Template revised January 10, 2019.
COMMISSION
AGENDA MEMORANDUM
Item No.
8c
ACTION ITEM
Date of Meeting
September 22, 2026
DATE : August 17, 2026
TO: Stephen P. Metruck, Executive Director
FROM: Sarah Ogier, Director-Maritime Environment & Sustainability
Joanna Florer, Sr.Manager, Env. Programs, Maritime Environment & Sustainability
Joy Dunay, Sr.Env.Program Manager, Maritime Environment & Sustainability
SUBJECT: Terminal 25 South Removal Design/ Removal Action Order
Amount of this request:
$0
Total estimated project cost:
$132,000,000
ACTION REQUESTED
Request Commission authorization for the Executive Director to (1) sign and execute an
Administrative Settlement Agreement and Order on Consent (ASAOC) with EPA requiring
removal design and removal action at Terminal 25 South (T-25S).
EXECUTIVE SUMMARY
Soil and sediments at T-25S contain contaminants that include polychlorinated biphenyls (PCBs),
arsenic, dioxins/furans and polycyclic aromatic hydrocarbons (PAHs) that pose risk to human
health and the environment and need to be addressed.
After completion of a comprehensive environmental investigation and development of cleanup
alternatives, the Port has reached agreement with the U.S. Environmental Protection Agency
(EPA) to conduct the removal design and removal action for the cleanup of contaminated soil and
sediments at the site. Current spending for this work was included in the 2026 Environmental
Remediation Liability (ERL) Program authorization, which is funded through the Environmental
Liability Fund (ELF) via the tax levy. Additional Funding authorization will be proposed in
subsequent annual ERL authorizations. The $132 million cleanup cost is already identified in the
Port’s 5-year and long-term ERL plans.
COMMISSION AGENDA – Action Item No. 8c Page 2 of 5
Meeting Date: September 22, 2026
Template revised June 27, 2019 (Diversity in Contracting).
BACKGROUND
Terminal 25 is located along the East Waterway. The northern two thirds of the property is an
active cargo facility, whereas the southern third of the property, known as T-25S, is an
underutilized parcel that has primarily been used in recent years for bulk material storage,
viaduct demolition material storage, and drayage parking. The eastern half of T-25S is licensed to
the Northwest Seaport Alliance (NWSA), and the western half of the site, managed by the Port
of Seattle (Port), has been identified as a future habitat restoration site.
The Port discovered a PCB hotspot at the T-25S site in 2020. An environmental investigation was
performed with EPA’s oversight, to refine the nature and extent of contamination and ensure
that the proposed habitat restoration meets EPA cleanup requirements for the East Waterway
Superfund site. This investigation was completed with the submittal of the final Engineering
Evaluation and Cost Analysis (EE/CA) on June 26, 2026. The cleanup alternative and cost
estimates were presented in the EE/CA. EPA selected and memorialized their preferred
alternative in their Action Memorandum issued June 24, 2026. The next phase of the cleanup
process is to perform the removal design and a removal action, which is the subject of this
Commission authorization request.
Although funding is not included for this request, the cost to complete the removal design and
removal action is currently estimated to be $132 million. Current year funding for this work was
included in the 2026 Environmental Remediation Liability (ERL) Program authorization, which is
funded through the Environmental Liability Fund (ELF) via the tax levy. Additional Funding
authorization will be proposed in subsequent annual ERL authorizations. The $132 million is
already identified in the Port’s 5-year and long-term ERL plans.
JUSTIFICATION
The Administrative Settlement Agreement and Order on Consent (ASAOC or “EPA Order”) is a
binding agreement to perform work by the Port; therefore, the signing of the EPA Order requires
Commission authorization. The project will formally initiate the process of removal design and
removal action for T25S, as necessary and required, to meet EPA’s cleanup objectives in its Action
Memorandum. By cleaning up the site, the Port advances the long-term protection of human
health and the environment, reduces our environmental liability, and enables the advancement
of future habitat restoration at the site.
Diversity in Contracting
The removal design effort will utilize consultant services via existing environmental IDIQ
contracts developed to serve design and permitting efforts such as those required by this
program. The Maritime Environmental Site Management IDIQ contract and Maritime
COMMISSION AGENDA – Action Item No. 8c Page 3 of 5
Meeting Date: September 22, 2026
Template revised June 27, 2019 (Diversity in Contracting).
Environmental Review Permitting and Sustainability IDIQ contract have WMBE goals of 15% and
23%, respectively.
The removal action effort will utilize a General Contractor/Construction Manager (GC/CM)
contract that is currently out for solicitation. The WMBE aspirational goal for the GC/CM contract
is 10%.
DETAILS
The Statement of Work detailed in the EPA Order requires that the Port perform the work
necessary to complete Removal Design and Removal Action.
Scope of Work
The design scope to be performed under this authorization will include:
• Coordination with EPA, Trustees, NWSA and other stakeholders
• Environmental, land use review and permitting
• Construction permitting
• Preparation of cleanup in conjunction with habitat construction documents
• Preparation of construction cost estimates
The proposed site improvements planned to be performed as a result of the project’s design
efforts consist of:
• Dredging and disposal of contaminated in-water sediment
• Removal and disposal of existing in-water/shoreline creosote treated timber piles and
marine structural remnants
• Excavation and disposal of upland contaminated soils
Schedule
Activity Estimated Schedule
Commission Authorization of Order
Removal Design
Removal Action
Cost Breakdown
This Request
Total Project
Design
$4,000,000
$4,000,000
Construction
$128,000,000
$128,000,000
Total
$132,000,000
$132,000,000
COMMISSION AGENDA – Action Item No. 8c Page 4 of 5
Meeting Date: September 22, 2026
Template revised June 27, 2019 (Diversity in Contracting).
ALTERNATIVES AND IMPLICATIONS CONSIDERED
Alternative 1 – Do Not Authorize Signature of the Order
Cost Implications: Not signing the Order may result in the issuance of an enforcement order by
EPA, or EPA may elect to perform this work itself. This would result in EPA recovering the cost of
the work from the Port, increasing the Port’s estimated costs by 1.5 to 3 times.
Pros:
(1) May delay the Port’s spending by a year or more while EPA prepares the enforcement
order.
Cons:
(1) Increased legal and staff time and efforts and costs to respond to an enforcement order
and provide ancillary support to the EPA to carry out the enforcement order (gain access
to the site, etc.)
(2) The ultimate costs of the work will be much higher if EPA elects to perform the work
itself.
(3) Not performing this work could tarnish the Port’s reputation with EPA and the
community as having a commitment to public health and being a steward of community
resources and the environment.
This is not the recommended alternative.
Alternative 2 – Authorize Signature of the Order and begin the required Statement of Work
Cost Implications: $132,000,000
Pros:
(1) Avoids potential delays and higher costs associated with an enforcement order (as an
alternative to an agreed order) and furthers the Port’s collaborative working
relationship with EPA.
(2) Takes the next step leading to T25S cleanup and long-term protection of human health
and the environment.
(3) Demonstrates the Port’s value of being responsible stewards of community resources
and the environment.
(4) Allows for habitat restoration.
Cons:
(1) None, but will cost approximately $132,000,000 to complete the Order’s Statement of
Work.
This is the recommended alternative.
FINANCIAL IMPLICATIONS
There is no funding request as part of this authorization. Current year funding for the associated
scope of work is included in the annual ERL authorization. Total project costs are anticipated in
the ERL 5-year and long-term financial plans.
COMMISSION AGENDA – Action Item No. 8c Page 5 of 5
Meeting Date: September 22, 2026
Template revised June 27, 2019 (Diversity in Contracting).
Annual Budget Status and Source of Funds
The current year project cost is included in the Annual ERL Authorization. Future year funding
will be subject to annual ERL authorizations. The funds for this work come from the ELF via the
tax levy.
Financial Analysis and Summary
Project cost for analysis
$132,000,000
Business Unit (BU)
Maritime Environmental Services
Effect on business performance
(NOI after depreciation)
N/A
IRR/NPV (if relevant)
N/A
CPE Impact
N/A
Future Revenues and Expenses (Total cost of ownership)
The Port will pursue cost recovery options (e.g., grants, insurance or payments from other 3rd
parties) to help support this work.
Future expenses may include long-term monitoring requirements to ensure that the clean-up
remedy is performing as expected.
ATTACHMENTS TO THIS REQUEST
(1) Administrative Settlement Agreement and Order on Consent for Removal Design and
Removal Action (Terminal 25 South, East Waterway Operable Unit, Harbor Island
Superfund Site, Seattle, WA)
(2) PowerPoint
PREVIOUS COMMISSION ACTIONS OR BRIEFINGS
November 11, 2025 – Consent Item 8g. The Commission authorized the Environmental
Remediation Liability (ERL) Programs fund for 2026 and approved a five-year spending
plan for 2026 – 2031
February 8, 2022 - T25 South Restoration program EPA Order approval and Cleanup (106176)
and Habitat (105562) ERL projects design authorization. The Commission authorized the
Executive Director to (1) execute an Administrative Settlement Agreement and Order on
Consent (ASAOC) with the U.S. Environmental Protection Agency (EPA); and (2) authorize
completion of design and permitting for the Terminal 25 South Restoration Program
Cleanup (106176) and Habitat Restoration (105562) projects