PPE QAPP RACR RADR RAWP RFI RvAL personal protective equipment quality assurance project plan removal action completion report removal action design report removal action work plan request for information removal action level Settlement Agreement Administrative Settlement Agreement and Order on Consent Number CERCLA SOW SPU statement of work Seattle Public Utilities T-117 Terminal 117 Teufel USACE Teufel Landscaping U.S. Army Corp of Engineers Integral Consulting Inc. xi

12 REPORT CERTIFICATION The following certifications are provided pursuant to the Administrative Settlement Agreement and Order on Consent for Removal Action, Appendix A, Statement of Work, task c.e.i Removal Action Construction Report and task C.e.ii - Removal Action Completion Report. This report pertains only to the Residential Yards portion of the Terminal 117 Early Action Area. Removal action completion reports for the remaining portions of the Early Action Area will be submitted under separate cover. PROJECT COORDINATOR I, Mary Mitchener, Project Coordinator on behalf of the City of Seattle, hereby certify that the removal action for the Residential Yards cleanup has been completed in full satisfaction of the requirements of the Settlement Agreement. 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. ~ Mart2t:~ Project Coordinator City of Seattle Date RESIDENT ENGINEER I, Eric Pilcher, Resident Engineer on behalf of the City of Seattle, hereby certify that the removal action for the Residential Yards cleanup has been completed in full satisfaction of the requirements of the Settlement Agreement. 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. ;j (. \)\ \\ '\'~II 'C'/ 2. ~. \ " })// Eric L. Pilcher P.E. ~ :::J..-.,. -. /-1c-, ~...' ':'. ',; ~ Resident Engineer t:- I~. ~ Integral Consulting Inc. II/Ot)/ZOI? Date Integral Consulting Inc. xii

13 EXECUTIVE SUMMARY The City of Seattle (City) has completed a non-time critical removal action (NTCRA) to address contaminated soil within the Residential Yards portion of the Terminal 117 (T-117) Early Action Area (EAA) within the Lower Duwamish Waterway (LDW) Superfund site. The T-117 EAA is a 15.2-acre site located in Seattle s South Park neighborhood on the west bank of the LDW about 3.5 river miles south of Harbor Island (Figure 1-1). The City and the Port of Seattle are responsible for conducting the T-117 NTCRA under U.S. Environmental Protection Agency (EPA) oversight. The Residential Yards portion of the cleanup included eight residential properties, planting strips along S. Cloverdale Street, and the alleyway between S. Cloverdale Street and S. Donovan Street (Figure 1-2). Integral Consulting Inc. (Integral), of Seattle, Washington, prepared the removal action design in coordination with the City. National Response Corporation (NRC), of Portland, Oregon, performed the removal action construction. The City managed the construction contract, and Integral provided construction quality assurance. NRC initiated construction on December 3, 2012, and completed construction on March 22, EPA, with support from U.S. Army Corp of Engineers, performed oversight throughout all phases of construction. The primary construction elements of the removal action included stripping and removal of residential sod, vegetation and structures within the removal area footprint, excavation and offsite disposal of residential yard and alleyway soil and debris, placement of clean backfill and topsoil materials, and restoration and landscaping of all disturbed areas. The design excavation boundaries and depths were established based on rationale provided in the quality assurance project plan in Appendix F of the removal action design report (Integral 2012). The removal action achieved excavation within those boundaries and depths for all of the designated yards, planting strips, and the southern alleyway. Integral Consulting Inc. xiii

14 1 INTRODUCTION This removal action completion report (RACR) documents the implementation phase of the Residential Yards portion of the Terminal 117 (T-117) Early Action Area (EAA) within the Lower Duwamish Waterway (LDW) Superfund site in Seattle and Tukwila, Washington (Figure 1-1). The T-117 removal action is being performed in accordance with the Administrative Settlement Agreement and Order on Consent; Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) No (Settlement Agreement, including Statement of Work [SOW]; USEPA 2011b) as a non-time critical removal action (NTCRA). In September 2010, the U.S. Environmental Protection Agency (EPA) approved an engineering evaluation and cost analysis (EE/CA; Windward et al. 2010) prepared by the Port of Seattle (Port) and City of Seattle (City). As indicated in Figure 1-1, the approved removal action described in the EE/CA and associated Action Memorandum (USEPA 2010) includes the removal and disposal of contaminated soil and sediment from the LDW estuary (Sediment Area), the T-117 upland site (Upland Area, formerly an industrial facility), and portions of the Adjacent Streets and Residential Yards (Streets and Yards), as defined below. It also includes required drainage improvements to capture and treat stormwater runoff from the Adjacent Streets. The cleanup is being conducted in two coordinated phases: the Sediment and Upland cleanup (Phase 1), performed by the Port, and the Adjacent Streets and Residential Yards cleanup (Phase 2), performed by the City. In addition, Phase 2 is being conducted in two stages as follows: The Residential Yards cleanup, consisting of eight residential yards, the planting strips on S. Cloverdale Street, and the alleyway between S. Cloverdale Street and S. Donovan Street The Adjacent Streets cleanup, consisting of portions of the rights-of-way of 16th Avenue S., 17th Avenue S., Dallas Avenue S., and S. Donovan Street; and construction of new stormwater infrastructure. The City completed the Residential Yards cleanup in March This RACR documents that the Residential Yards cleanup was performed in accordance with the construction contract and supporting documents, including the EPA-approved removal action design report (RADR) (Integral 2012) and removal action work plan (RAWP) (Integral and NRC 2012). Integral Consulting Inc. 1-1

15 1.1 REPORT ORGANIZATION The RACR is intended to satisfy reporting requirements set forth in the SOW and has been prepared in general accordance with EPA guidance on closeout procedures for national priorities use sites (USEPA 2011a). The RACR is organized as follows: Section 1. Introduction Introduction and overview of RACR organization, project background and site information, and project team organization. Section 2. Summary of Removal Action Construction Activities Summary of the construction methods and sequencing of the work. Section 3. Performance Standards and Construction Quality Control A description of the construction quality assurance (CQA) and construction quality control (CQC) protocols followed during construction. Section 4. Operation and Maintenance Activities A brief statement regarding operation and maintenance with respect to closure of the Residential Yards portion of the T-117 EAA NTCRA. Section 5. References. Appendices. Construction documentation is provided on CD as an appendix to this RACR. The information includes CQA/CQC documentation, waste profiles and disposal receipts, import material analytical results and import tickets, construction monitoring and testing results, contractor submittals, requests for information, field memorandums, confirmation surveys, record drawings, and inspection documentation. 1.2 SITE BACKGROUND T-117 was identified for early action within the LDW Superfund site in 2003 to address potential sources of polychlorinated biphenyl (PCB) contamination to LDW sediments. The T-117 Residential Yards Cleanup area is located adjacent to the Upland and Sediment portion of the site and includes eight residential properties, planting strips along S. Cloverdale Street, and the alleyway between S. Cloverdale Street and S. Donovan Street (Figure 1-2). Numerous investigations have been conducted within the Streets and Yards study areas from 2004 to present to characterize the nature and extent of contamination and confirm the removal action boundaries. These investigations focused on the designated chemicals of concern for the Streets and Yards: PCBs, and polychlorinated dibenzo-p-dioxins (dioxins) and polychlorinated dibenzofurans (furans) where co-located with PCBs that exceed the action level. In 2004 and 2005, the City completed a series of interim actions in portions of the Streets and Yards study Integral Consulting Inc. 1-2

16 areas. Descriptions of these past investigations and interim actions are summarized in the T-117 EAA EE/CA prepared jointly by the City and Port (Windward et al. 2010). In September 2010, EPA issued an Action Memorandum indicating its selected cleanup alternative for T-117 (USEPA 2010). In 2012, pursuant to the Action Memorandum (USEPA 2010) and Settlement Agreement (USEPA 2011b), the City conducted an extensive sampling program to support the removal action design and to confirm the areal and vertical extent of removal for the Streets and Yards study area. The results of this investigation were presented in Appendix G of the RADR (Integral 2012). 1.3 REMOVAL ACTION OBJECTIVES The primary objective of the Residential Yards cleanup was to reduce risks to human health and the environment. For upland and residential soil, the specific removal action objective was to reduce PCB concentrations to ensure protection of sediments (USEPA 2010). Total PCB concentrations determined the extent of the excavation prisms in the Residential Yards study area. As outlined in the engineering evaluation and cost analysis (EE/CA; Windward et al. 2010), cleanup in the Residential Yards study area was guided by the following decision rules: Total PCB concentrations were the driver for this Residential Yards cleanup. Cleanup occurred where total PCB concentrations exceeded the removal action level (RvAL) of 1 mg/kg. For yard decision units characterized by multi-increment sampling, a remediation level of 0.5 mg/kg total PCBs was used to define portions of the yards to be removed. The 0.5 mg/kg total PCB remediation level was developed from an evaluation of variability in triplicate multi-increment samples collected from decision units as discussed in Appendix L of the EE/CA (Windward et al. 2010). Alleyway sampling followed procedures similar to those used to establish decision units but with a lower ratio in composite sample collection. EPA determined that the variability analysis completed in the EE/CA for yard decision units applies to the alleyway areas and that the remediation level for total PCBs is 0.5 mg/kg. Planting strips are of limited area and were characterized by point samples. Removal within the planting strips was completed such that all point samples in a given planting strip area, at a given depth, are less than the RvAL for total PCBs of 1 mg/kg. Wherever PCB cleanup occurred, co-located dioxins/furans were also removed. Further, in a letter dated September 5, 2012, EPA directed the City to remove soil from one residential yard (1430 S. Donovan Street) that contained dioxin/furan concentrations exceeding 50 ng/kg toxicity equivalency. Integral Consulting Inc. 1-3

17 1.4 REMOVAL DESIGN AND WORK PLAN DOCUMENTS A summary listing of project design and construction documents prepared in support of the Residential Yards cleanup is provided in Table 1-1. The Residential Yards RADR was submitted to EPA on October 26, EPA granted conditional approval on November 20, 2012, pending resolution of comments. The RADR was finalized and issued to EPA on December 3, The RADR includes the following elements: Construction drawings and technical specifications The construction quality assurance plan (CQAP) The site construction quality assurance health and safety plan (CQA HASP) The community health and safety plan (community HASP) Access agreements The quality assurance project plan (QAPP) The pre-excavation confirmation sampling data report. A design memorandum adding 1430 S. Donovan Street to the Residential Yards cleanup was submitted on January 8, 2013, as an appendix to the RADR. Following contractor selection, a draft RAWP was submitted to EPA on October 15, EPA granted conditional approval on November 20, 2012, allowing work to commence. The final RAWP was issued on December 3, The RAWP included the following plans from the removal action contractor, National Response Corporation (NRC), describing how the work would be performed: Project work plan Construction checklist Project schedule Construction health and safety plan Green/sustainable remediation plan Surveying plan Utility protection plan Pollution control and mitigation plan Transportation and disposal plan Traffic control plan Integral Consulting Inc. 1-4

18 Clearing, demolition, and excavation plan Contractor quality control plan Site restoration plan. 1.5 PROJECT TEAM ORGANIZATION The roles, responsibilities, and lines of communication for key members of the project team are illustrated in the organizational chart presented in Figure 1-3 and briefly outlined below. Contact information for the project team members is provided in Table Agency Personnel EPA was the regulatory authority and responsible agency for authorizing and overseeing the Residential Yards cleanup. In this capacity, EPA reviewed and maintained approval authority over the QAPP and RADR (Integral 2012), RAWP (Integral and NRC 2012), and related City and contractor CQA/CQC programs. On behalf of EPA, the U.S. Army Corps of Engineers (USACE), USACE provided agency construction oversight during the Residential Yards cleanup. USACE was responsible for ensuring that the construction activities complied with the Settlement Agreement (USEPA 2011b), the construction drawings and technical specifications in Appendix A of the RADR (Integral 2012), and the RAWP (Integral and NRC 2012) Construction Management and Oversight Personnel The City was responsible for the overall planning, implementation, and management of the Residential Yards cleanup. As the lead design consultant to the City, Integral Consulting Inc. (Integral) was responsible for developing the Residential Yards RADR (Integral 2012), including construction drawings, technical specifications, and related plans, and for implementing the CQAP included in Appendix B of the RADR. During construction, the City team prepared weekly quality assurance reports (Appendix A, Attachment 1) and meeting minutes (Attachment 2), and issued field memorandums (Attachment 3) as necessary to describe deviations to the approved design Removal Action Contractor NRC performed the construction activities associated with the Residential Yards cleanup. NRC implemented site controls to restrict unauthorized access, manage traffic, and minimize environmental impacts. NRC also established and followed health and safety protocols during construction. NRC utilized numerous subcontractors to support the project, as listed in Table 1-2. During construction, NRC prepared daily work reports (Attachment 4), quality Integral Consulting Inc. 1-5

19 control reports (Attachment 5), and health and safety documentation (Attachment 6). NRC also issued submittals for subcontractors (Attachment 7) and materials (Attachment 8), and requests for information (Attachment 9) as necessary to clarify the design intent. Integral Consulting Inc. 1-6

20 2 SUMMARY OF REMOVAL ACTION CONSTRUCTION ACTIVITIES The Residential Yards cleanup was conducted in accordance with the EPA-approved construction drawings and technical specifications presented in Appendix A of the RADR (Integral 2012) and the work plans presented in the RAWP (Integral and NRC 2012). The City issued a purchase order to NRC for the cleanup construction on October 11, EPA provided approval to proceed on November 20, The following sections describe specific construction activities that were performed during the Residential Yards cleanup, including an overview of the construction process, summaries of activities performed at individual properties, deviations to the approved design, and other related site activities. A chronological summary of the cleanup is presented in Table 2-1. Representative photographs are provided for various construction activities. A comprehensive photo log is provided in Attachment OVERVIEW OF CLEANUP PROCESS The primary removal activities included removal of hardscape features such as private sidewalks, patios, and sheds; clearing of existing vegetation for offsite transport and disposal; excavation of contaminated soils to pre-determined depths for offsite transport and disposal; backfilling with clean import materials to original grades; planting replacement vegetation; and replacement of hardscape features such as sidewalks, driveways, and fences. The alleyway was reconstructed with a compacted gravel surface. Cleanup of each individual property followed the general progression described in this section. Specific information for each property, including dates, equipment, techniques used, and special situations encountered are presented in Section Resident Communication, Access Agreements Communication with property owners and residents began several months prior to construction. The City team met with each of the property owners on multiple occasions to obtain access agreements, discuss the details of landscape restoration for the designated properties, obtain acknowledgement and concurrence of the restoration design and landscape maintenance requirements, coordinate on construction scheduling and access/parking logistics, and to brief homeowners and residents on construction-related health and safety issues. Property owner acknowledgements are provided in Attachment 11. Integral Consulting Inc. 2-1

21 2.1.2 Mobilization NRC established a staging area at the intersection of Dallas Avenue S. and S. Donovan Street on November 26, Equipment mobilized to the site included a field office trailer, a 5 kw generator, an equipment trailer, two large metal storage containers, and a 20,000-gallon water tank. NRC implemented stormwater best management practices (BMPs) in accordance with the RAWP (Integral and NRC 2012), which included placement of catch basins inserts in and around the staging area and work areas, and storage of wattles and sandbags. This staging area was used throughout the duration of the Residential Yards cleanup Pre-construction Surveying and Utility Locating Seattle Public Utilities (SPU) provided pre-construction surveying and mapping to support the removal action design and serve as the basis for quantity measurements for each of the designated properties. The pre-construction survey was completed on May 17, 2012, and included all designated properties with the exception of 1430 S. Donovan Street, which was completed by Duane Hartman & Associates, Inc. (DHA) on December 7, NRC contacted the Utility Notification Center to mark existing utilities prior to excavation and recorded the actual locations in the as-built record drawings Clearing and Demolition With the exception of noxious weeds (e.g., Himalayan blackberry), above-grade vegetation was cleared and transported to Pacific Topsoils for mulching and composting. Cleared, noxious weeds were transported to the City s south transfer station for disposal. Grubbed vegetation was comingled with excavated soil and transported to a Subtitle D landfill. Hardscape items such as concrete walkways, sheds, pavers, and/or wooden decks were removed prior to or in conjunction with the removal of contaminated soils and either recycled, retained for reuse, or comingled with excavated soil and transported to a Subtitle D landfill. Representative clearing operations are documented in Photo Site Controls NRC established exclusion zones, contamination reduction zones (CRZs), and safe zones as described in the RAWP (Integral and NRC 2012) prior to excavation activities at each property. The exclusion zones were accessible only through CRZs, where appropriate personal protective equipment (PPE) was required. The CRZ included personnel decontamination stations and waste disposal facilities. Integral Consulting Inc. 2-2

22 The CRZ/exclusion zone was monitored by a qualified NRC team member who was responsible for the maintenance of PPE and emergency equipment. NRC provided safe passage for residents to and from their houses via a separate clean path, over which no contaminated soil was transported or tracked, and which was demarcated by orange fencing. The loading zone was located within the exclusion zone and was lined with plastic sheeting. Public access to all construction zones was controlled by temporary fencing, stanchions, and NRC personnel. Representative site controls are documented in Photo Excavation, Transport, and Disposal of Contaminated Soil NRC used excavators, skid steer loaders, Vactor trucks, and hand tools to excavate the yards and other areas. Yard excavation commonly proceeded in two phases using the front entryway sidewalk as a dividing line between left and right sides of the yard. Roll-off bins were placed on the street in front of the house. Excavation activities began at the point furthest from the roll-off bin to avoid recontamination of clean, excavated areas. Once the excavator reached the target elevation, the operator used a smooth-edged excavator bucket to perform a final scrape of the area, removing any uneven or sloughed soils. Hand digging or Vactor excavation was performed within the drip lines of mature trees and shrubs to remain, and within 2 feet of foundations and utilities. NRC excavated around structural elements such as utilities, sidewalks, pier blocks, and concrete foundations in accordance with the guidance outlined in Field Memo 1 (Attachment 3). To the extent practicable, excavations immediately adjacent to structures extended to 6 inches below ground surface. Deeper excavations were adjusted, as needed, to prevent undercutting of structure foundations. The final excavation grades and slopes are documented in the post-excavation surveys (Attachment 12). Representative excavation documentation is presented in Photos 2-3, 2-4, and 2-5. Cross-contamination was controlled by protecting access ways with boards or metal plates and plastic sheeting. Similarly, NRC installed temporary plastic sheeting within excavated areas and on unexcavated slopes at the end of each shift, to protect excavated areas from becoming recontaminated. Pooled stormwater collected within excavations was removed with a vacuum truck before excavation resumed and disposed of with other site water at Marine Vacuum Services, Inc. (MarVac). All excavated soil and demolition debris intended for offsite disposal was placed directly into a dump truck or roll-off bin and transported under a special waste profile (Attachment 13) to Allied Waste s transfer facility at 3rd Avenue S. and S. Lander Street. From there, the contaminated soil and debris was transferred to railcars for disposal at Roosevelt Regional Landfill s Subtitle D facility. Disposal facility contractors were verified and approved by EPA in accordance with its off-site rule (OSR, see Attachment 14). A summary of material quantities Integral Consulting Inc. 2-3

23 and disposal locations is included in Table 2-2. Disposal receipts are provided in Attachments 15 through 19. NRC s disposal log is proved in Attachment Confirmation Survey NRC used site levels and measuring sticks to gauge excavation depth during soil removal. Upon completion of the excavation, DHA performed survey confirmation using a digital optical station and prism pole calibrated to the City s coordinate system using a real time kinematic global positioning system. The accuracy of DHA s equipment was verified using the City s magnetic survey nails at various points within the neighborhood. DHA conducted survey measurements at the top and toes of corners, walls, slopes, points on the excavation floor, and at utility locations. The City s resident engineer and USACE s construction oversight manager provided verbal acceptance of excavated elevations based on the real-time confirmation survey performed by DHA. The final post-excavation survey maps and data are provided in Attachment 12. Representative survey confirmation is documented in Photo Backfill Following visual confirmation by the City and USACE, the excavations were backfilled with clean import material in accordance with the construction drawings and technical specifications (RADR, Appendix A; Integral 2012). Import material sources were evaluated for acceptability based on specified physical and chemical properties. Prior to construction, Integral submitted representative samples of each import material, with the exception of crushed rock that contained no fine-grained material, to Analytical Resources, Inc., for analytical chemical testing. The analytical results were compared to project acceptance criteria established in the technical specifications and, in some cases where certain parameters exceeded the specified acceptance criteria, compared to Washington State Model Toxics Control Act screening criteria (Ecology 2012) and EPA residential soil regional screening levels (USEPA 2012). Import material analytical test results were approved by EPA prior to use. Import material source information and quantities are summarized in Table 2-3 and import material analytical results are presented in Attachment 21. Where practical, the backfill was placed in 1-foot lifts via a conveyor aggregate delivery truck or otherwise placed using a skid steer loader. NRC compacted the placed material in accordance with the technical specifications. Compaction reports are included in Attachment 22 of this RACR. Representative backfill placement and compaction is documented in Photos 2-7 and 2-8. Import material receipts are provided in Attachment 23. Survey maps and data following placement of subgrade are provided in Attachment 24. Integral Consulting Inc. 2-4

24 2.1.8 Restoration Restoration of the properties included placement of sod in lawn areas, planting of trees, shrubs and other plants in designated locations, and the construction of fences, sidewalks, and other hardscape features in accordance with the construction drawings and technical specifications (RADR, Appendix A; Integral 2012). Concrete. G.A. Jorgensen Company, Inc., formed and poured replacement concrete sidewalks. Test cylinders were taken during the pours and submitted to Otto Rosenau and Associates, Inc. (Otto Rosenau), for compressive testing. Test cylinders were tested for compressive strength at 7 and 28 days, and in all cases were found to exceed the compression strength testing criteria of 3,000 pounds per square inch. Concrete testing results are provided in Attachment 25. An example of placed concrete is documented in Photo 2-9. Fencing. All City Fence provided new replacement fences at designated residential properties. An example of replacement fencing is documented in Photo Sod. Teufel Landscaping (Teufel) placed sod on the scarified turf area soil and hand cut the sod as needed to fit surface features such as sidewalk curves and tree trunks. The sod contains a seed mix suitable for growth within the Seattle area. Representative sod installation is documented in Photo Plants and Mulch. Prior to delivery the specified landscape materials were inspected by the City team s landscape architect, J.A. Brennan Associates, PLLC (J.A. Brennan). Approved plants were delivered to the site and installed by Teufel. J.A. Brennan reviewed the final placement of plant materials and made recommended adjustments, as necessary. All planting beds were covered with medium bark mulch. Example finished planting beds are documented in Photo Survey maps and data following completion of restoration are provided in Attachment CHRONOLOGY OF EVENTS This section presents the general chronology and certain site-specific details of the removal activities performed at each of the designated properties. The chronology is also summarized in Table S. Cloverdale Street NRC performed the cleanup and restoration at 1410 S. Cloverdale Street from December 4, 2012, to February 21, 2013 (except certain days during the holiday period). During excavation several unmarked utility lines were uncovered, which required that the soil removal in these areas be accomplished using Vactor truck or excavating by hand. Approximately 300 tons of soil was Integral Consulting Inc. 2-5

25 excavated from this property and 337 tons of clean material was imported and placed. Before and after site conditions are documented in Photo S. Cloverdale Street NRC performed the cleanup and restoration at 1421 S. Cloverdale Street from January 30 to March 20, Excavated soil from this property was comingled with excavated soil from the alleyway and not tracked separately (see Section for alleyway excavation volume). Approximately 15 tons of clean material was imported. Before and after site conditions are documented in Photo S. Cloverdale Street NRC performed the cleanup and restoration at 1425 S. Cloverdale Street from January 15 to February 28, A natural gas utility line was identified in the front yard and protected during excavation by preserving the soil base underneath the pipe (in accordance with Field Memo 1, Attachment 3). At the request of the property owner, NRC coordinated with the property owner s independent contractor who installed a backflow preventer on the existing sanitary sewer lateral once the target removal elevation had been reached in the front side yard. Approximately 225 tons of soil was excavated from the front and side yard of this property. Soil excavated from the back yard was comingled with soil from the alleyway and not tracked separately. Approximately 332 tons of clean material was imported. Before and after site conditions are documented in Photo S. Cloverdale Street NRC performed the cleanup and restoration at 1440 S. Cloverdale Street from December 10, 2012, to February 28, 2013, with a break during the holidays. NRC unearthed a drain pipe for a downspout coming from the east side of the house. The City team contacted the property owner, who expressed interest in performing maintenance on the drainage system. At the request of the property owner, NRC excavated a 3- by 3- by 4-foot deep pit below excavation grade to serve as a dry well for a new downspout connection. The property owner hired an independent subcontractor to fill the pit with drain rock, and install a pipe connection to the downspout. In addition, NRC coordinated with the property owner s independent contractor to install a backflow preventer on the existing sanitary sewer lateral following excavation activities in the front yard. Approximately 261 tons of soil was excavated from this property, and 314 tons of clean material was imported. Before and after site conditions are documented in Photo Integral Consulting Inc. 2-6

26 S. Cloverdale Street NRC performed the cleanup and restoration at 1445 S. Cloverdale Street from January 14 to March 14, Approximately 27 tons of soil was excavated from the front yard at this property. Soil excavated from the back yard was comingled with soil from the alleyway and not tracked separately. Approximately 55 tons of clean material was imported. Before and after site conditions are documented in Photos 2-17 and S. Donovan Street NRC performed the cleanup and restoration at 1418 S. Donovan Street from February 11 through 22, Approximately 81 tons of soil was excavated from this property, and 104 tons of clean material was imported. Before and after site conditions are documented in Photo S. Donovan Street NRC performed the cleanup and restoration at 1430 S. Donovan Street from February 14 to March 14, Approximately 61 tons of soil was excavated from this property, and 49 tons of clean material was imported. Before and after site conditions are documented in Photo Dallas Avenue S. NRC performed the cleanup and restoration at 8523 Dallas Avenue S. from February 19 to March 5, Approximately 151 tons of soil was excavated from this property, and 222 tons of clean material was imported. Before and after site conditions are documented in Photo S. Cloverdale Street Planting Strips NRC performed the cleanup and restoration of the northern planting strip from January 23 to March 19, 2013, and performed the cleanup and restoration of the southern planting strip from February 25 to March 8, Approximately 127 tons of soil was excavated from the northern planting strip, and 121 tons of clean material was imported. Approximately 122 tons of soil was excavated from the southern planting strip. A total of 154 tons of clean material was imported for backfill; most was placed in the planting strip. Excess import was placed as backfill within the pilot infiltration test (PIT) excavations, described in Section 2.4. Before and after site conditions are documented in Photo Southern Alleyway NRC performed the cleanup and restoration of the southern alleyway from January 31 to February 12, Approximately 913 tons of soil was excavated from the alleyway and Integral Consulting Inc. 2-7

27 adjoining backyards and 1,074 tons of clean material was imported. Before and after site conditions are documented in Photo DEVIATIONS FROM ORIGINAL DESIGN The following deviations were made from the originally approved plans during the course of the Residential Yards cleanup. Each of these deviations is documented in the referenced field memos (Attachment 3), which were approved by EPA prior to implementing the work. A summary of the field memos issued by the City is presented in Table 2-4. Excavation limits adjacent to foundations and other structures were clarified to limit the extents in certain locations to avoid potential stability impacts (Field Memo 1). The City refined the excavation prisms at 1440 S. Cloverdale Street, 1445 S. Cloverdale Street, the Southern Alleyway, 1418 S. Donovan Street, and 8523 Dallas Avenue S. to improve removal efficiency (Field Memos 2, 4, 8, 9, and 10). The homeowner at 1410 S. Cloverdale Street requested that grass be installed where the brick paver patio and planting beds had previously been located, and that the location of the eastern concrete walkway be moved closer to the house. Plantings that were slated for installation around the patio were moved to the planting bed between the sidewalk and the house. The landscape restoration drawing was revised accordingly. These revisions are documented in Field Memo 6. One large raised bed was provided at 1421 S. Cloverdale Street, instead of two smaller beds, per the homeowner s request at the time of the pre-construction briefing. The landscape drawing was revised accordingly and signed by the homeowner on January 28, The revision is documented in Field Memo 7. In addition to the excavation related changes, superficial revisions were made to some of the restoration elements. These revisions, as well as design deviations discussed above, are documented in the annotated drawings in Attachment CONCURRENT ACTIVITIES The following activities related to the overall T-117 NTCRA were conducted concurrent with the Residential Yards cleanup. Gas Service Installation. On January 2, 2013, InfraSource, on behalf of Puget Sound Energy, excavated planting strip soil to provide a gas service connection to the building at 1432 S. Cloverdale Street. Soil was excavated from both the north and south planting strips on S. Cloverdale Street in areas identified for removal during the Residential Yards cleanup. Upon discovery of the work, the City team coordinated with InfraSource and NRC to ensure that soil Integral Consulting Inc. 2-8

28 excavated from the planting strips would be disposed of with other soils from the Residential Yards cleanup at a Subtitle D landfill. The gas service excavation activity is described in Field Memo 5 (Attachment 3). Pre-design Confirmation Sampling. Integral performed pre-design confirmation sampling within the southern planting strip on S. Cloverdale Street and within Adjacent Streets decision unit 16 (DU16) on 16th Avenue S. Sampling activities were performed from January 23 to 25, 2013, in accordance with the approved pre-design QAPP (Appendix F to the RADR; Integral 2012). Procedures and findings related to the sampling effort in the southern planting strip are documented in Field Memos 3 and 11 (Attachment 3). Analytical results from sampling of DU16 will be presented in the final data report for the Adjacent Streets area (currently in preparation). Pilot Infiltration Testing. SPU performed PIT to support the design of the planned drainage improvements for the Adjacent Streets. PIT was performed in accordance with the EPAapproved PIT work plan (Integral and DCG 2013). The PIT program involved excavation of 10 test holes at various locations within the Adjacent Streets study area and generated approximately 103 tons of excavated soil. The City team sampled excavated soil from each PIT location for waste characterization testing. The analytical results indicated that the PIT excavation spoils were suitable for disposal at Allied Waste s Subtitle D landfill. Following completion of the PIT, NRC over-excavated an additional 2 feet from each location to remove any sloughed soil, then backfilled to pre-existing grades. PIT locations were backfilled with excess import material from the yards and southern planting strip work and 37 tons of additional import material. PIT results will be provided in the Adjacent Streets and Stormwater removal design documents (currently in preparation). Disposal of Investigation Derived Waste. Investigation derived waste (IDW) from the Adjacent Streets and Residential Yards study areas was temporarily stored in 19 drums staged on S. Donovan Street, east of 17th Avenue S. The IDW consisted of approximately 3 tons of drill cuttings, Lexan core tubes, discarded PPE, aluminum foil, and decontamination water. Two of the drums contained drill cuttings from borings in Adjacent Street excavation units. Some Adjacent Streets soils exceed 50 mg/kg total PCBs and are managed in accordance with the Toxic Substances Control Act. The City team collected and analyzed a composite sample from the two drums following the protocols in Attachment 3 of the PIT work plan (Integral and DCG 2013) and confirmed that the IDW had a concentration less than 50 mg/kg and was acceptable for disposal at Allied Waste s Subtitle D landfill. Analytical test results are summarized in Table 2-5. NRC disposed of all 19 drums under the same waste profile as the Residential Yards soil. Geotechnical Investigation. Zipper Geo Associates, LLC, performed six geotechnical borings on S. Donovan Street to support the design of median slope restoration during the Adjacent Streets cleanup. Drilling occurred on March 6 and 7, 2013, and was coordinated with NRC, who Integral Consulting Inc. 2-9

29 provided roll-off bins for collection of drill cuttings. Approximately 3 tons of drill cuttings was disposed of under the same waste profile as the Residential Yards soil. Power Pole Replacement. Seattle City Light replaced power poles on 16th Avenue S., Dallas Avenue S., and S. Cloverdale Street between February 14 and March 18, Based on prior sampling performed near pole locations, the excavated soil from the pole installations on 16th Avenue S. and Dallas Avenue S. was disposed of under the same waste profile as the Residential Yards soil. Soil from the pole replacement on S. Cloverdale Street did not require special handling. Integral Consulting Inc. 2-10

30 3 PERFORMANCE STANDARDS AND CONSTRUCTION QUALITY CONTROL CQA/CQC was managed in accordance with the CQAP (Appendix B of the RADR; Integral 2012) and the RAWP (Integral and NRC 2012). Key elements of CQA/CQC activities are summarized below. NRC s quality control representative (Russ Morgan) performed CQC. The City s resident engineer (Eric Pilcher, Integral) and quality assurance representative (Zach Estela, Integral) performed CQA. 3.1 CQA/CQC PROTOCOLS This section describes the protocols that were followed in providing oversight during removal action construction and in documenting the work performed CQA/CQC Documentation and Reporting NRC generated daily progress reports and provided them to the City team via . In addition to describing the activities that occurred onsite each day, the reports contained copies of health and safety meeting minutes, compaction and concrete testing reports, disposal receipts, import material receipts, and subcontractor submittals. Copies of the daily CQC reports are provided in Attachments 4, 5, and 6. The City s team prepared weekly CQA reports that described the work that occurred and summarized the monitoring, sampling, and verification activities that were performed. The CQA reports were submitted to EPA via early following each week. Copies of the weekly CQA reports are provided in Attachment Weekly Progress Meetings Weekly progress meetings were generally held every Tuesday afternoon at 1:00 p.m. The meetings were held in NRC s job trailer and led by the resident engineer. Typical attendees included EPA s remedial project manager and USACE s construction oversight manager; the City s project coordinator, consultant project manager, resident engineer, and quality assurance representative; and NRC s project manager, CQC representative, and site supervisor. Meeting agendas were distributed via in advance of each meeting, and later revised to become the meeting minutes. Copies of the meeting minutes are included in Attachment Inspections, Sampling, and Verification Activities NRC utilized a variety of independent subcontractors to perform various CQC monitoring, sampling, and verification activities during the Residential Yards cleanup. The Center for Integral Consulting Inc. 3-1

31 Toxicology and Environmental Health, LLC, provided dust and noise monitoring during excavation activities. DHA provided survey confirmation of target elevations. Robinson Nobel, Inc., provided density testing of compacted backfill. Otto Rosenau provided compressive strength testing of placed concrete. Onsite Environmental, Inc., provided analytical chemistry testing of construction wastewater. A summary of monitoring activities and results is provided in Table 3-1. Copies of reports from subcontractor monitoring, sampling, and verification are provided in Attachments 22, 25, and 28. Integral performed CQA throughout all construction activities. Routine observations of construction activities were made throughout each day. Questions and concerns regarding construction practices were communicated directly to NRC s CQC representative, who in turn coordinated with NRC s site supervisor and field crew as necessary to correct deficiencies. In addition to construction observation and review of CQC documentation, Integral performed analytical sampling of import materials to verify acceptability. Results from analytical testing of import materials are provided in Attachment Submittal Management All construction contractor submittals were distributed to the City team via . Once received, the City team reviewed them for accuracy and concurrence with the construction drawings and technical specifications and either approved (with or without exception) or denied them based on incorrect or insufficient information. Copies of subcontractor submittals are included in Attachments 7 and Field Change Documentation Site conditions and refinement of excavation prisms resulted in the generation of requests for information (RFI) and field memorandums. NRC generated RFIs and submitted them to the City via to document questions encountered and to suggest potential solutions. The City s team reviewed each RFI and responded accordingly. A summary of NRC s RFIs and the corresponding responses from the City s team is presented in Table 3-2. Copies of the RFIs and the responses are provided in Attachment 9. Similarly, the City issued field memos to NRC via , to clarify design intent or otherwise modify or authorize tasks beyond the scope of the construction drawings and technical specifications. A summary of the field memos issued by the City is presented in Table 2-4. Copies of the field memos are provided in Attachment 3. Integral Consulting Inc. 3-2

32 3.1.6 Post-Construction Documentation Upon completion of excavation, backfill, and restoration, DHA collected survey data and submitted post-excavation surveys, subgrade surveys, and final surveys (Attachments 12, 24, and 26, respectively). Review of the post-excavation surveys indicates that target removal elevations were achieved within each of the designated residential yards, planting strips, and southern alleyway. The removal depths, corresponding elevations, and contaminant concentrations for material left in place are presented in Table 3-3. NRC also maintained a set of drawings, which it marked up during construction to document as-built conditions. The as-built drawings are provided in Attachment 29. The City s CQA representative and NRC s site supervisor conducted post-construction walkthroughs with each property owner from March 5 to 22, The City provided results from those walkthroughs in a letter of substantial completion to EPA on March 20, A prefinal inspection was held with EPA s remedial project manager and USACE s construction oversight manager, and the City s project coordinator and resident engineer on April 2, EPA issued its findings from the inspection in a letter to the City on April 11, Similarly, the City responded with an acknowledgement of EPA s findings on April 12, Copies of this post-construction documentation are provided in Attachment SUMMARY OF CQA/CQC OBSERVATIONS This section provides a summary of key CQA/CQC observations, and where necessary, corrective measures that were implemented to ensure that the Residential Yards cleanup was completed in accordance with the requirements and intent of the construction drawings and technical specifications Material Handling, Quantities, and Disposal Generated wastes were transported and disposed of in accordance with the technical specifications (Appendix A of the RADR; Integral 2012) and the RAWP (Integral and NRC 2012). All facilities receiving materials generated from the site were verified to be acceptable under EPA s OSR. OSR documentation is included in Attachment 14. Cleared plant material that was not classified as noxious weeds was mulched at Pacific Topsoils. Recoverable concrete from demolished sidewalks was recycled at Renton Concrete Recyclers. Recoverable metals from sheds, fences, and other metal debris was recycled at Seattle Iron & Metals. Noxious weeds were disposed of at Seattle s South Transfer Station. Grubbed vegetation, trash, and non-recyclable debris were comingled with excavated soil and disposed of at Roosevelt Integral Consulting Inc. 3-3

33 Regional Landfill. Waste characterization for the contaminated material is provided in Attachment 13. Soil disposal logs provided by NRC and tipping receipts provided by Allied Waste verify that all waste material has been accounted for. Potentially contaminated water from excavations and puddles, PIT locations, and decontamination was disposed of at MarVac. Wastewater analytical testing and shipping receipts are provided in Attachment 17. A detailed summary of the quantities of material generated during the Residential Yards cleanup is provided in Table 2-2. A detailed summary of the quantities of material imported during the Residential Yards cleanup is provided in Table Health and Safety Health and safety concerns and procedures were addressed in three separate, but related, HASPs developed for 1) construction workers; 2) government and CQA oversight workers; and 3) the community at large. NRC and its subcontractors performed the work in accordance with the construction HASP submitted as Appendix E of the RAWP (Integral and NRC 2012). Construction oversight and quality assurance activities were performed in accordance with the site CQA HASP included as Appendix B of the RADR, and measures to protect homeowners, residents, and the general public were presented in the community HASP included as Appendix D of the RADR (Integral 2012). Due to the site s location in a populated residential area, the City team took certain measures to protect the public, in accordance with the community HASP. These measures included: Setting barriers around exclusion zones Monitoring for fugitive dust Monitoring construction related noise Restricting smoking within exclusion zones and within 25 feet of any building entrance Limiting unnecessary idle time to 2 minutes or less Providing flaggers for large trucks entering and leaving the work zone Promoting community awareness of the construction activities via fact sheets, community meetings, and listserv posts. In addition, NRC provided no parking signs 72 hours in advance of street parking disruptions and coordinated with residents 48 hours in advance of construction activities within individual yards. Integral Consulting Inc. 3-4

34 NRC s site safety and health officer (or a designated alternate) conducted daily safety meetings prior to the beginning of work for each shift. Topics covered for each meeting are included on NRC s daily health and safety reports in Attachment 6. There were no reportable health and safety incidents and no known near misses that occurred as a result of construction activities during the Residential Yards cleanup Stormwater Management NRC implemented stormwater BMPs in accordance with Section 4.8 of the RAWP (Integral and NRC 2012). Specific BMPs included the use of geotextile, plastic, and plywood for crossings over sidewalks and planting strips; plastic sheeting with boom berms surrounding roll-off bins in the loading area; installation and inspection of catch basin inserts; and regular manual sweeping of work areas to collect and remove fugitive materials. Stormwater was collected from excavated areas by vacuum truck and transported to MarVac for disposal. Stormwater collected at the staging area was pumped to a Baker tank and managed through SPU s existing stormwater control system. Analytical results for the stormwater have been provided to EPA through the issuance of monthly progress reports Community Outreach and Coordination Community outreach during the Residential Yards cleanup was an essential aspect of the work. Integral and Harris & Smith Public Affairs coordinated with affected residents throughout site cleanup and restoration. The City team incorporated stakeholder input before, during, and after the cleanup work. Several changes to the approved restoration design were made in response to homeowner requests, as documented in Section 2.2 of this RACR. 3.3 FINAL INSPECTION AND CERTIFICATIONS The City submitted a letter of substantial completion to EPA on March 20, Following the letter, a pre-final inspection was held on April 2, EPA s remedial project manager and USACE s construction oversight manager, and the City s project coordinator and resident engineer attended the pre-final inspection. During the inspection, EPA observed the postconstruction condition of each designated property. The only noted deficiency was that two evergreen clematis vines at 1440 S. Cloverdale Street appeared to be dead or dying. The City agreed to provide replacement plants. Based on the de minimis findings during the pre-final inspection, EPA agreed to waive the requirement to conduct a Final Inspection. Copies of correspondence between the City and EPA are provided in Attachment 30. A summary of lessons learned during the Residential Yards cleanup is provided in Table 3-4. Integral Consulting Inc. 3-5

35 3.4 WARRANTY Copies of the signed restoration drawings and landscape maintenance memorandums for the residential owners/tenants are included in Attachment 30. Routine landscape maintenance is the responsibility of the homeowners; however, the City will provide assistance during the first year of establishment, on an on-call basis, in accordance with maintenance agreements between the City and individual property owners. The agreements include a 1-year warranty on sod and plantings, on the condition that the property owner provides routine maintenance during the first year. To assist in routine maintenance, the property owner may request that the City provide professional assistance twice during the course of the first year. In addition, the City provided a maintenance memorandum to each property owner, describing recommended landscape maintenance activities specific to the property owner s yard. Integral Consulting Inc. 3-6

36 4 LONG-TERM MAINTENANCE AND MONITORING The Residential Yards cleanup met the requirements of the NTCRA, thus restoring this portion of the T-117 site to unrestricted land use without the need for further remediation, long-term monitoring, or institutional controls. Integral Consulting Inc. 4-1

37 5 REFERENCES Ecology Cleanup Levels and Risk Calculations Database. Washington State Department of Ecology, Toxics Cleanup Program. September. Integral Removal Action Design Report, Residential Yards Area; LDW Superfund Site, Terminal 117 Early Action Area. Prepared for the City of Seattle. Integral Consulting Inc., Seattle, WA. November 30. Integral and DCG Pilot Infiltration Test Work Plan, Adjacent Streets Area; LDW Superfund Site, Terminal 117 Early Action Area. Prepared for the City of Seattle. Integral Consulting Inc., Seattle, WA, and Davido Consulting Group, Inc., Lake Forest Park, WA. January 28. Integral and NRC Removal Action Work Plan, Residential Yards Area; LDW Superfund Site, Terminal 117 Early Action Area. Prepared for the City of Seattle. Integral Consulting Inc., Seattle, WA, and National Response Corporation, Portland, OR. November 30. USEPA Action Memorandum for a Non-Time-Critical Removal Action at the Terminal 117 Early Action Area of Lower Duwamish Waterway Superfund Site, Seattle, Washington. U.S. Environmental Protection Agency Region 10, Seattle, WA. September 30. USEPA. 2011a. OSWER Directive , Close Out Procedures for National Priorities Use Sites, Office of Superfund Remediation and Technology Innovation, U.S. Environmental Protection Agency. May. USEPA. 2011b. Administrative Settlement Agreement and Order on Consent for Removal Action Implementation (Settlement Agreement and Statement of Work [SOW]). U.S. Environmental Protection Agency Region 10, Seattle, WA. June 9. USEPA Regional Screening Level Residential Soil Table. U.S. Environmental Protection Agency Region 9, San Francisco, CA. May. Windward, Integral, AECOM, Crete, and DOF Lower Duwamish Waterway Superfund Site, T-117 Early Action Area, Revised Engineering Evaluation/Cost Analysis. Prepared for the Port of Seattle and the City of Seattle. Windward Environmental LLC, Seattle, WA; Integral Consulting Inc., Seattle, WA; AECOM, Seattle, WA; Crete Consulting, Inc., Seattle, WA; and Dalton, Olmsted & Fuglevand, Inc., Seattle, WA. June 3. Integral Consulting Inc. 5-1

38 FIGURES

39 Figure 1-1. T-117 Early Action Cleanup Site Overview N:\GIS\Projects\A0006_City_of_Seattle\15_T117\Working_MXDs\NotStandard\Template_Overview_CIP_ mxd - 12:38:26 PM

40 Dallas Ave S DU South Park Marina DU3 DU S:\se\A0006_Lower-Duwamish_Various\A0006_15H_T117\Working_MXDs\60pctDesign\Fig2_Excavation_Yards_ mxd 7/30/ :22:24 PM 2574 T-117 EAA Boundary Alleyway and Landscape Strip Excavation Areas Residential Yard Excavation Area Buildings with addresses Background imagery is for reference purposes only, courtesy of the City of Seattle and dated Feet N 14th Ave S S Cloverdale St S Donovan St PS North A PS North B PS North C PS South A PS South B DU DU36a DU35a Area 17 Area 16 PS South C DU DU33a Area 15 Area 14 Area DU25 DU th Ave S th Ave S Boeing South Park T-117 Upland Figure Soil Excavation Boundaries for Residential Yards Lower Duwamish Superfund Site - Terminal 117 Early Action Area

41 U.S. Army Corps of Engineers Project Manager Leanna Woods Pan Agency Construction Oversight Manager Jayson Osborne Bob Wilkins U.S. Environmental Protection Agency Region 10 Remedial Project Manager Piper Peterson Other Agencies Washington Department of Ecology Source Control Lead Rick Thomas Agency Statistical Analysis Consultant Greg Glass City Consultant Integral Consulting Inc. Technical Consultant Lead/ Principal-in-Charge Reid Carscadden City of Seattle Seattle City Light Project Manager Bill Devereaux Project Coordinator Mary Mitchener City Consultant Integral Consulting Inc. Consultant Project Manager Linda Baker Resident Engineer/ Site Health and Safety Officer Eric Pilcher City Consultant Integral Consulting Inc. Analytical Field Lead Kim Carlton Quality Assurance Representative Zach Estela Regulatory Agency Owner Consultant Contractor Contractor NRC Environmental Services Project Manager Russell Morgan Quality Control Representative Scott St. John Project Supervisor/ Safety Officer Scot Overdick Subconsultants Landscape Architect Drew Coombs, J.A. Brennan Community Involvement Barbara Smith, Harris & Smith Public Affairs Analytical Laboratory Analytical Resources, Inc. Both Teams Design Team Construction Team Subcontrators Independent Surveyor Duane Hartman & Associates, Inc. Landscaper Teufel Landscaping Figure 1-3. Design and Construction Management Team Organization

42 TABLES

43 T 117 Residential Yards Table 1-1. Project Documents Document Title Date Approved/Issued Engineering Evaluation / Cost Analysis June 3, 2010 Action Memorandum October 15, 2010 Administrative Settlement Agreement and Order on Consent June 9, 2011 Joint NTCRA Management Plan February 10, 2012 Removal Action Design Report December 3, 2012 a Drawings and Specifications Construction Quality Assurance Plan Site Quality Assurance Health and Safety Plan December 3, 2012 a December 3, 2012 a December 3, 2012 a Community Health and Safety Plan September 25, 2012 Quality Assurance Project Plan December 3, 2012 a Pre-excavation Confirmation Sampling Results December 3, 2012 a Design Memorandum, 1430 S. Donovan Street January 8, 2013 Removal Action Work Plan December 3, 2012 a Construction Health and Safety Plan December 3, 2012 a Pilot Infiltration Testing Work Plan January 30, 2013 Notes: NTCRA = non-time critical removal action a Conditional approval granted on November 20, Integral Consulting Inc. Page 1 of 1

44 Table 1-2. Project Team Contact Information Organization Individual Project Role Phone Mobile EPA Region 10 Piper Peterson Remedial Project Manager (206) (206) USACE Jayson Osborne Agency Construction Oversight Manager (206) (206) Bob Wilkins Agency Construction Oversight Manager (509) Kristen Kerns (206) (541) Greg Glass Agency statistical analysis consultant Seattle City Light Bill Devereaux Project Manager (206) Mary Mitchener Project Coordinator (206) (206) Integral Consulting Inc. Reid Carscadden Consultant Team Principal In Charge (206) (206) Linda Baker Consultant Team Project Manager (206) (206) Eric Pilcher Resident Engineer/Site Health and Safety Officer (206) (253) Mark Bryant Resident Engineer (Alternate) (206) (206) Kim Carlton Analytical Quality Assurance Manager (360) Zach Estela Quality Assurance Representative (206) (206) Harris & Smith Public Affairs Barbara Smith Community Involvement Representative (206) (206) J.A. Brennan Associates Jim Brennan Landscape Architect, Principal (206) Drew Coombs Landscape Architect, Design Lead (206) (206) NRC Scott St. John NRC Project Manager (206) Russell Morgan NRC Quality Control Representative (503) Scot Overdick NRC Project Supervisor / Safety Officer (425) soverdick@nrcc.com Kathy Weed NRC Project Supervisor / Safety Officer (alternate) kweed@nrcc.com Ken Koppler, CIH NRC Safety Manager (971) Duane Hartman & Associates, Inc. Douglas Hartman Survey Manager (425) Mark Chaney Party Chief Teufel Landscaping Steve Johnson Landscaping Manager (206) Other Subcontractors All City Fence Co. Fencing Subcontractor Asplundh Tree Expert Co. Tree Trimming and Felling Subcontractor Center for Toxicology and Environmental Health, LLC Air Quality and Noise Monitoring Subcontractor Emerald Paving, Inc. Asphalt Subcontractor Evergreen Concrete Cutting, Inc. Concrete Cutting Subcontractor G. A. Jorgensen Company, Inc. Concrete Installation Subcontractor Onsite Environmental, Inc. Environmental Laboratory Otto Rosenau & Associates, Inc. Concrete Testing Subcontractor Robinson Nobel, Inc. Soil Compaction Testing Subcontractor Integral Consulting Inc. Page 1 of 1

45 Table 2-1. Removal Action Chronology Activity Start Date End Date Purchase Order Issued -- October 11, 2012 Pre-Construction Conference -- November 15, 2012 Mobilization & Setup November 26, 2012 December 6, S. Cloverdale Street Pre-Construction Briefing -- November 30, 2012 Clearing December 4, 2012 December 10, 2012 Excavation December 10, 2012 January 4, 2013 Backfill - Subgrade December 19, 2012 January 8, 2013 Backfill - Turf Soil January 14, 2013 January 15, 2013 Backfill - Planting Soil -- January 23, 2013 Concrete Placement January 21, 2013 January 28, 2013 Sod Installation January 25, 2013 January 28, 2013 Plantings February 8, 2013 February 21, 2013 Fence Installation -- February 12, 2013 Mulch Planting Beds -- March 5, 2013 Post-Construction Walkthrough -- March 5, S. Cloverdale Street Pre-Construction Briefing -- December 7, 2012 Clearing December 10, 2012 December 12, 2012 Excavation January 7, 2012 January 11, 2013 Backfill - Subgrade January 9, 2013 January 15, 2013 Installation of Backflow Preventer a -- January 15, 2013 Backfill - Turf Soil January 15, 2013 January 16, 2013 Backfill - Planting Soil January 23, 2013 January 23, 2013 Sod Installation January 25, 2013 February 11, 2013 Concrete Placement January 21, 2013 January 28, 2013 Gravel Driveway Placement January 14, 2013 January 29, 2013 Plantings February 11, 2013 February 21, 2013 Fence Installation -- February 28, 2013 Mulch Planting Beds -- March 5, 2013 Post-Construction Walkthrough -- March 5, S. Cloverdale Street Pre-Construction Briefing -- January 14, 2013 Clearing -- January 15, 2013 Excavation (Front Yard) January 15, 2013 January 22, 2013 Installation of Backflow Preventer a -- January 15, 2013 Backfill - Subgrade (Front Yard) January 18, 2013 January 25, 2013 Integral Consulting Inc. Page 1 of 4

46 Table 2-1. Removal Action Chronology Activity Start Date End Date Backfill - Turf Soil (Front Yard) January 21, 2013 January 28, 2013 Excavation (Back Yard) January 29, 2013 January 31, 2013 Backfill - Subgrade (Back Yard) January 29, 2013 January 31, 2013 Sod Installation January 31, 2013 February 11, 2013 Concrete Placement February 1, 2013 February 8, 2013 Plantings February 8, 2013 February 11, 2013 Fence Installation (Front Yard) -- February 11, 2013 Pea Gravel Placement -- February 12, 2013 Fence Installation (Back Yard) -- February 25, 2013 Crushed Gravel Placement -- February 28, 2013 Mulch Planting Beds -- March 5, 2013 Post-Construction Walkthrough -- March 5, S. Cloverdale Street Pre-Construction Briefing -- January 1, 2013 Excavation (Front Yard) January 14, 2013 January 15, 2013 Backfill - Subgrade (Front Yard) -- January 16, 2013 Backfill - Turf Soil (Front Yard) -- January 16, 2013 Rock Placement (Front Yard) January 24, 2013 January 25, 2013 Sod Installation (Front Yard) -- January 31, 2013 Clearing (Back Yard) -- January 23, 2013 Excavation (Back Yard) February 5, 2013 February 8, 2013 Backfill - Subgrade (Back Yard) February 6, 2013 February 11, 2013 Backfill - Turf Soil (Back Yard) February 11, 2013 February 12, 2013 Fence Installation -- February 13, 2013 Sod Installation (Back Yard) -- February 22, 2013 Plantings March 5, 2013 March 14, 2013 Mulch Planting Beds -- March 5, 2013 Post-Construction Walkthrough -- March 4, S. Cloverdale Street Pre-Construction Briefing -- January 28, 2013 Clearing January 30, 2013 January 31, 2013 Excavation January 31, 2013 February 1, 2013 Backfill - Subgrade -- February 1, 2013 Planting Bed February 12, 2013 February 13, 2013 Backfill - Planting Soil -- February 19, 2013 Sod Installation -- February 22, 2013 Fence Installation -- February 13, 2013 Integral Consulting Inc. Page 2 of 4

47 Table 2-1. Removal Action Chronology Activity Start Date End Date Post-Construction Walkthrough -- March 11, 2013 Compost Amendment March 18, 2013 March 19, 2013 S. Cloverdale St. Planting Strips Pre-excavation Confirmation Sampling (South) b January 23, 2013 January 25, 2013 Excavation (North) January 23, 2013 January 25, 2013 Backfill - Subgrade (North) January 23, 2013 January 28, 2013 Backfill - Turf Soil (North) January 24, 2013 January 28, 2013 Sawcuts at Tree Locations (North) -- January 29, 2013 Sod Installation (North) -- January 30, 2013 Receipt of Analytical Results (South) b -- February 7, 2013 Tree Planting (North) February 8, 2013 February 8, 2013 Excavation (South) February 25, 2013 February 26, 2013 Backfill - Subgrade (South) February 25, 2013 February 27, 2013 Backfill - Turf Soil (South) February 25, 2013 February 27, 2013 Sod Installation (South) February 27, 2013 March 1, 2013 Trees Planting (South) -- March 4, 2013 Mulch Planting Beds -- March 5, 2013 Grouting at Sawcuts March 8, 2013 March 11, 2013 Additional Sawcuts (North) -- March 8, 2013 Revise Finished Grade near 1415 S. Cloverdale St. -- March 11, 2013 Tree Relocation (North) -- March 11, 2013 Sidewalk Patching (North) -- March 14, 2013 Southern Alleyway Excavation January 31, 2013 February 7, 2013 Backfill - Subgrade & Gravel Surface January 31, 2013 February 11, 2013 Fine Grading of Surface February 11, 2013 February 12, S. Donovan Street Pre-Construction Briefing -- February 2, 2013 Clearing -- February 11, 2013 Excavation February 11, 2013 February 14, 2013 Backfill - Subgrade February 14, 2013 February 15, 2013 Backfill - Turf Soil -- February 19, 2013 Sod Installation -- February 22, 2013 Concrete Placement February 19, 2013 February 27, 2013 Planting Soil Placement -- February 19, 2013 Mulch Planting Beds -- March 5, 2013 Post-Construction Walkthrough -- March 5, 2013 Integral Consulting Inc. Page 3 of 4

48 Table 2-1. Removal Action Chronology Activity Start Date End Date 1430 S. Donovan Street Pre-Construction Briefing -- January 14, 2013 Clearing -- February 14, 2013 Excavation February 14, 2013 February 15, 2013 Backfill - Subgrade February 15, 2013 March 4, 2013 Backfill - Turf Soil -- February 19, 2013 Sod Installation -- February 22, 2013 Retaining Wall Installation February 28, 2013 March 4, 2013 Gravel Driveway Placement -- March 1, 2013 Handrail Installation -- March 6, 2013 Planting Soil Placement -- March 14, 2013 Plantings -- March 14, 2013 Mulch Planting Beds -- March 14, 2013 Post-Construction Walkthrough -- March 18, Dallas Avenue S. Pre-Construction Briefing NA c NA c Clearing -- February 19, 2013 Excavation February 19, 2013 February 22, 2013 Backfill - Subgrade February 19, 2013 February 26, 2013 Gravel Driveway Placement February 22, 2013 February 27, 2013 Backfill - Turf Soil February 27, 2013 February 28, 2013 Concrete Placement February 27, 2013 March 5, 2013 Sod Installation -- March 4, 2013 Plantings -- March 4, 2013 Fence Installation -- March 6, 2013 Mulch Planting Beds -- March 5, 2013 Post-Construction Walkthrough -- March 22, 2013 Demobilization -- March 5, 2013 Pre-Final Inspection -- April 2, 2013 Notes: -- = Work was performed within one day. See end date. NA = not applicable a Work was performed by an outside contractor working under the direction of the property owner. b Work performed by design team. c Dwelling was unoccupied at time of removal action construction. Integral Consulting Inc. Page 4 of 4

49 Table 2-2. Disposal Facilities Facility Name Facility Type Address Phone Number Allied Waste, Subtitle D Landfill 500 Roosevelt Grade Road Roosevelt Regional Roosevelt, WA Landfill (509) Solid Waste Permit # Permit # / RCRA ID # Material Type Description Contaminated Soil and Debris Grass, grubbed vegetation, excavated soil, debris, used PPE, miscellaneous refuse Quantity 2,378 tons Renton Concrete Recyclers Recycling Facility 500 Monster Road SW Renton, WA (206) NA Concrete Concrete from walkways, pavers 5 CY Seattle Iron & Metals Corporation Recycling Facility 601 South Myrtle Street Seattle, WA (206) RCRA ID # WAH Metals Metal shed, chain link fencing 0.43 tons Marine Vacuum Services, Inc. Water Treatment Facility 1516 S Graham Street Seattle, WA (206) RCRA ID # WAD Wastewater Rainwater from excavated areas and surface puddles, decontamination rinse water 4,750 gallons Pacific Topsoils, Inc. Mulching / Composting Facility 6000 S 129th Street Tukwila, WA (206) NA Organic Yard Waste Cleared vegetation 16.1 CY City of Seattle, South Transfer Station Notes: NA = not applicable CY = cubic yards Municipal Recycling, Composting, and Disposal Facility 130 S Kenyon Street Seattle, WA (206) NA Noxious Weeds Himalayan blackberry bushes 0.91 tons Integral Consulting Inc. Page 1 of 1

50 Table 2-3. Material Import Facilities Facility Address Phone Number Import Material Type Description Quantity Lloyd Enterprises, Inc. 80 5th Avenue (253) Type 17 Aggregate Bank Run Gravel Tons Milton, WA Type 2 Aggregate 1 ¼ Minus Crushed Tons Rock Playfield Sand Gas Pipe Bedding Tons Type 9 Aggregate 3/8" Washed Pea Gravel Tons Miles Sand & Gravel Company 1220 M Street SE Auburn, WA (253) Type 22 Aggregate 3/4 Crushed Gravel Tons Washington Rock Quarries, Inc. Pacific Topsoils, Inc. King Creek Pit Champion 1 Road Orting, WA S 129th Street Tukwila, WA (253) (206) Type 17 Aggregate Bank Run Gravel Tons Turf Area Soil 75% Sandy Loam, 25% Tons Organic Compost Planting Soil 67% Sandy Loam, 25% Tons Organic Compost Bark Mulch Medium Bark Mulch -- a Sand Washed Sand 1.5 CY Type 1 Aggregate 3/4" Minus Crushed Rock 1 CY Sayers Fueld Landscape Supplies 3900 Rainier Ave S. Seattle, WA Notes: a Import receipts from the landscaping subcontractor were not provided. (206) Round River Rock 1 1/2" Drain Rock 3 CY Integral Consulting Inc. Page 1 of 1

51 Table 2-4. Field Memorandums No. Title/Content Issue Date EPA Approval Date 001 Excavation Near Structural Elements December 21, 2012 December 21, Excavation at 1440 S. Cloverdale Street January 7, 2013 January 9, Pre-excavation Sampling in Southern Planting Strip January 21, 2013 a January 22, Excavation at 1445 S. Cloverdale Street Front Yard January 14, 2013 January 15, PSE Excavation for Gas Service Connection January 15, 2013 NA b 006 Restoration at 1410 S. Coverdale Street January 24, 2013 NA c 007 Restoration at 1421 S. Cloverdale Street January 24, 2013 NA c 008 Excavation in Southern Alleyway February 4, 2013 February 7, Excavation at 1418 S. Cloverdale Street February 6, 2013 February 7, Excavation at 8523 Dallas Avenue S. February 8, 2013 February 15, Excavation in Southern Planting Strips February 19, 2013 February 19, 2013 Notes: NA = not applicable a This field memo was initially issued on January 11, 2013 and later retracted. b Field memo generated for informational purposes only. c Design revision(s) related solely to restoration. Integral Consulting Inc. Page 1 of 1

52 Table 2-5. Pilot Infiltration Test Excavation and Investigation Derived Waste Sample Summary Total PCB Aroclors Sample Location Sample ID Date Collected (mg/kg dry wt) Test Hole 1 TH-1-D-1-4 February 25, Test Hole 2 TH-2-S-0-1 February 4, TH-2-D Test Hole 3B TH-3B-D-2-4 February 4, Test Hole 4 TH-4-D February 25, Test Hole 5 TH-5-D-1-4 March 1, Test Hole 6 TH-6-D-1-5 February 21, Test Hole 7B TH-7B-D-1-5 February 20, Test Hole 8B TH-8B-S-1-2 February 5, TH-8B-D TH-8B-D Test Hole 8C TH-8C-D-1-5 February 20, Test Hole 10 TH-10-D-1-7 March 1, Various a TH-P2comp-S-0-1 February 20 - March 1, Street Excavation Unit EU-WC-01 February 5, Waste Drums b Notes: PCB = polychlorinated biphenyl a Sample is a surface composite from test holes 1, 4, 5, 6, 7B, 8C, and 10. b Sample is a composite from two waste drums containing cuttings from Adjacent Street excavation units in which TSCA exceedances were previously encountered. Integral Consulting Inc. Page 1 of 1

53 Table 3-1. Construction Quality Assurance/Quality Control Monitoring Parameter Measuring Entity Date Location Data Action level Pass/Fail Dust NRC/Integral Daily During Excavation/Backfill Visual observation Visible dust Pass Idle equipment Throughout site No idling of inactive vehicles or equipment for longer than 2 minutes Pass Smoking Throughout site No smoking on private property or within 25 feet of a building entrance Pass Background noise NRC December 13, 2012 Street in front of 1410 S. Cloverdale Street; no NRC equipment running dba, 77.5 dba with plane overhead a None, reference only Pass General construction noise Inside 1415 S. Cloverdale Street; no Vactor running dba a Pass NRC December 13, 2012 Street in front of 1410 S. Cloverdale Street; NRC equipment dba a 50 feet from work area; 85 dba L eq for general Pass running construction equipment Vactor noise level (instantaneous) NRC December 13, 2012 From 1410 S. Cloverdale Street to entrance to 1415 S. Cloverdale Street (~80') From 1410 S. Cloverdale Street to entrance to th Avenue S. (~65') dba a 50 feet from work area; 85 dba L eq for general Pass construction equipment on a time weighted average; 90 dba L eq for impact type dba a equipment. Pass From 1410 S. Cloverdale Street to corner of S. Cloverdale Street and 14th Avenue S. (~120') 80 dba a Pass January 14, 2013 From 1445 S. Cloverdale Street to far side of 16th Avenue S. (~100') From 1445 S. Cloverdale Street to front yard of 1429 S. Cloverdale Street (~100') 82.0 dba a Pass 85 dba a Pass Vactor noise level (time weighted) Total PCBs in waste water (accumulated stormwater from excavations & puddles; decontamination water) CTEH Onsite Environmental January 21, feet away from Vactor and general construction at 1425 S 74 dba (one hour L eq ) 50 feet from work area; 85 dba L eq for general Pass January 21, 2013 Cloverdale. Readings are time-weighted over several hours of construction equipment on a time weighted 80 dba (four hour L eq) monitoring during a Vactor-intensive day. average; 90 dba L eq for impact type Pass January 22, dba (six hour L eq) equipment. Pass December 27, 2012 Poly tank in staging area ND for 0.11 µg/l PQL b Marine Vacuum will not accept PCB Pass January 10, 2013 Poly tank in staging area 27 µg/l for Aroclor 4.8 µg/l PQL b. All other Aroclors 4.8 µg/l PQL concentrations >1 mg/l Pass February 19, 2013 Poly tank in staging area 5.9 µg/l for Aroclor 0.52 µg/l PQL b. All other Aroclors 0.52 µg/l PQL Pass Integral Consulting Inc. Page 1 of 7

54 Table 3-1. Construction Quality Assurance/Quality Control Monitoring Parameter Measuring Entity Date Location Data Action level Pass/Fail Airborne dust - PM10 Aerosols CTEH December 10, data points from around active construction at 1410 Cloverdale High: mg/m 3 c Average: mg/m 3 1 mg/m 3 : Implement engineering 3 mg/m 3 : Stop work Pass Total PCBs in air pump d Collection by CTEH; Analysis by Galson Laboratories December 11, data points from around active construction at 1410 Cloverdale December 12, data points from around active construction at 1410 Cloverdale December 13, data points from around active construction at 1410 Cloverdale December 14, data points from around active construction at 1410 Cloverdale December 17, data points from around active construction at 1410 Cloverdale December 18, data points from around active construction at 1410 Cloverdale High: mg/m 3 Low: mg/m 3 Avg: mg/m 3 High: mg/m 3 Low: mg/m 3 Avg: mg/m 3 High: mg/m 3 Low: mg/m 3 Avg: mg/m 3 High: mg/m 3 Low: mg/m 3 Avg: mg/m 3 High: mg/m 3 Low: mg/m 3 Avg: mg/m 3 High: mg/m 3 Low: mg/m 3 Avg: mg/m 3 December 10, 2012 Shellea P. <0.002 mg/m 3 ND 0.5 mg/m 3 PCB PEL for dermal contact Pass December 10, 2012 Track hoe (Jim D.) <0.002 mg/m 3 ND Pass December 10, 2012 Back porch at excavation site <0.002 mg/m 3 ND Pass December 11, 2012 Back porch at excavation site < mg/m 3 ND Pass December 11, 2012 Skid Steer (Jake) <0.001 mg/m 3 ND Pass December 11, 2012 Richard G. <0.001 mg/m 3 ND Pass December 12, 2012 VOID-Sample contaminated NA Pass December 12, 2012 Track hoe (Jim D.) <0.002 mg/m 3 ND Pass December 12, 2012 Back porch at excavation site <0.002 mg/m 3 ND Pass December 13, 2012 Track hoe (Jim D.) <0.003 mg/m 3 ND Pass December 13, 2012 Back porch at excavation site <0.002 mg/m 3 ND Pass December 14, 2012 Front porch at excavation site <0.001 mg/m 3 ND Pass December 14, 2012 Track hoe (Jim D.) <0.002 mg/m 3 ND Pass December 17, 2012 Track hoe (Jim D.) <0.001 mg/m 3 ND Pass December 17, 2012 Front porch at excavation site <0.001 mg/m 3 ND Pass December 18, 2012 Front porch at excavation site <0.001 mg/m 3 ND Pass December 18, 2012 Track hoe (Jim D.) <0.002 mg/m 3 ND Pass Pass Pass Pass Pass Pass Pass Integral Consulting Inc. Page 2 of 7

55 Table 3-1. Construction Quality Assurance/Quality Control Monitoring Parameter Measuring Entity Date Location Data Action level Pass/Fail Soil Compaction Robinson Noble December 19, S. Cloverdale Street 96% 85% modified Proctor; turf area subgrade Pass 96% Pass 97% Pass 93% Pass January 7, S. Cloverdale Street 91% Pass 93% Pass 91% Pass 99% Pass 98% Pass January 15, S. Cloverdale Street 99% 95% modified Proctor; sidewalk subgrade Pass 99% Pass 99% Pass 96% Pass 89% 85% modified Proctor; turf area subgrade Pass 89% Pass 1440 S. Cloverdale Street 88% Pass 88% Pass 98% 95% modified Proctor; sidewalk subgrade Pass 99% Pass 87% 85% modified Proctor; turf area subgrade Pass 90% Pass 87% Pass January 16, S. Cloverdale Street 87% Pass 91% Pass 89% Pass 88% 95% modified Proctor; driveway surfacing Fail 95% Pass 89% Fail 1445 S. Cloverdale Street 85% 85% modified Proctor; turf area subgrade Pass 85% Pass January 22, S. Cloverdale Street 96% 95% modified Proctor; driveway surfacing Pass - Retest of fail from previous session 95% Pass 95% Pass - Retest of fail from previous session Integral Consulting Inc. Page 3 of 7

56 Table 3-1. Construction Quality Assurance/Quality Control Monitoring Parameter Measuring Entity Date Location Data Action level Pass/Fail Soil Compaction Robinson Noble January 22, S. Cloverdale Street 90% 85% modified Proctor; turf area subgrade Pass 93% Pass 97% Pass 86% Pass January 25, 2013 S. Cloverdale Street Planting Strips, North Side 93% Pass 91% Pass 92% Pass January 28, 2013 S. Cloverdale Street Planting Strips, North Side 87% Pass 88% Pass 90% Pass 1425 S. Cloverdale Street 86% Pass 91% Pass 89% Pass 100% 95% modified Proctor; sidewalk subgrade Pass 96% Pass January 30, S. Cloverdale Street 86% 85% modified Proctor; turf area subgrade Pass 90% Pass January 31, 2013 Southern Alleyway 101% 95% modified Proctor; subgrade Pass 100% Pass 98% Pass February 1, 2013 Southern Alleyway 100% Pass 95% Pass 94% Pass 101% Pass 99% Pass 102% Pass February 4, 2013 Southern Alleyway and Adjacent Yards 101% Pass 99% 85% modified Proctor; turf area subgrade Pass 100% 95% modified Proctor; subgrade Pass 99% Pass 95% Pass February 5, S. Cloverdale Street, Backyard 97% 95% modified Proctor; alleyway, driveway Pass 96% subgrade Pass Southern Alleyway 96% Pass Integral Consulting Inc. Page 4 of 7

57 Table 3-1. Construction Quality Assurance/Quality Control Monitoring Parameter Measuring Entity Date Location Data Action level Pass/Fail Soil Compaction Robinson Noble February 5, 2013 Southern Alleyway 100% 95% modified Proctor; alleyway, driveway Pass 100% subgrade Pass 96% Pass 97% Pass 98% Pass 100% Pass 97% Pass February 6, S. Cloverdale Street, Backyard 96% Pass 97% Pass Southern Alleyway 98% Pass 99% Pass 96% Pass 100% Pass 97% Pass 96% Pass 99% Pass 96% Pass 100% Pass 100% Pass 100% Pass 100% Pass 100% Pass 100% Pass 100% Pass February 7, 2013 Southern Alleyway 98% Pass 95% Pass 96% Pass 99% Pass 99% Pass 100% Pass 97% Pass 97% Pass 99% Pass 99% Pass Integral Consulting Inc. Page 5 of 7

58 Table 3-1. Construction Quality Assurance/Quality Control Monitoring Parameter Measuring Entity Date Location Data Action level Pass/Fail Soil Compaction Robinson Noble February 7, 2013 Southern Alleyway 100% 95% modified Proctor; alleyway, driveway Pass 100% subgrade Pass 97% Pass February 8, 2013 Southern Alleyway 100% Pass 99% Pass 100% Pass 99% Pass 98% Pass 99% Pass 99% Pass 99% Pass 100% Pass 100% Pass February 21, Dallas Avenue S. 99% Pass 97% Pass 1430 S. Donovan Street 91% 85% modified Proctor; turf area subgrade Pass February 22, Dallas Avenue S. 96% 95% modified Proctor; driveway surfacing Pass 97% Pass February 26, Dallas Avenue S. 97% Pass 98% Pass 100% Pass S. Cloverdale Street Planting Strips, South Side 96% 85% modified Proctor; turf area subgrade Pass 93% Pass 97% Pass 99% Pass 97% Pass 97% Pass Concrete Compressive Otto Rosenau January 28, 2013 Walkways at 1410 and 1440 S. Cloverdale Street 3,040 psi at 7 days >3000 psi at 28 days Pass Strength February 18, 2013 Walkways at 1410 and 1440 S. Cloverdale Street 4,610 psi at 28 days Pass 4,420 psi at 28 days Pass 4,450 psi at 28 days Pass February 8, 2013 Walkway at 1425 S. Cloverdale Street 3,290 psi at 7 days Pass March 1, 2013 Walkway at 1425 S. Cloverdale Street 3,290 psi at 28 days Pass 5,010 psi at 28 days Pass 5,200 psi at 28 days Pass 5,090 psi at 28 days Pass Integral Consulting Inc. Page 6 of 7

59 Table 3-1. Construction Quality Assurance/Quality Control Monitoring Parameter Measuring Entity Date Location Data Action level Pass/Fail Concrete Compressive Otto Rosenau February 26, 2013 Walkway at 1418 S. Donovan Street 4,130 psi at 7 days >3,000 psi at 28 days Pass Strength March 19, 2013 Walkway at 1418 S. Donovan Street 6,000 psi at 28 days Pass 5,890 psi at 28 days Pass March 6, 2013 Walkway at 8523 Dallas Avenue S. 4,640 psi at 7 days Pass March 27, 2013 Walkway at 8523 Dallas Avenue S. 5,770 psi at 28 days Pass 5,950 psi at 28 days Pass 5,790 psi at 28 days Pass Notes: CTEH = Center for Toxicology and Environmental Health a These readings were instantaneous and do not equate to the time-varying A-weighted one hour equivalent constant sound level (L eq) limitation specified in SMC B. b Practical Quantitation Limit c Results as provided by CTEH via December 11, (See page 1 of Appendix E1 for documentation.) d Limit of Quantitation <0.05 µg Integral Consulting Inc. Page 7 of 7

60 Table 3-2. Requests for Information No. Title/Content Issue Date Response Date 001 Storm Water Discharge December 4, 2012 December 5, Request for AutoCAD Files December 5, 2012 December 5, Excavation Near Structures December 11, 2012 December 14, Type of Proctor Test for Imported Material December 13, 2012 December 17, Sidewalk Subgrade Material January 2, 2013 January 7, Downspout Terminations at 1440 S. Cloverdale Street January 8, 2013 January 11, Sidewalk Transition at 1425 S. Cloverdale Street January 8, 2013 January 11, Reuse of Pavers from 1410 S. Cloverdale Street January 11, 2013 January 14, Pre-excavation Grading within Southern Alley January 11, 2013 January 17, Concrete within Shed at 8523 Dallas Avenue S. January 14, 2013 January 17, Lift Thickness of Type 2 Aggregate at 1440 S. Cloverdale Street January 13, 2013 January 14, Removal of Owner's Equipment from 1425 S. Cloverdale January 14, 2013 January 17, 2013 Street 013 Sidewalk Base Material at 8523 Dallas Avenue S. January 14, 2013 January 17, Extension for Dallas Avenue S. Street Use Permit January 16, 2013 February 15, Removal of Light Post and Protection of Structures at 1425 S. Cloverdale Street January 18, 2013 January 21, Reinstallation of Downspouts at 1440 S. Cloverdale Street January 25, 2013 January 31, Sidewalk Subgrade Material at 1425 S. Cloverdale Street January 25, 2013 January 31, Reinstallation of Fence at 1425 S. Cloverdale Street January 29, 2013 January 31, Request for Advanced Notice of Plan Revisions February 1, 2013 February 4, Detail of Parking Area at 1430 S. Donovan Street February 19, 2013 February 20, 2013 Integral Consulting Inc. Page 1 of 1

61 Table 3-3. Excavation Depths, Elevations, and Residual Concentrations Affected Property, Ownership, Minimum Removal Depth Lowest DU Surface Elevation (ft NAVD88) Removal Elevation (ft NAVD88) Residual Analytical Data b Total PCB Aroclors (mg/kg dry wt) Dioxins/Furans (ng/kg TEQ) and Decision Unit (ft bgs) a 1410 S. Cloverdale Street (McKnight) DU c 1421 S Cloverdale Street (Hill) DU36a J 1425 S. Cloverdale Street (Collins/Johnson) DU J c DU35a J 1440 S. Cloverdale Street (Collins/Malagon) DU14 - Sub Area DU14 - Sub Area c DU14 - Sub Area S. Cloverdale Street (Barnett) DU32a 0.5 d U c 9.5 J c DU33a J 1418 S. Donovan Street (Carroll) DU25 - Sub Area DU25 - Sub Area J c DU25 - Sub Area S. Donovan Street (Colson) DU 23 - Sub Area DU 23 - Sub Area d DU 23 - Sub Area * 29.7 J DU 23 - Sub Area Dallas Avenue S. (Security National Mortgage) DU01 - Sub Area DU01 - Sub Area c DU01 - Sub Area S. Cloverdale Street Planting Strip, North (City of Seattle) PS North A - Sub Area A PS North A - Sub Area B PS North A - Sub Area C J PS North A - Sub Area D1 1.0 PS North A - Sub Area E PS North B - Sub Area A PS North B - Sub Area B * J PS North B - Sub Area C PS North C - Sub Area A PS North C - Sub Area B J PS North C - Sub Area C S. Cloverdale Street Planting Strip, South (City of Seattle) PS South A J PS South B J PS South C J Integral Consulting Inc. Page 1 of 2

62 Table 3-3. Excavation Depths, Elevations, and Residual Concentrations Affected Property, Ownership, and Decision Unit Minimum Removal Depth (ft bgs) a Lowest DU Surface Elevation (ft NAVD88) Removal Elevation (ft NAVD88) Residual Analytical Data b Total PCB Aroclors (mg/kg dry wt) Dioxins/Furans (ng/kg TEQ) Southern Alleyway (City of Seattle) 14a 0.24 * 15 J 14b J 1.3 J 14c 0.19 e 10 J e 15a f 0.20 e 3.1 J 15b f e 1.6 J e 15c f e 1.9 J e 16a J 16b J 1.1 J 16c J 1.4 J 17a g U b g J 0.84 J 21a h 9.4 J b J 1.7 J Notes: -- = data not analyzed * = reported result is an average of the sample result and the laboratory duplicate result J = estimated concentration U = analyte not detected at associated concentration a Minimum removal depth defined by pre-design confirmational sampling concentrations below the removal action level of 1.0 mg/kg. Refer to the pre-excavation confimation sampling results for the Residential Yards study area (Appendix G of the removal action design report; Integral 2012). b Analytical data representative of material below excavation or shallowest instance of non-exceedance. c Analytical data representative of material from interval ft bgs (excavated). d 0.5 ft held as minimum excavation depth. Pre-design confirmation sampling indicated non-exceedence below 0.2 ft. e Analytical data representative of material from interval ft bgs (excavated). f Excavation includes area between 14 and 15. g Excavation includes area between 16 and 17. h Analytical data representative of material from interval ft bgs (excavated). Integral Consulting Inc. Page 2 of 2

63 Table 3-4. Lessons Learned Category Issue Suggestions / Response Actions Lines of Communication Organizational structure for construction management and oversight could have been better defined. Ensure that project roles and responsibilities are clearly defined within project documents. Include detailed organizational chart with phone numbers, which clearly indicates communication linkages between management and oversight personnel. Public Communication Noisy equipment impacting residents and businesses. Conduct one-on-one outreach with affected residents and business owners prior to the use of noisy or vibratory equipment (e.g.,vactor trucks); coordinate with businesses to perform work outside of peak business hours. Design and scope of work not adequately conveyed to potentially affected individuals at properties adjacent to the work. Vehicles not moved from work zone area prior to construction. Improve outreach to the surrounding community before the start of remedial activities that affect public spaces. Oneon-one briefings with property owners and tenants adjacent to work areas. Improve outreach to the community beforehand as parking signs alone do not always motivate people to relocate. Construction vehicles impacting parking within the neighborhood. Improve outreach to affected community regarding contractor needs (e.g., need for portable sanitary facilities adjacent to the work area). Work Zone / Traffic Control Exclusion zone demarcation is too porous and decontamination procedures not well defined at initial startup. Engines idling for longer than 2 minutes. Contractor vehicles (esp. subcontractors) impacting parking within the neighborhood. Ensure protocols are in place and well understood prior to land disturbance. Perform dry run training walkthroughs prior to excavation activities. Do not allow land disturbance to proceed until work zone controls and decontamination procedures are approved by QA program manager. Provide better communication to contractor to ensure that site protocols are followed. Require that site protocols be conveyed to all workers and subcontractors performing work or delivering materials to the site. Provide better communication to contractor to ensure that site protocols are followed. Require that site protocols be conveyed to all workers and subcontractors performing work or delivering materials to the site. Integral Consulting Inc. Page 1 of 2

64 Table 3-4. Lessons Learned Category Issue Suggestions / Response Actions Excavation and Soil Handling Establishment of target elevations within excavation/decision units results in areas where a significant volume of non-contaminated soil would be removed. During design, subdivide excavation/decision units into smaller parts relative to elevation in order to minimize the removal of non-contaminated soil. Vertical cuts at edges of excavation/decision units are not practical due to soil sloughing or potential undermining of structural elements and/or underground utilities. Clarify in the design documents that the design is based on minimum removal to a 45-degree (1-foot horizontal:1- foot vertical) slope, but steeper cuts may be made where soil conditions allow, based on field observation. Unclear if loads need to be lined and/or covered based on level of contamination within the soil being removed. Clarify in the design documents that all dangerous waste and/or TSCA waste must be shipped in sealed containers. Clarify that contaminated materials not designated as dangerous waste or TSCA waste will be covered unless there is at least 12 inches of freeboard, in accordance with City policy and state law. Further, clarify that decontamination of equipment used in transport is required prior to hauling any non-contaminated materials. Restoration After installation, members of the public are not satisfied with the specified materials and/or finished conditions (e.g., soil composition, tree locations, plant selection). Notes: TSCA = Toxic Substances Control Act Improve outreach to the surrounding neighborhood during planning of restoration design and before the start of restoration activities. Conduct outreach to the broader community regarding designs that affect public spaces. Integral Consulting Inc. Page 2 of 2

65 SELECTED PHOTOGRAPHS

66 Photo 2-1. Clearing at 1410 S. Cloverdale Street (December 4, 2012) Photo 2-2. Site Controls at 1410 S. Cloverdale Street (January 2, 2013) Integral Consulting Inc. 1

67 Photo 2-3. Excavation at 1440 S. Cloverdale Street (top: January 8, 2013; bottom: January 10, 2013) Integral Consulting Inc. 2

68 Photo 2-4. Vactor Excavation at 1445 S. Cloverdale Street, Backyard (February 8, 2013) Photo 2-5. Utility Protection at 1425 S. Cloverdale Street (January 18, 2013) Integral Consulting Inc. 3

69 Photo 2-6. Survey Confirmation at 1418 S. Donovan Street (February 14, 2013) Photo 2-7. Backfill at S. Cloverdale Street Planting Strips (January 25, 2013) Integral Consulting Inc. 4

70 Photo 2-8. Compaction at Southern Alleyway (February 5, 2013) Photo 2-9. Placed Concrete at 1440 S. Cloverdale Street (January 21, 2013) Integral Consulting Inc. 5

71 Photo New Fence at 1445 S. Cloverdale Street, Backyard (February 19, 2013) Photo Sod Installation at 1425 S. Cloverdale Street (January 30, 2013) Integral Consulting Inc. 6

72 Photo Planting Beds at 1430 S. Donovan Street (March 18, 2013) Integral Consulting Inc. 7

73 Photo S. Cloverdale Street, Before and After (top: December 4, 2012; bottom: March 8, 2013) Integral Consulting Inc. 8

74 Photo S. Cloverdale Street, Before and After (top: January 28, 2013; bottom: March 22, 2013) Integral Consulting Inc. 9

75 Photo S. Cloverdale Street, Before and After (top: January 15, 2013; bottom: March 5, 2013) Integral Consulting Inc. 10

76 Photo S. Cloverdale Street, Before and After (top: January 4, 2013; bottom: March 4, 2013) Integral Consulting Inc. 11

77 Photo S. Cloverdale Street, Front Yard, Before and After (top: January 14, 2013; bottom: January 30, 2013) Integral Consulting Inc. 12

78 Photo S. Cloverdale Street, Back Yard, Before and After (top: January 23, 2013; bottom: March 14, 2013) Integral Consulting Inc. 13

79 Photo S. Donovan Street, Before and After (top: February 11, 2013; bottom: March 8, 2013) Integral Consulting Inc. 14

80 Photo S. Donovan Street, Before and After (top: January 2, 2013; bottom: March 18, 2013) Integral Consulting Inc. 15

81 Photo Dallas Avenue S., Before and After (top: February 19, 2013; bottom: March 14, 2013) Integral Consulting Inc. 16

82 Photo S. Cloverdale Street Planting Strips, Before and After (top: January 2, 2013; bottom: March 5, 2013) Integral Consulting Inc. 17

83 Photo Southern Alleyway, Before and After (top: January 31, 2013; bottom: February 4, 2013) Integral Consulting Inc. 18

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