Template revised January 10, 2019.
COMMISSION
AGENDA MEMORANDUM
Item No.
8c
ACTION ITEM
Date of Meeting
October 25, 2022
DATE : September 7, 2022
TO: Stephen P. Metruck, Executive Director
FROM: Megan King, Interim Senior Manager, Aviation Environment & Sustainability
Sarah Cox, Director Aviation Environment & Sustainability
SUBJECT: Former United Continental Tank Farm Site Funding and Agreement Amendment for
Site Closure
Amount of this request:
$78,505 (included in ERL Forecast)
Total estimated Port cost to date:
$639,576
ACTION REQUESTED
Request Commission authorization for the Executive Director to execute a Sixth Amendment to
the Participation Agreement (Amendment) for Cleanup of Sea-Tac International Airport Jet Fuel
Facility executed in November 1995 between the Port, United Airlines, Continental Airlines, and
Olympic Pipeline Company (Participants).
EXECUTIVE SUMMARY
The Former United/Continental Fuel Farm Site (Site) is located south of the Fire Station on Air
Cargo Road near gate E-100. Subsurface jet fuel contamination was encountered at the Site
during closure of the tank farms in the 1990s. Following identification of contamination, the
parties (United as the lead responsible party, Continental which is now also United, Olympic
Pipeline, and the Port) entered into a Participation Agreement for investigation and remediation
of the Site.
Remedial activities at the Site are complete, and the parties agree that independent closure, as
allowed by the Model Toxics Control Act, is the best path forward.
This Participation Agreement Amendment adds funds to the project escrow account to cover
costs of system decommissioning, and long-term responsibility language for contamination
remaining in place at the Site. Work will consist of removal of the remaining treatment system
infrastructure including all subsurface piping and monitoring wells and restoration of the Site.
The Port’s 21% share of remedial costs (share percentages were determined in the original
Participation Agreement) for this Amendment will be $78,505. No ongoing monitoring or actions
are anticipated following completion of Site closure activities.
COMMISSION AGENDA – Action Item No. 8c Page 2 of 4
Meeting Date: October 25, 2022
Template revised June 27, 2019 (Diversity in Contracting).
JUSTIFICATION
Remediation of the Site has removed all recoverable product, and groundwater impacts have
reduced in concentration and extent. The Participation Agreement requires decommissioning
and removal of the remediation equipment once it is no longer necessary. Additional funding is
now required in the project escrow account for system decommissioning and removal, which
requires modification to the existing Participation Agreement to cover this issue and address
future responsibility for any contamination remaining in place following Site closure.
Diversity in Contracting
Not applicable to this request.
DETAILS
Investigation and remediation at the Site has been in progress since 1995 and consisted of active
in-situ remediation by dual-phase and soil vapor extraction processes. The remediation
successfully removed recoverable product from the subsurface, and in 2017 the remediation
system was shutdown. After some monitoring was conducted, the Site was enrolled in Ecology’s
Voluntary Cleanup Program and a No Further Action opinion was requested from the Department
of Ecology in March 2019. In 2021, additional data were collected. These data confirmed that the
product remaining in the subsurface is not transmissive (doesn’t move) and therefore cannot be
recovered, and the groundwater data confirmed that the concentrations and extent of
contamination remaining in groundwater beneath the site are decreasing due to natural
attenuation.
Ecology has communicated that it does not need the Participants to undertake further action at
the Site. Accordingly, in early August, the Participants submitted a letter to Ecology formally
removing the Site from Ecology’s Voluntary Cleanup Program. The letter notifies Ecology that Site
cleanup has been conducted as an Independent Cleanup Action, as allowed by the Washington
state Model Toxics Control Act. This letter also describes how the Port will implement
Institutional Controls at the property for future protection of human health and the environment
that consist of:
• maintaining the Site as zoned for Airport Operational uses
• restricting access to the area through maintenance of the existing facility fencing and
signage
• controlling future contact with remaining contamination during actions that disturb the
subsurface through implementation of the Port’s Rules for Airport Construction, and
• restricting groundwater extraction at the Site.
Scope of Work
Site Closure Activities funded by Amendment 6 will consist of:
(1) Removal of remediation system and supporting infrastructure
COMMISSION AGENDA – Action Item No. 8c Page 3 of 4
Meeting Date: October 25, 2022
Template revised June 27, 2019 (Diversity in Contracting).
(2) In-place decommissioning of the groundwater monitoring well network
(3) Removal of Tank Farm infrastructure components left in place during decommissioning
due to the presence of contamination (concrete and sheetpile wall segments).
Schedule
On authorization, work will be scheduled as soon as possible, with the goal of completing work
before Summer 2023.
ALTERNATIVES AND IMPLICATIONS CONSIDERED
The following alternatives were considered:
Alternative 1 – Partial removal of remediation system infrastructure by other construction teams
as part of future capital projects in the area of the Site.
Cost Implications: $78,000+ plus additional Port effort for removal, coordination, and cost
recovery
Pros:
(1) Does not require a separate mobilization for removal of the treatment system
infrastructure.
(2) Allows for removal of only system components that conflict with previously approved
future development actions.
Cons:
(1) Places burden of system removal on capital project teams to estimate, track and
conduct.
(2) Capital project contractors may not have specialized skills or equipment to remove the
remediation system infrastructure and introduces unnecessary complexity to capital
development efforts.
(3) Requires separation and cost tracking of remediation system removal by the capital
projects, and cost recovery following completion.
This is not the recommended alternative.
Alternative 2 – Hire specialized contractor to completely remove the remediation system
infrastructure ahead of any capital projects in the vicinity of the Site, in accordance with the
existing participation agreement.
Cost Implications:
Pros:
(1) Completes remediation requirements scoped in the Participation Agreement.
(2) Allows for costs to be split between the remediation parties according to the
established percentages.
(3) Does not require cost recovery following completion.
COMMISSION AGENDA – Action Item No. 8c Page 4 of 4
Meeting Date: October 25, 2022
Template revised June 27, 2019 (Diversity in Contracting).
Cons:
(1) No limitations identified for this alternative.
This is the recommended alternative.
FINANCIAL IMPLICATIONS
Annual Budget Status and Source of Funds
This work will be funded by a project escrow account setup by the Participants. The Port’s share
of costs will be deposited to the escrow account from ERL funds. No additional costs are
anticipated for this Site.
ATTACHMENTS TO THIS REQUEST
(1) Presentation slides
(2) Draft Sixth Amendment
PREVIOUS COMMISSION ACTIONS OR BRIEFINGS
July 2014 – The Commission authorized execution of the Fifth Amendment to the
Participation Agreement
2013 – The Commission authorized execution of the First Addendum to the Fourth
Amendment to the Participation Agreement
March 2009 – The Commission authorized execution of the Fourth Amendment to the
Participation Agreement
August 2001 – The Commission authorized execution of the Third Amendment to the
Participation Agreement
January 1997 – The Commission authorized execution of the Second Amendment to the
Participation Agreement
1996 – The Commission authorized execution of the First Amendment to the Participation
Agreement
1995 – The Commission authorized execution of the Original Participation Agreement
