Seattle City Light 2016 ANNUAL REPORT | Audited Financial Statements 63 THE CITY OF SEATTLE—CITY LIGHT DEPARTMENT NOTES TO FINANCIAL STATEMENTS AS OF AND FOR THE YEARS ENDED DECEMBER 31, 2016 AND 2015 - 63 - manager has estimated that total remediation liability may be up to $300.0M, of which $100.0 million is the City share. The Department recorded its share of the estimated liability of $45.0 million in October, 2016 in accordance with GASB Statement No. 49. The Department’s ultimate liability is indeterminate. ● The Lower Duwamish Waterway Superfund Site—In 2001, the EPA designated this site as a federal Superfund site for contaminated sediments. The Department’s involvement is attributable to its land ownership or use of property along the river. The City of Seattle is one of four parties who signed an Administrative Order on Consent (AOC) with the EPA and Washington State Department of Ecology (DOE) to conduct a remedial investigation and feasibility study to prepare a site remedy. The EPA approved the feasibility study in November 2012. In February 2013, the EPA issued the Proposed Plan for cleanup of the Lower Duwamish Waterway. In December 2014, the EPA issued its final Record of Decision (ROD) indicating its preferred alternative clean-up with an estimated cost of $342.0 million. The extent and cost of additional investigation work required prior to implementation of remedy is still unknown. The Department’s ultimate liability is indeterminate. In November 2012, the EPA issued general notification letters to parties informing them of their potential liability for the Lower Duwamish Waterway cleanup. The City and other three parties who signed the AOC with the EPA agreed to invite some of those parties to participate in an alternative dispute resolution process (the “allocation process”) to resolve their respective shares of past and future costs. There are 44 parties are participating in allocation. The City hired an allocator and the allocation process officially began in April 2014. The Department agreed to administer the allocator’s contract, estimated to cost about $4.0 million over a four-year period. Parties participating in the allocation process will share the cost of the allocator and the process. The City is also responsible for investigation and cleanup at the Port of Seattle Terminal 117 Streets, Uplands and Sediments sites. The South Park street is not owned by the Department but the City has jurisdiction over the streets and right-of-ways. Remediation activities for streets was completed in August 2016. The City’s share for the uplands and sediments site is paid 100% by the Department. The City’s share for the adjacent streets is split between the Department and SPU according to a Memorandum of Agreement (MOA) signed in August 2014. According to this MOA, SPU will pay 2.5% for some portions of the construction and up to 100% for other parts of the cleanup and restoration. The cleanup of the sediments and the upland is complete. ● South Park Marina—The Washington Department of Ecology has notified the City that it is a Potentially Liable Party for contamination at South Park Marina, which is adjacent to Terminal 117. The Department is the lead for the City at this site. Negotiations with the property owner and with Washington State Department of Ecology is underway. The Department’s ultimate liability is indeterminate. ● North Boeing Field/Georgetown Steam Plant—The City, King County, and Boeing signed an Administrative Order issued by the Washington State Department of Ecology (Ecology) requiring them to investigate and possibly remove contamination in an area that encompasses North Boeing Field, the Department’s Georgetown Steam Plant, and the King County Airport. This site was also the subject of the lawsuit brought by the City against Boeing. Boeing agreed to pay 67% of the costs for Ecology’s implementation of the current order. The order requires completion and then implementation of a remedial investigation and feasibility. The final remedial investigation work plan was issued in November 2013. In January 2015, all parties executed the First Amendment to the North Boeing Field/Georgetown Steam Plant Agreed Order, making all parties responsible for conducting