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1. Introduction
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1.1 Background
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Site Number: |
10JA |
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Contract Number: |
EP-S7-06-02 |
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D.O. Number: |
N/A |
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Action Memo Date: |
9/30/2010 |
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Response Authority: |
CERCLA |
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Response Type: |
PRP Oversight |
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Response Lead: |
PRP |
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Incident Category: |
Removal Action |
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NPL Status: |
Non NPL |
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Operable Unit: |
N/A |
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Mobilization Date: |
1/24/2011 |
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Start Date: |
2/2/2011 |
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Demob Date: |
3/31/2011 |
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Completion Date: |
3/31/2011 |
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CERCLIS ID: |
WAN0002329803 |
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RCRIS ID: |
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ERNS No.: |
N/A |
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State Notification: |
N/A |
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FPN#: |
N/A |
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Reimbursable Account #: |
N/A |
1.1.1 Incident Category
Time critical removal action.
1.1.2 Site Description
The Jorgensen Forge Outfall Site consists of two outfall pipes, a 24-inch and adjacent 15-inch, buried just south of the current Jorgensen Forge facility’s northern boundary with the adjacent Boeing Plant 2 facility. Both pipes discharged into the Lower Duwamish Watershed (LDW). The LDW was listed on the National Priority List (“NPL”) in September 2001 (CERCLIS No. WA0002329803). In 2002, the Washington Department of Ecology (“Ecology”) added the LDW to the Hazardous Site List under Facility Site identification No. 42927743.
1.1.2.1 Location
The Site is located along the northern boundary of the adjacent Jorgensen and Plant 2 facilities. The street address is 8531 East Marginal Way South, Seattle, Washington, 98108. The approximate location of the east end of the 24-inch PLSD is 47° 31’37.82” North Latitude; 122° 18’13.59” West Longitude.
The Site and surrounding area are primarily industrial. The nearest school (Concord Elementary) is approximately 0.75 miles west-southwest. The closest residences are within a mile are to the west in the South Park neighborhood across the LDW.
1.1.2.2 Description of Threat
Numerous environmental investigations have documented the presence of PCBs in the PLSD pipes which discharge to the LDW. Total PCBs have been detected at concentrations as high as 10,000 mg/kg in a sample collected from the 24-inch PLSD. Multiple samples exceed both the MTCA cleanup level for industrial soil (10 mg/kg) and EPA Regional Screening Levels for industrial soil and the protection of groundwater (0.74 and 0.0088 mg/kg, respectively, for Aroclor 1254).
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
(See Proposed Modifications figure 3A for detailed locations. Can be found in document section of website)
02/11/2011:
Continue the cleaning and video inspections of the 24" Line between Public Manhole SDMH 11 and Manhole SDMH 24B. This included the cleaning and inspection of a 15-inch lateral out of SDMH 37-7 the extended to the northeast and terminated in a manhole on the adjacent propery. The 15-inch lateral had been previously sealed at that manhole.
02/14/2011:
Manholes SDMH 11, SDMH 37-2, SDMH 37-7, and SDMH 24B of the storm drain were sealed with controlled density file (CDF). This sealed(closed) the 24-inch clay pipe attached to these manholes as well as a 15-inch lateral that extended from SDMH 37-7 northeast to a manhole on adjacent property.
The vac truck excavated down to a 4” ductile iron pipe lateral that extended off the crown of the 24-inch pipe under the Jorgensen Forge visitors parking lot. From the 24-inch pipe the 4-inch iron pipe extended up vertical and terminated about 18- inches under the pavement of the visitor parking area at Jorgensen Forge. The 4-inch pipe had been broken off and was open. A video camera inspected of the 4-inch iron pipe down to the 24-inch clay pipe confirmed that the pipe was clear and could be sealed. The excavation was back filled with CDF. The 4-inch piped will be sealed and the parking lot will be restored.
02/16-02/17/2011:
EPA provided written approval of the cleaning of the 24-inch line between public manhole SDMH 11 and manhole SDMH 24B.
Work continued with the cleaning and the removal of water from the 24-inch clay pipe between manholes SDMH 24A and SDMH 24B. The focus was on a 9 foot, 12-inch lateral just upstream of manhole SDMH 24A. The lateral presented with a piece of wood in it. The jet water cleaning was successful in removing the wood and cleaning the lateral to where is had been terminated and sealed.
The section of 24-inch pipe from SDMH 24A to the 12-inch PVC riser at the west terminal which was the transitional area between the clay pipe and the CMP, was cleaned and video inspected. The video inspection confirmed that the section was clean.
02/18/2011:
Additional cleaning and video inspection of the 15" line (onsite determined that it is a 12-inch pipe) between manhole 15B and western transition point where the 12-inch PVC riser was place, where completed. EPA approved the cleaning of the 15" line between Manhole 15B and Transition so that it can be sealed.
02/22/2011:
EPA approved of the cleaning of the 24" line between manhole 24B and western transition point of the storm water line.
02/28/2011:
Manholes 24A, 15B, and 15A were sealed with CDF. The two, 12-inch PVC risers at the transitional area of the 24-inch and 12-inch clay pipes and CMP, that were used for temporary clean outs, were cut down to below grade. They were plugged with inflatable marine buoys and sealed with quick set Cement All. The PVC caps were put back on the risers.
Sampling and sealing of the 4" visitor's parking lot iron lateral was completed after it was cleaned.
EPA approved of completion of all pipe cleaning and sealing.
2.1.2 Response Actions to Date
None
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
None to date.
2.1.4 Progress Metrics
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Medium |
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Manifest # |
Treatment |
Disposal |
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2.2 Planning Section
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2.2.1 Anticipated Activities
See Operations section
2.2.1.1 Planned Response Activities
None
2.2.1.2 Next Steps
• Decontamination of equipment
• Dewatering of solids
• Offsite shipment of solids to authorized disposal facility
• Application for discharge permit for wash waters
• Disposal of wash waters
• Demobilization
• Report preparation
2.2.2 Issues
None
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2.3 Logistics Section
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02/01/2011
Orange construction fencing was erected to delineate the work area for the CMP/concrete transition area. The fence would also assist in separating the facility work yard area from the removal and excavation work areas.
02/14/2011
Two additional Baker Tank trailers were brought onsite to help manage the water storage from the cleaning of the pipes. This also allowed the water to be re-cycled for use in cleaning the pipes after it had been filtered through the de-watering system.
A third roll off box was brought on-site, in anticipation of additional solid waste collection.
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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2.5.1 Safety Officer Background:
All consultants, contractors, and sub-contractor personnel coming onto the facility attended a video heath and safety presentation and completed a safety checklist. This was done to ensure that everyone was familiar with the health and safety requirements of the facility while working on the property.
Additional morning safety briefings were conducted each day to address the specific hazards and procedures for the work to be completed that day. topic addressed:
- Jorgensen Forge Yard Traffic
- Hearing protection around the vac truck operations
- PPE at open manholes during cleaning operations will be Tyvek, APR, eye and hearing protection
- Weather extremes
- Emergency response, command and control. PR's consultant field manager will be the nitial IC
until Jorgensen Forge personnel arrive on the scene.
2.6 Liaison Officer N/A
2.7 Information Officer 2.7.1 Public Information Officer
N/A
2.7.2 Community Involvement Coordinator
N/A
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3. Participating Entities
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3.1 Unified Command None
3.2 Cooperating Agencies WDOE
City of Tukwila
King County Airport
EPA RCRA
EPA Remedial Program
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4. Personnel On Site
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The number of personnel varied onsite based on the work load. This accounting is the maximum that would be onsite at any one time during a normal work day.
Facility Environmental Consultant - 1
RP Environmental Consultant - 1
START - 1
RP Environmental Contractor - 3
RP Cleanup Subcontractor - 3
EPA - 1
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5. Definition of Terms
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CMP: Corrugated Metal Pipe
CDF: Controlled Density Fill
IC: Incident Commander
JF: Jorgensen Forge
RP: Responsible Party
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6. Additional sources of information
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6.1 Internet location of additional information/report
6.2 Reporting Schedule
Completion of storm pipe cleaning (Feb 21-22th)
Sealing of remaining manholes (Feb 23-24th)
Dewatering of Soil Bins (Week of March 7th)
Wash water permitting, treatment, discharge and/or disposal (Week of March 21st)
Transport of soil bins to TSD (Week of March 21st)
Demobilization (Week of March 28th)
Transmittal of completion report (60 days following completion of field demobilization)(May 30th)
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7. Situational Reference Materials
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No information available at this time.
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