From: The Edmonds Marsh Estuary Advocates

Subject: The Final Cleanup Action Plan for the Edmonds Unocal Site

1/18/24

 EMEA Input to Ecology on the Unocal Cleanup

The Edmonds Marsh Estuary Advocates (EMEA) recommends that the remaining contaminated soils on the Unocal cleanup site be completely removed from the Edmonds Marsh, a sensitive and important Puget Sound shoreline area. Our opinion is that the proposed environmental covenants do not present an adequate or long-term cleanup solution and should not be attached to the site as a final cleanup action.

 The EMEA appreciates that Ecology has listened to Edmonds citizens regarding the future use of the site. The much more restrictive cleanup levels proposed will protect not only humans, fish, and wildlife, but also biota that are in continual contact with the soil. 

 We also appreciate the level of effort that has gone into the cleanup to date. The mass excavation and replacement of contaminated soils has left the site 95% clean. What remains are four relatively small, but important, areas of soil contamination.

 The contaminated soils surrounding the SR104 storm drain pipe are in one of the four areas. Remedial Alternative 6 (Feasibility Study), which included the implementation of a Dual Phase Extraction (DPE) system, was selected in the interim cleanup plan as the preferred alternative to address soil contamination at the storm drain pipe. The DPE system has not performed as proposed and has failed to meet cleanup standards. Because of that failure, remedial Alternative 4 (i.e. excavation of remaining contaminated soil) should be the selected cleanup method in the final cleanup plan going forward. Alternative 4 includes the removal of storm drains, excavation of contaminated soils, and replacement of storm drains.

 We join the Washington Department of Transportation and many other local Edmonds citizens in urging Ecology to complete restoration of the Unocal site without the use of environmental covenants. In other words, our desire is the complete removal of all remaining contamination from the Unocal site.

 The end is in sight. We are close to reaching the next objective, which is to plan for restoration of this once polluted industrial site into an important local and regional natural attraction for both wildlife and humans.

Sincerely,

The Edmonds Marsh Estuary Advocates