United States
          Environmental Protection
          Agency
             Office of
             Emergency and
             Remedial Response
EPA/ROD/R10-89/020
September 1989
&EPA
Superfund
Record of Decision
           Commencement Bay Nearshore/

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50272.101
REPORT DOCUMENT A TJON 1'0 REPORT NO. 12.
PAGE 'I EPA/ROD/R10-89/020
3. Reclplentl AccHeIon No.
4. TItle IIIId Subtitle
'UPERFUND RECORD OF DECISION
bmmencement Bay Nearshore/Tideflats, WA
Second Remedial Action
. 7. Au1hor(l)
5. Report D8ta
09/30/89
I.
a. P8rlonnlng OrIl8nlzatlon Rept. No.
8. Pwfonning Orll8lnlzatlon N8m8 IIIId Addr8M
,0. Proj8c:tlTulllWork Unit No.
11. Contrect(e) or Gr8n1(G) No.
(e)
-'

,2. ~oring OrIl8nlutlon N8m81111d AdIhu
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
(G)
,3. Type of Report . Period Covend
Agency
800/000
,4.
,5. Supplemen1ary No...
,I. Abetrlct (Umlt: 200 _rdl)
The Commencement Bay Nearshore/Tideflats site is in Tacoma, Pierce County, Washington at
the southern end of the main basin of puget Sound. The site encompasses an active
commercial seaport and includes 10-12 square miles of shallow water, shoreline, waterways
and adjacent land. Site contamination is the result of a long history of industrial
a~~ivity in the area. More than 281 active industrial facilities are in the area and
'oximately 34 of those are NPDES permitted dischargers. Releases of hazardous
w~stances to the marine environment have resulted in contamination of bottom sediment in
the waterways of the Tideflats Industrial Area, and along the shoreline in the Nearshore
Area. This Record of Decision represents two of six operable units for the site and will
address source control and marine sediment contamination in the Nearshore/Tideflats
environment. Eight problem areas are being addressed independently by this remedy. The
remaining operable units will address remedial response to releases of hazardous
substances associated with the Tacoma tar pits and the ASARCO Tacoma smelter. The
primary contaminants of concern affecting the sediment are organics including PCBs and
PAHs; and metals including arsenic, mercury, lead, and zinc.
The selected remedial action for this site includes an 8-year active cleanup phase for
source control and sediment remediation, and a 10-year natural recovery phase. Source
. :::ar ~ nn ~ n,.. 1 "lio.. rhp ~ lionr ~ . ::Inr! /"'nnr Tnl n11Pr! on npvt- ,.,::1,.,.0 \
'7. Oocum8nt An8/y8I8 L D88crtpCar8
Record of Decision - Commencement
Second Remedial Action
Contaminated Medium: sediment
Key Contaminants: Qrganics (PCBs,
Bay Nearshore/Tideflats, WA
PAHs), metals (arsenic, lead)
b. IdentlIl8n/Open-End8d Tenne
COSA11~
~ ........
,I. 98cutty CIM8 (11118 ~
None
20. 98cutty CIM8 (11118 P8ge)
NonA
21. No. of PIIIM
245
22. PrioI
SI8 A~Z3I.lI
S.~_on~-
(4-77)
(FOI'IMdy HT1~)

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OPTIONAL FORM 272 BACK

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EPA/ROD/R10-89/020
Commencement Bay Nearshore/Tideflats, WA
Abstract (Continued)
sources of contamination into the marine environment at the site. Sediment
remediation includes a combination of natural recovery for areas expected to recover
naturally within a 10-year period after source control measures are implemented, and the
utilization, as appropriate, of four active sediment control alternatives to remediate
approximately 1,181,000 cubic yards of contaminated sediment. The four sediment
confinement options include in situ capping, (placement of clean material on top of
. existing substrate), confined aquatic disposal (removal of contaminated sediments with
confined. disposal in shallow or open-water aquatic environments using capping with clean
, dredged material), confined nearshore disposal (removal and confined disposal in the
. nearshore environment with capping and diking), and removal and upland disposal
(transferring dredged material to a land-based confinement facility. In addition, the
remedy will implement site use restrictions, and source and sediment monitoring. The
estimated total cost for sediment remediation at the site is $32,300,000, which includes
O&M costs for 10 years. Costs associated with source control activities are not included
in this ROD because of the difficulty in determining what proportion of total

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u.s. Environmental Protection Agency
Region 10
Seattle, Washington
. .'.

Commencement Bay N~arshore jTideflats
RECORD OF DEOSION
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U.S. EnvironmentaJ Protection Agency
Region 10
Seattle, Washington
Commencement Bay NearshorejTideflats
RECORD OF DECISION

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PREFACE
This Record of Decision documents the remedial action plan for contaminated sediments and
associated sources within eight discrete problem areas at the Commencement Bay Nearshore!
Tideflats site. The Record of Decision serves three functions: .
.
It certifies that the remedy selection process was carried out in accordance with
the Comprehensive Environmental Response, Compensation, and Liability Act as
amended by the Superfund Amendment and Reauthorization Act, and to the extent
pr3Cucable, with the National Contingency Plan.

It summarizes the technical parameters of the remedy, specifying the treatment,
engineering, and institutional components, as well as remediation goals.

It provides the public with a consolidated source of information about the site, the
selected remedy, and the rationale behind the selection.
.
.
In addition, the Record of Decision provides the framework for transition into the next phases of
the remedial process, Remedial Design and Remedial Action.
The Record of Decision consists of three basic components: a Declaration, a Decision \
Summary, and a Responsiveness Summary. The Declaration functions as an abstract for the key
information contained in the Record of Decision and is signed by the U.S. Environmental
Protection Agency Regional Administrator. The Decision Summary provides an overview of the
site characteristics, the alternatives evaluated, and an analysis of those options. The Decision
Summary also identifies the selected remedy and explains how the remedy fulfills statutory
requirements. The Responsiveness Summary addresses public comments received on the Proposed
Plan, the Feasibility Study, and other information in the administrative record.
This Record of Decision is organized into three main sections: the Declaration, the Decision
Summary, and Appendices. Appendix A provides hmers of concurrence from the state of
Washington and the Puyallup Tribe of Indians. Appendix B consists of the Responsiveness
Summary, and Appendix C presents implementation schedules for source- and sediment-related
remedial activities in the eight problem areas addressed in this Record of Decision.

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PREFACE
LIST OF FIGURES
LIST OF TABLES
CONTENTS
~.
u
viii
ix
LIST OF ACRONYMS
DECLARATION
x
SITE NAME AND LOCA nON
STATEMENT OF PURPOSE
ASSESSMENT OF THE SITE
DESCRIPTION OF THE REMEDY
DECLARA TION
~
2
DECISION SUMMARY
4
2.
OVER VIEW
SITE LOCATION AND DESCRIPTION
4
1.
2.1
SITE LOCATION
5
5
2.2
2.3
CURRENT LAND USE
ENVIRONMENTAL SETTING
5
:.4
7
PROBLEM DEFINITION
7
2.4.1
2.4.2
~A.J
1.4.4
:.-+.5
.,
~.
Focus on Marine Environment
Relation to Other Environmental Programs and A~tivi[ies
Definition of Cleanup Goats
Probiem Scope
Data Needs in [he Remedial Design ?hase
~
,
J
~o
:0
3.1
SITE HISTORY AND ENFORCEMENT
: 1
SITE HISTORY
., .,
~.-
!l
MAJOR SOURCE CONTROL PROGRAMS
13
3.:.1
3.2.2
3.2.3
3.2.4
3.2..S
3.2.6
Cummencement Bay Urban Bay Action ream
TPCHD Marine Resource Protection Program
City of Tacoma
TPCHD/City of Tacoma Storm Drain Program'
CERCLA Pre-remedial Program
Coordination of Source Control with Other Programs
,b
16
16
17
17
17

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3.3
MAJOR SEDIMENT MANAGEMENT PROGRAMS

ENFORCEMENT ROLES OF EPA, ECOLOGY, AND THE PUYALLUP
TRIBE
3.4
SCHEDULING AND COORDINATION OF SOURCE CONTROL AND
SEDIMENT REMEDIAL ACTION

4. HIGHLIGHTS OF COMMUNITY PARTICIPATION
3.5
5. SCOPE OF RESPONSE ACTION WITHIN OVERALL SITE STRATEGY
5.1
SCOPE AND ROLE OF COMMENCEMENT BAY NEARSHORE/
TIDEFLA TS OPERABLE UNITS
5.1.1
5.1.2
5.1.3
5.1.4
5.1.5
5.1.6
Operable Unit 01 - Commencement Bay Nearshore/Tideflats Sediments
Operable Unit 02 - ASARCO Tacoma Smelter
Operable Unit 03 - Tacoma Tar Pits
Operable Unit 04 - ASARCO Orf-Property
Operable Unit 05 - Commencement Bay Nearshore/Tideflats Sources
Operable Unit 06 - ASARCO Sediments
5.2
COORDINATION OF OPERABLE UNITS 05 (SOURCES) AND
01 (SEDIMENTS)
6. SITE CHARACTERISTICS
6.1 HEAD OF HYLEBOS WATER WAY
6.2 MOUTH OF HYLEBOS W A TERW A Y
6.3 SITCUM WATERWAY
6.4 ST. PAUL WATERWAY
6.5 MIDDLE WATERWAY
6.6 HEAD OF CITY WATERWAY
r,.7 WHEELER-OSGOOD WATERWA Y
., MOUTH OF Clr{ WATER WAY
J,y
~, SUMMARY OF SITE RISKS
-:- ,1
HUMAN HEALTH RISKS
- , .
I.';'. ~
G~nerai Strategy
[dentific:ltion of Chemic:lts of Concern
3aseline R isic.\ssessment
~eiationsi1io to Sediment Quali[y Objectives
7.1.2
. . ..,
- . .
, ....~
tV
P:l2e
17
20
21
22
24
24
25
25
26
26
26
26
\
27
28
30
32
32
35
35
35
,
- '
~o
....,
-...
....,
-...
:,
-"
~3
~3

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7.2
ENVIRONMENTAL RISK ASSESSMENT
7.2.1
7.2.2
7.2.3
7.2.4
7.3
General Strategy
Identification of Problem Chemicals
Identification of Problem Areas
Relationship to Sediment Quality Objectives
MITIGATING FACfORS
7.3.1
7.3.2
Natural Recovery Process
Relationship to Sediment Quality Objectives
8. DESCRIPTION OF AL TERNA TlVES
8.1 SEDIMENT CLEANUP OBJEcrIVES AND EXTENT OF CONT AMINA TION
8.2
KEY ELEMENTS OF CANDIDATE AL TERNA TIVES
8.2.1
8.2.2
8.2.3
8.2.4
8.2.5
8.3
Site Use Restrictions
Source Control
Natural Recovery
Sediment Remedial Action
Monitoring
CANDIDA TE AL TERN A TIVES
8.3.1
8.3.2
8.3.3
8.3.4
8.3.5
8.3.6
8.3.7
8.3.8
8.3.9
8.3.10
8.4
Alternative 1: No-Action
Alternative 2: Institutional Controls
Alternative 3: In Situ Capping
Alternative 4: Removal/Confined Aquatic Disposal
Alternative 5: Removal/Nearshore Disposal
Alternative 6: Removal/Upland Disposal
Alternative 7: Removal/Solidification/Upland Disposal
Alternative 8: Removal/Incineration/Upland Disposal
Alternative 9: Removal/Solvent Extraction/Upland Disposal
Alternative 10: Removal/Land Treatment
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
9. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
9.l
THRESHOLD CRITERIA
9.1.1
9.1.:
9.:
OveraH Protection at Human Hea1th :lnd [he Environment
Compliance with Applicable or Relevant :lnd .-\ppropriate Requirements
9.2.1
?RIMARY 3ALANC!NG CRITERIA
').:.:
).:.:
9.2.4
9.2.5
Long- Term Effectiveness and Permanence
~cduction ,]f~axicity, .\1obiiity, Jr '.'oiume [hrou~h Treatment
Short- Term Effectiveness
Implemencability
Cost
v
~
48
48
49
50
51

54
58
58

60
62
.62
63
63
66 \
66 .
66
67
67
68
68
68
70
70
73
73
75
75
i5
36
56
$6
37
,-
.} J
37
,-
) I
38
88 .

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9.3
MODrFYING CRITERIA
9.3.1 State and Tribal Acceptance
9.3.2 . Community Acceptance
9.4 OVERALL RANKING
10. SELECTED REMEDY
10.1 CLEANUP OBJECTIVES
10.2 KEY ELEMENTS OF THE SELECTED REMEDY
10.2.1 Site Use Restrictions
10.2.2 Source Control
10.2.3 Natural Recovery
10.2.4 Sediment Remedial Action
10.2.5 Monitoring
10.3 IMPLEMENT A nON
10.4 COSTS
II. ST A TUTOR Y DETERMINA nON
11.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

11.2 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
11.2.1 Action-Specific ARARs
11.2.2 Chemical-Specific ARARs
11.2.3 Location-Specific ARARs
11.2.4 Other Factors To Be Considered
11.3 COST EFFECTIVENESS

11.4 UTILIZATION OF PERM~NENT SOL UTIONS AND ALTERN A TIVE
TREA TMENT ITECHNOLOGIES
[1.5 PREFERENCE FOR TREATMENT .-\S .-\ PRINCIPAL ELE;..,.! ENT
12. DOCUMENTATION OF SIGNIFTC.-\NT CHANGES
I" .
, ...1
?ROJECT SCOPE
12.: SOURCE CONTROL
: 2.3 :-IABIT AT OBJECTIVES
!:A SELECTED REMEDY
12.5 COST ESTIMATES
12.6 IMPLEMENT A nON SCHEDUl.ES
REFERENCES
VI
Page
92
92
95
95
97
97
98
98
98
99
99
103
104
106'
108
108
109

109
110
III
111
112
112
I ' .
. ~-'
: !~
: 1.:1
. 15
: ! 5
~ I 5
~ 1-;-
117

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APPENDIX A - LETTERS OF CONCURRENCE
APPENDIX B - RESPONSIVENESS SUMMARY
APPENDIX C - IMPLEMENTATION SCHEDULES FOR SOURCE CONTROL
AND SEDIMENT REMEDIAL ACTION

APPENDIX D - REVISED COST ESTIMATE FOR CONFINEMENT OPTIONS

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Figure 1.
Figure 2.
LIST OF FIGURES
Commencement Bay Nearshore/Tideflats study area
Figure 4.
Figure 3. . Commencement Bay drainage netWork
Commencement Bay tide flats and shoreline modifications as of 1986
Figure 5.
Figure 6.
Figure 7.
Figure 8.
Figure 9.
Sediments at the Head of Hylebos Waterway not meeting sediment quality
objectives for indicator chemic:i1s at present and 10 years after
implementing feasible source control

SedimentS at the Mouth of Hylebos Waterway Dot meeting sediment quality
objectives for indicator chemicals at present and 10 years after
implementing feasible source control
SedimentS in Shcwn Waterway not meeting sediment quality objectives
for indicator chemicals at present and 10 years after implementing
feasible source control
Sediments in Middle Waterway not meeting sediment quality objectives
for indicator chemicals at present and 10 years after implementing
feasible source control
Sediments at the Head of City Waterway not meeting sediment quality
objectives for indicator chemicals at present and 10 years after
implementing feasible source control
Sediments in Wheeler-Osgood Waterway not meeting sediment quality
objectives for indicator chemicals at present and 10 years. after
implementing feasible source control
Figure 10. Sediments at the Mouth of City Waterway not meeting sediment quality
objectives for indicator chemicals at present and 10 years after
implementing feasible source control
-. '-.
.-:~ure :-.
Figure II. Concentrations of total PCBs in English sole muscle tissue
?!gure ; 3.
?!gure 14.
Reiationship. between ;)roblem 1re:1S :dentjii~d ,juring (he ~emediaj
investigation Jnd those scudiea ['or (he ['easlbiiity scuay
The AET 1Dproach appiied to sediments restea t'or lead ana -+-fOetnylphenol
concentrations and toxicity response during bioassays
[n- waterway ,:onfined JQuatic disposal (H' .;ontaminated dredged materiai
?:~ure i b.
rigure l5. Cunfined nearshore disposal or -:omaminated dredged material
Dredge '.vater .,;:temiC:11 -::ariiic:1tion i'Jc~ii[y
Figure 17. Confined upland disposal and components of a typical diked upland disposal
site
Figure 18. Key decision points and associated activities
viii
~
6
12
29
31
33
34
\
36
38
39
~I
~J
5:
55
")9
:-\
74

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Table 1.
Table 2.
Table 3.
Table 4.
Table S.
Table 6.
Table 7.
Table 8.
Table 9.
. .
:. ..-. . ...- ..- ". . ............ -, -... -. -. . .~', .' . .
UST OF TABLES
Regulatory authorities for source control activities
Sites at the Commencement Bay Nearshore/Tideflats site listed in Superfund.
Information System
Estimated- individual lifetime risks from eating fish muscle tissue containing
organic compounds
Projected lifetime cancer risks for PCBs and arsenic
Sediment quality values representing the sediment cleanup objectives related
to environmental risks
Major elements of the 10 candidate alternatives
Status of source control activities in Commencement Bay Nearshore/TideflatS
problem areas .
Major chemical-specific ARARs for remedial alternatives
Table 10. Major action-specific ARARs for remedial alternatives
Major location-specific ARARs for remedial alternatives.
Table 11. Costs .associated with candidate alternatives
Table 12. Estimated costs for the four confinement options
Table 13. Indicator chemicals and recovery factors
Table 14. Estimated surface areas and volumes of sediments subject to sediment
remedial action
Table 15. Sediment remedies selected in the feasibility stUdy and Record of Decision
IX
.
~
14
18
46
47
56
61
64
77
81
83
90
93
100
101

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Acronym
AAL
ADI
AET
AKARTs
ARAR
CB/NT
CB/STC
CERCLA
CERCLIS
Corps
EAR
Ecology
EPA
HPAH
LPAH
MCL
NCP
NOAA
NPDES
PAH
PCB
POTW
PRP
PSDDA
PSWQA
RCRA
SARA
SEDCAM
TBC
TPCHD
UBAT
.
liST OF ACRONYMS
Definition
Acceptable ambient level
Acceptable daily intake
Apparent effects threshold .
All known available and reasonable methods of treatment
Applicable or relevant and appropriate requirement
Commencement Bay Nearshore/Tideflats
Commencement Bay South Tacoma Channel
Comprehensive Environmental Response, Compensation, and
Liability Act of 1980
Comprehensive Environmental Response, Compensation, and
Liability Information System
U.5. Army Corps of Engineers
Elevation above reference
Washington Depanment of Ecology
U.S. Environmental Protection Agency
High molecular weight polycyclic aromatic hydrocarbon
Low molecular weight polycyclic aromatic hydrocarbon
Maximum contaminant level
National Contingency Plan
National Oceanic and Atmospheric Administration
National Pollutant Discharge Elimination System
Polycyclic aromatic hydrocarbon
Polychlorinated biphenyl
Publicly owned treatment works
Potentially responsible party
Puget Sound Dredged Disposal Analysis
Puget Sound Water Quality Authority
Resource Conservation and Recovery Act of 1976
Superfund Amendments and Reauthorization Act of 1986
Sediment Contamination Assessment Model
Other factors to be considered
Tacoma-Pierce County Health Department
Urban Bay Action Team

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DEClARATION
COMMENCEMENT BAY NEARSHORE/TIDEFLATS
TACOMA, PIERCE COUNTY, WASHINGTON
RECORD OF DECISION
Statutory Preference for Treatment as a Principal
Element Is Not Met and Five-Year
Site Review Is Required.
SITE NAME AND LOCATION
Commencement Bay Nearshore/Tideflats
Tacoma, Washington
STATEMENT OF PURPOSE
This decision document Presents the selected remedial action for two of the six operable units
of the Commencement Bay Nearshore/Tideflats (CB/NT) Superfund site in Tacoma, Washington.
developed in accordance with the Comprehensive Environmental Response, Compensation. and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization
Act of 1986 (SARA), and to the extent practicable, the National Contingency Plan (NCP). This
Record of Decision is based on the administrative record for this site.
The state of Washington and the Puyallup Tribe of Indians (whose reservation is largely within
or ldjacent to the site) concur on the selected remedy (see Appendix A).
ASSESSMENT OF THE SITE
Actual or thre:ltened releases of hazardous substances from this sire. if not -:orre'.;reu b\'
implementation or' response Jcrions selecred in ,his Recora or" Decision. may presenr :.:n :mmin:::l,
.l:1C ';'-losr:mrill ~ndan~erment :0 public 'l~:~lrh. ',ve:r:lr~.)r the -:~virnnrne~r.
DESCRIPTION 01<' THE REMEDY
The remedy selected in this Record or Decision -:overs two CB/NT .)OeraDle unHS. ~ourcc
.;ontroi IOperable Onit (5) ~md sediment remediation \Ooerable Unit I)]). which were ,'orrnerl\'
~eierred :0 :.lS :1 ..:ombined ')pemble './Oir. ~remvlcie. The i'unction . Jr" rhe ...:omorehensive ;'emel1 \' .'or
these tWO operable unHS i:i ,0 ~rorect me Inarine ~nvlronmenc :.lna thereby reouce :.!:iSOCI:.lrel1 )ulJii...:
':e:ith ...:oncerns. .
in the Cvmmellcemem Bay Nearshore/Ticie!lals FeWjlOililY Sludy (Tetra Tech I n~l). ',VI1I\.:a
covered the former operable unit Areawide, nine problem areas were identified that warrlnted

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Because this remedy will result in hazardous substances remaining onsite in concentrations
above health-based and environmentaJIy-based cl~anup levels. a review will be conducted within
5 years after remedial action begins to assure that the remedy continues to provide adequate
protection of human health and the environment. The time frame for the 5-year review will be
determined separately for source control and sediment remediation and will vary among the eight
problem areas. Initiation of the 5-year review period will be scheduled by the lead management
agency for each action. .


i~~ i/l>L~_j ()
'0 I~i(//U
Robie G. Russell
Regional Administrator \
U.5. Environmental Protection Agency
Region 10
?V
';T~f,I~fi~~
V Date
/~o'1

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8 Head of Hylebos Waterway 8 Mouth of Hylebos Waterway
8 Sitcum Waterway 8 St. Paul Waterway
8 Middle Waterway 8 Head of City Waterway
8 Wheeler-Osgood Waterway 8 Mouth of City Waterway
8 Ruston-Pt. Defiance Shoreline.  
Response actions governed by this Record of Decision are limited to eight of the nine CB/NT
problem areas listed above. As a result of new information received during public comment on the
CB/NT feasibility study. the U.s. Environmental Protection Agency (EPA) has decided to
reconsider the proposed plan for the Ruston-Pt. Defiance Shoreline problem area. A revised
feasibility study for that problem area.. now established as Operable Unit 06 (ASARCO Sediments)
is currently being prepared by EPA for further public comment.
The selected remedy for the eight remaining CB/NT problem areas is defined according to
cleanup objectives for both source control and sediment remediation. The remedy establishes a
cleanup objective and a multi-element remedial strategy designed to achieve the objective. In
general, the selected remedy will be implemented in each of the different problem areas indepen-
dently of one another. The overall remedy includes a 8-year active cleanup phase for source
control and sediment remediation, and a IO-year natural recovery phase.

Remedial technologies for source control, the first step in the selected remedy, include a fuU
range of all known available and reasonable methods of treatment (AKARTs). The schedule for
source control varies among problem areas but is expected to be largely accomplished during the
next 8 years. The Washington Department of Ecology (Ecology) is the lead management agency
for source control under a cooperative agreement with EPA.
The second step in the selected remedy. correction of sediment problems. will be accomplished
through a combination of natural recovery and active sediment remediation. Areas expected to
recover naturally within a IO-year period after source control measures are implemented will be
monitored annually to confirm that prediction. Site use restrictions, such as advisories against
seafood consumption. will be implemented to protect human health until recovery is complete.
Areas not expected to recover naturally in a timely manner will be actively remediated when source
control measures are designated acceptable by Ecology and EP A.
Active remediation of problem sedimentS will be accomplished by utilizing a limited range of
four confinement technologies. each of which can provide a feasible and cost-effective means of
achieving the cleanup objective for the site. These technologies are in-place capping, confined
aquatic disposaJ, ne:ushore disposal. and upland disposal. The selected remedy provides perform-
:mc~ objectives for ~ach of these confinement technologies and 11l0wS the f1e~ibility to implement
any or all of them durjng the active cleanup phase of the project. EPA will be the lead :lgency for
:moiementin~ .>ediment remediation. The ?uvallup Tribe of (ndi:ms has :,een ~si::lblished :lS .:
;upporting a~ency for the project through J cooperative Jgreement with EPA.
DECLARATION
7he ~eiected remedy is protective 01 the marine ~nvironment Jnd related ~uman ~e:J.ith
~oncems. The remedy :J.iso comolies with federal. state. Jnd tribal reauirementS ~hat :ue :lOpiic~ole
or relevant Jnd appropriate (or this remedial Jction. :lOd it is cost-~Ifective. This remedy uses
Jermanent :olutions :1Od ::1iternative ,re:ltment technoio~ies ,0 the :naximum extent Jr:lc:ic~bie :'or
:his ~i[e. The r"easibiiity 'J[" ;Jermanent treatment wiil be ~vaiuated oJn J. -::lSe-oy--'::lSe):lSis JV
Ecology for the purposes of source control. However. treatment of contaminated marine sedimentS
was not judged practicable at this site bec3use CB/NT problem sediments are characterized by
rela1ively low concentrations of caammimwntS and relatively Large volumes of material. Therefore.
this remedy does not satisfy the statUtory preference for treatment as a principal element of the
remedy.

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DEOSION SUMNIARY
1. OVERVIEW
The Decision Summary provides a condensed description of the site-specific factors and
analysis that led to selection of the remedy for the Commencement Bay Nearshore/Tideflats
(CB/NT) Superfund site. beginning with the early identification and characterization of the problem
(documented in the remedial investigation). proceeding through the identification and evaluation
of candidate remedial alternatives (documented in the feasibility study), and concluding with the
remedy selected in this Record of Decision. The involvement of the public throughout the process
is also described, along with dIe environmental progr.uns and regulations that relate to or direct the
overall site remedy. The way in which the selected remedy meets CERCLA requirements is also
carefully documented.
The Decision Summ~ry is provided in the following sections. Section 2 describes general
. characteristics of the site. Section 3 provides site history and discusses the coordination of
enforcement activities. Community participation is highlighted in Section 4. The scope of the
response actions is described in the context of the overall site strategy in Section 5. Site
characteristics and a summary of site risks are provided in Sections 6 and 7, respectively.
Candidate alternatives are described and compared in Sections 8 and 9, respectively, and the
selected remedy is presented in Section 10. The conformance of the selected remedy with statutory
requirements is described in Section II, and significant changes betWeen the remedy described in
the proposed plan and the remedy selected in the Record of Decision are described in Section 12.

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2. SITE LOCATION AND DESCRIPTION
2.1 SITE LOCATION
The CD/NT Superfund site is located in Tacoma, Washington at the southern end of the main
basin of Puget Sound (Figure 1). The site encompasses an active commercial seaport and includes
10-12 square miles of shallow water, shoreline, and adjacent lan~ most of which is highly
developed and industrialized. The upland boundaries of the site are defined according to the
contours of localized drainage basins that flow into the marine waters. The marine boundary of
the site is limited to the shoreline, intertidal areas. bottOm sediments. and water of depths less than
60 feet below mean lower low water. The nearshore portion of the site is defined as the area
along the Ruston shoreline from the mouth of City Waterway to Pt. Deiumce. The tideflats portion
of the site includes the Hylebos, Blair, Sitcum. Milwaukee, St. Paul. Middle, Wheeler-Osgood, and
City waterways; the Puya11up River upstteam to the Interstate-S bridge; and the adjacent land
areas. Because the landward boundary of the CD/NT site is defined by drainage pathways rather
than political boundaries. the precise landward extent of the site may be adjusted as new informa-
tion regarding surface water and groundwater flow patterns is developed.
2.2 CURRENT LAND USE
The CB/NT site is located within the city of Tacoma. which has a population of 162,100.
The land, water, and shoreline within the study area are owned by various parties, including the
state of Washington, the Port of Tacoma. the city of Tacoma, Pierce County, the Puyallup Tribe
of Indians, and numerous private entities. Much of the publicly owned land is leased to private
enterprises. Within the site boundaries, land use is chiefly industrial and commercial.
The Port of Tacoma owns approximately 3S-40 percent of the 2,700 acres that make up the
port and industrial areas within the CB/NT site. The port operates many cargo handling and
storage facilities along the waterways and leases other properties to large and small industrial,
manufacturing, and commercial tenants. Many of the remaining properties within the port and
industrial area were under port ownership at one time, but have since been sold. Major private
landowners include lumber, chemical, and petroleum companies. Property along the Hylebos
Waterway is owned almost exclusively by private companies, and there are several privately-owned
parcels along the Blair Waterway. Other privately owned parcels are found predominancly :lt the
landward end of the port and industrial area.
,~ t:lrge ;Jortion of the tideland :lnd offshore Jre:lS of rhe CB/NT site is ~ither I)wned ,)utri~ht
'~.,' ::-te3t:lte 'Jr is designated :lS state-owned harbor :lre:lS. ~he ?ort ')f T~coma ,)wns 'lllc!:lnaS ':na
1ottom sediments in several :lreas incjudin~ the head ,)f Hylebos Waterway, [he ileaa ,)f 31::lJr
'Vaterway. ::md Milwaukee and.Sitcum waterways. The .St, ?:lui :lna Wheeier-O$~ooa waterways :lre
privatety owned, Private ownership ot" shoretines :lnd intertidai Jreas in many portions tH' ~he site
generaily corresponds with ownership of the adjacent upland property parcets.
The ?uyaHuD Tribe of Indians has JSSerted title to land in the Tacoma tidethts ~1rea. inciuding
;'ormer Puyailup River bottomiand 1nd i"iiled :idelands Jdjacent [0 ,he :'uyailuD ;,cser\'ation.
~e~otiations Jmon~ the PuyaJluo Tribe of rndians. rhe t"ederaJ government. the state of Washin~ton"
:he :'Ort H' ::lcoma. ::.nd '.Jther :lffccted ;J:lrtles ',Vere ..:omDleted 'Iurin~ ~he ';ummer It' i)8S"J
reSOlve '/arious land 'Jwnership issues. The settJement 19reement was J.pproved un :'7\ugust : SJ8S
by tribal members and by federal, state, and local governments. On 21 June 1989, the Puyallup
Tribe of Indians Settlement Act of 1989 was signed into law by the President, incorpor:uing the
August 1988 settlement agreement and technical documentS. Efforts are underway to implement
me terms of ~ agreemeflr, wtrictr adctt to me rribe'! land ~ and provide for subSt:1nti31
restoration and enhancement of fisheries resources. Several large parcels of property within the

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Commencement Bay
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Problem Areas
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CB/NT site boundaries that are slated for environmental cleanup by the Port of Tacoma will be
transferred to the tribe within the next few years.
Cont~min~ntS in the CB/NT area originate from both point and nonpoint sources. Industrial
surveys conducted by the Tacoma-Pierce County Health Department (TPCHD) and the Port of
Tacoma indicate that there are more than 281 active industrial facilities in the CB/NT area.
Approyim~tely 34 of these facilities are National Pollutant Discharge Elimination System (NPDES)-
permitted dischargers, including CWo sewage treatment plants. Nonpoint sources include CWo creeks;
the Puyallup River, numerous storm drains, seeps, and open channels; groundwater seepage;
atmospheric deposition; and spills. The TPCHD has identified approximately 480 point and
nonpoint sources that empty into Commencement Bay (Rogers et al. 1983).
2.3 ENVIRONMENTAL ~J!.llll'lG
Commencement Bay is a large, deepwater embayment of approximately 9 square miles in
southern Puget Sound. In March 1987 Puget Sound was designated by EP A as an estuary of
national significanc:e. Several waterways including the Puyallup River adjoin Commencement Bay,
The drainage area for the Puyallup River is approximately 950 square miles.
, Commencement Bay, including the CB/NT site, supports important Itshery resources. Four
salmonid species (chinook, coho, chum, and pink) and steelhead trout occupy the bay for part of
their life cycle. Recreational and commercial harvesting of these species occurs in the bay\,
Extensive inshore marine fish resources include English sole, rock sole, flathead sole, c-o sole,
sand sole, starry flounder, and speckled sand dab.. Rock sole, c-o sole, and several species of
rockfish are most abundant along the outer shoreline. Although the TPCHD has warned against
regularly cODSuming fish, shellfish. and crabs caught within the study area, recreational harvesting
of many of these species occurs, primarily within City Waterway and along the Ruston-Pt. Defiance
Shoreline.
2.4 PROBLEM DEFINITION
The CB/NT remedial investigation/feasibility study and selection of remedy have been
conducted in accordance with CERCLA as amended by SARA. commonly known as Superfund.
However, given the large study area, the multiplicity of contaminant sources, and [he diversity of
ongoing activities within the CB/NT site, project development and selection of remedy has differed
in many respects from the reports and implementation strategies developed at more traditional
Superfund sites. There are five key aspects of this project that are unique:
.
The focus on protection of the marine environment lnd public health ~onc~rns
related to the. marine environment

The relationship of the project wich other r"eaer::u. mae. cribal. :lnd local programs
:md authorities
oJ
311'
The development or sediment quality objectives that address :J. diverse range ..J{
chemic:!.l contaminantS

The QveraJl scope of the oroblem. including J 'fery large' volume of sediment
~equiring remediation

The need for Jdditionai data in the remedial design phase to refine :md imolement
.he :emedy.
2:
»
2.4.1
Focus on Marine Environment
This Record of ~iorr [$ interrded only co guide actiom related to the goals and objectives
of the CB/NT Superfund project. The CB/NT Superfund project focuses on contaminated marine
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sedimentS, contaminant sources, impacts to marine organisms, and related human exposure
pathways. Therefore, although the CBjNT site includes a large and active urban embayment.
response actions governed by this Record of Decision are designed to address specific problems
associated either with the marine environment or with public health concerns related to the marine
environment. The CD/NT Superfund project is not intended to address other types of environ-
mental or public health problems within the site boundaries that should be adequately covered by
other federal. State, tri~ or local programs. Problems not within the scope of the CD/NT project
include conmmin~ted properties and sources of contamination within the site boundaries that have
not been determined to impact marine sedimentS.
CD/NT response actions are further focused by this Record of Decision to address specific
problem areas within the overall site boundaries. As described in Section 3.4, the identification of
potentially responsible parties (PRPs) by EPA will also focus on ownen and operators of businesses
and properties associated with contaminat,ed sedimentS within the eignt specific problem areas
addressed by this Record of Decision.
2.4.2 Relation to Other Environmental Programs and Activities

Numerous 10ca4 state, and regional programs developed during the course of the CBjNT
project are similarly focused on the protection of marine resources and management of marine
sedimentS, as described in the next section. The attainment of CD/NT cleanup objectives under
the Superfund program will require effective coordination with these and other environmental anq,
public health programs. Jurisdictional considerations will be important during project implementa-
tion in order to differentiate Superfund-related activities from activities regulated according to
other programs and authorities.
Correction of sediment contamination problems throughout the CD/NT site will be accom-
plished through a combiilation of activities implemented under both Superfund and non-Superfund
authorities, including:
.
Site use restrictions (e.g., public warnings and tJSheries advisories to reduce potential
human exposure) implemented by state and local health authorities

Source control measures to reduce or eliminate ongoing releases of hazardous
substances implemented through the following authorities:

Wastewater discharges regulated under state and federal water quality laws

Stormwater and industrial pretreatment requirementS implemented under
federal, state, and local laws and regulations

E::ology's Commencement Bay Urban Bay Action Team (UBA T) oversighc
1nd enforcement of source concrol measures

'facur:ll re~overy through .;hemic:lI degr:ld:uion. jeposicion 0f ;:e:.n 3edimenrs. .:;10
jiffusive loss of ,.:ontaminants co overlyin~ wacer

Sediment remedial lctions t'or more significamlY .;ontaminaced ~ediments 'JSJn~
1ppropriate confinement technologies I e.g.. removai. capping, Jisposai) ..;onducced
:.rnder the' federal Superfund law.
.
']
']
7he ~ffective inre~racion af ,he key ;>roject dementS. related :lctivicies. :lnd ~nvironmenc:lI
luchomies described above will be cricical in [he uitimate Jct:linment of CBI NT cleanup 1)0 jectlves.
2.~.3
Detinition of Cleanup Goals
The CBjNT project was further complicated by the lack of promulgated sediment standards
to serve as project cleanup objectives. ' ~'lSe o£ the (oc:us on the marine enviranmen~ the
development of cleanup objectives for the project had a similar emphasis on environmental risk
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assessment methods. As described in Section 7.2, these methods utilize a preponderance-of-
evidence approach that is based on a suite of three biological indicators. The cleanup objectives
are further adjusted to be protective of related human health concerns (see Section 7.1). In both
cases, cleanup levels have been established in relation to reference area conditions. Management
of site risks was based on the assumption that it would be infeasible to establish sediment cleanup
objectives for the CB/NT site that were cleaner than reference areas.
Initially, the attempt to develop deCmitive cleanup objectives for the CB/NT site was
complicated by the almost complete lack of deClDitive stan~ guidelines, or criteria for deCming
acceptable levels of contaminants in marine sediments. However, the 1989 Puget Sound Waler
QruJlity Managemml Plan (PSWQA 1988) specified numerous goals and policies applicable' to the
CB/NT area. For purposes of defining sediment cleanup goals and requirements, tWo program
elements of the PSWQA plan are of particular importance: standards for classifying sediments
having adverse ef{ec:ts (Element P-2) and guidelines for sediment cleanup decisions (Element S- 7).
Element P-2 req1Ar'es Ecology to develop and adopt regulatory standards for identifying and
designating sediments that have observable acute or chronic adverse effects on biological resources
or pose a signiilC3Dt health risk to hlllftJllM. The Standards for def'miDI 8"1ediments that have acute
or chronic adverse effects8 may incorporate chemical, physical~ or biological tests and must clearly
deCIDe interpretive guidelines. Initial standards may exclusively address biological effectS, but shall
be revised to include human health concerns as pertinent information becomes available. The
standards are to be used to assess discharges through NPDES (Element P-7), stormwater (Element
SW-4), and nonpoint programs; to identify sites with sediment contamination (Element 5-8); and'
to limit the disposal of dredged material (Element 5-4).

Element 5-7 requires Ecology to develop guidelines for determining when to implement
sediment remedial action. The guidelines will consider regulatory deadlines for making decisions,
natural recovery periods for sedimentS, procedures for determining priorities for action (including
consideration of costs), and trigger levels for defining sediments that require expedited remedial
action. Sediment remedial action trigger levels may be higher tban the standards developed under
Element P-2.
The sediment Quality goal of Element P-2 was adopted as the long-term sediment Quality goal
for the CB/NT site. As in other partS of Puget .Sound, this sediment Quality goal is meant to
establish levels of sediment contamination that would be acceptable throughout the CB/NT area.
It is a long-term goal to be achieved through numerous actions over a period of years. The factors
associated with translating this goal into project cleanup objectives will vary depending on the type
of action needed, statutory requirementS, and site-specific considerations.
In accordance with the focus of the CB/NT project and the goals of the 1989 P5WQA plan.
;!e:mup objectives were developed for the project :lccording to the following parameters:
1
S~diment QuaHty Goal: The sediment uua!icy goat is :l .;onceCtual rarget ;ondicion
~'or ?u~et Sound. defined by Element P- 2 of the 1989 PSWQA iJlan JS the :lbsence
:)f :lcute' or ~hronic adyerse ct"fectS on biological resources or' :;ignlt'icant ~uman
;leaith risk.

Sediment QuaHt)' Objective: The sediment Qualicy objective' is :l .jiscrete. :lnd
:neasurable rarget for project cteanuD related to the ?u~et Sound goaL The objective
is measurable in terms of specific human i1e:1ith risk JSSessmentS :lnd cnvlronmentai
~ffectS testS, and associated interpreuve guidetines. The resuHing bioiogical ~t'fect
'~'.'ets ')r;hemicat .;oncentrations :ue ~c:entific:ll1y '~cccCtat)le Jet"inicions .)t' :he
:eaiment quaiity 30a1 using ..vaiiaole :ntormauon.
~
.
Sediment Remedial Action Level: The sediment remedial action level differentiates
areas that exceed the sediment quality objective, but are predicted to recover
naturally, from those that are more signifiClDdy con~min:i'~ and therefore require
active remediation to achieve dIe sediment quality objective. The intent of ilny
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.
active remedjation of sediments is to achieve a net environmental and public he:1lth
benefit and therefore requires consideration of habitat issues.

Source Coatrol Level: The goals and objectives of source control are defined as
targetS thai will achieve respective sediment goals and objectives. Source control will
be implemented according to applicable or relevant and appropriate requirements
(ARARs) and AKARTs. Compliance with the sediment quality objective will be
commned through monitoring.
1.4.4
hobo Scope
The development of a comprehensive remedy for CB/NT site is complicated by various site
characteristics. The broad geographic area includes various sources. contaminants. and associated
biological effects and human health risks. Remediation of sediment COD~mination is inherently
complex because I) the concentration of habitat and food sources at the sediment-water interface
create conditions that are sensitive to contaminant accumulation. 2) con~inants that accumulate
in sediments are generally dispersed from their sources. resulting in relatively large areas of low-
level conmmina.tion. 3) surface sediment contamination reflectS both historical and on-going
conmminAtion because sediment accWDulation i3 a relatively slow process (e.g.. CB/NT sedimentS
typically accumulate at rates from 0.2 cm/yr to 2 cm/yr) and sediment reworking and benthic
activity mix sediment over the upper 5-15 em. and 4) the relatively large volumes of sedimentS
requiring remediation present considerable problems regarding disposal site availability and
capacity. .
To effectively deal with the broad geographic area and multiplicity of sources. high priority
problem areas were identified and treated independently of one another. Source control and
cleanup are being implemented on an individual basis. but subsequent sediment remediation will
be conducted as a concerted effort in each problem area by multiple and diverse PRPs. The
remedies developed for individual problem areas also require that various types of activities (i.e.,
use restrictions. source control. remedial action and natural recovery, and monitoring) be imple-
mented in an integrated fashion. .
2.4.5
Data Needs in the Remedial Design Phase
The data collection effortS in the remedial investigation/feasibility study were designed to
characterize contamination problems. identify priority areas requiring remediation, and evaluate
remedial :1lternatives. The data analyzed in the remedial investigation/feasibility study were not
adequate to fully determine the effectiveness of source controls previously implemented or to fully
define the volume of sediment exceeding the cle:1nup objective. Therefore. information developed
Juring sediment remedial design :1nd futUre source monitoring plays :1 key role in the refinement
jf ~he ,elected remedy for ;nany oroblem 'lreas. Deoils 'Jr. ,he ~iming ~~nd :Jurpose ,)f major ;Jhases
.jr ~ource ;lnci ~eciiment' monicormg lre provicieci :n S~ctlon ~O. r',Irthermore. ~ever:li ~ource ';;J nrro 1
lcrions have been implemented since the ~ource ;oadin~ 'lna1vsis 'vas .:onciucted. D:1t:1 ;:lCS
:lSsociateci with sources will he :lcidressed unaer the source ~OntrOI programs directea by ::~oio~y.
'Vhiie source concrot programs address many aspects or ~ource-related contamination. lctions :hat
.jiminish impactS on sediment lre the central focus of the CB/NT Superfund projecr. Cunse-
quently, source loaciing 'data (i.e.. 'm the amount at' each contaminant dischargeci cO ~ach :)t' :he
:Jroolem :lreas I provide the most important im'ormation f'or jeterrninin~ ~he etfectiveness .)t' .:ource
;ontrols. the relarive contributions ut' problem chemicals by ungoing sources. J.na the :Ieed ;'or
ldditionaj ~ource controls.
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3. SITE HISTORY AND ENFORCEMENT
Thjs section presents a synopsis' of the history of industrial development and CERCLA actions
at the CD/NT site, and provides an overview of CERCLA and non-CERCLA enforcement tools
available for implementing remedial actiODS.
3.1 SITE HISTORY
At the time of urban and indUStrial development in the late 18COs, the south end of Com-
mencement Bay was composed largely of tide flats formed by the Puyallup River delta. Dredge
and fill activities have significantly altered the estuarine nature of the bay since the 1920s.
Intertidal areas were covered and meandering streams ana "rivers were channelized (Figure 2).
Numerous industrial and commercial operatioDS have lO<:ated in the filled areas of the bay,
including shipbuilding, chemical manufacturing, ore smelting, oil refining, food preserving, and
transportation facilities.
With industtialization, the release of hazardous substances and waste materials into the
environment has resulted in alterations to the chemical Quality of waters and sediments in many
areas of the bay. Contaminants found in the area include arsenic, lead, zinc, cadmium, copper,
mercury, and various organic compounds such as polychlorinated biphenyls (PCBs) and polycyclic
aromatic hydrocarbons (PAHs).
Commencement Bay was placed on a national interim list of 115 highest priority hazardous
waste sites on 23 OctOber 1981. Initially, the Commencement Bay site was divided into four areas:
deepwater, nearshore, tideflatS/mdustria4 and south Tacoma channel. The National Priorities List
promulgated on 8 September 1983 designated the CD/NT area and the Commencement Bay South
Tacoma Channel (CB/STC) as separate National Priorities List sites. The deepwater portion of the
bay was eliminated from the list at that time because water Quality studies indicated there was
minimal contamination in the area.
On 13 April 1983, EP A announced that a cooperative agreement had been reached with
Ecology to conduct a remedial investigation/feasibility study on the nature and extent of contami-
nation in the CB/NT site. Under the agreement, Ecology was designated as the lead agency for
rhe investigation. The Commencement Bay Nearshore/Tideflals Remedial lnvesligalion (Tetra
Tech 1985), completed in August 1985, characterized the nature and extent of contamination :It the
5ite. The Cvmmencemem Bay Nearshore/Tideflals rea.~ibiiiIY SIWY (Tetra Tech [988a) was
';amoleted in December 1988. described feasible Jlternatives for sediment remedial Jcrion Jt ,he
:J[e. -:"11e i'e:lsibiiity study :ncluded .ln ;nte~rated Jcrion plan \?TI 1988) ro .;oordinJ[e ,)ngolng
;ource control ~iforts and sediment remediai :liternatives. :lnd a sediment quality goais document
,PTI 1989) to deveiop sediment Quality objectives. ?ublic .:omment on [he ,'easlbiiicy ~tudy '.vas
~eceived from :4 February ro 24. june [989. G~nerai notice letters were sent by EPA :0 i33 ?RPs
on :4 April! 989 informing rhem of [heir potential liability for sediment contamination Jt rhe
CB/NT sice:
;-:Jntaminated ~ediments Jiong rhe RustOn- Pt. Deiiance .5horeiine were r'urther chamcrerizea
jurin~ J site-soecific remediai investi~ation t"or the ASARCO Tacoma smelter which was aresented
.~s Juolic :omment 'm ::1e .~J/NT ~'cJ.Sibilicv :mdy:nd JrOooseu ;Jian. -:-heser~\'esw~aclOns
.;ont"irmed a direct linK aecween (he ":-'SARCO facilicy Jnd sediment contamInation. Que iO these
findings, sediment remedial action for the Ruston- Pt. Defiance Shoreline will not be addressed
under the CB/NT sediments Record of Decision. Following public comment on a re~ised study :lnd
proposed plan, they will be addressed under a separate Record of Decision for a newly defined
operable unit for the ASARCO sediments (see- Section 5.1).
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In September 1988, the Simpson Tacoma Kraft Company completed source control activities
:lnd implemented sediment cleanup action. These actions, which were undertaken as part of a stJte
consent decree signed in December 1987, consisted of the placement of a layer of clean sediment
(i.e., a sediment cap) over contaminated sedimentS and restoration of intertidal and shallow subtidal
habitats. Future EPA enforcement actions will expand response activities (e.g., sediment monitoring
activities) at this problem area to be consistent with this Record of Decision.
In several areas, additional sediment sampling has been conducted either as part of planned
dredging activities or in anticipation of pending CERCLA action.
3.2 MAJOR SOURCE CONTROL PROGRAMS
Several federal, state, and local programs address source control independently of CERCLA.
These programs and the CERCLA pre-remedial program are described in this section.
There are four general categories of cont~min~l1t sources at the CB/NT site:
.
Contaminated properties
Wastewater discharges
Air emissions
Storm drains.
.
.
.
Contaminated properties exist throughout the CB/NT site. In many cases, groundwater and
surface water discharges from these facilities represent significant sources of contamination to
CB/NT sediments. In other cases, active facilities discharge wastewater to Commencement Bay
directly via outfalls or storm drains. Wastewater discharged from some of these facilities contains
problem chemicals that may contaminate receiving waters and sediments. Wastewater discharges
are subject to regulation under one of three discharge programs: I) NPDES, 2) Washington waste
discharge permit, and 3) industrial pretreatment program. Historical and ongoing air emissions
from facilities in the CB/NT site are sources of contamination via the deposition of airborne
particulates. Stormwater runoff has been identified as a" major source of heavy metals and other
chemicals [e.g., high molecular weight polycyclic aromatic hydroc:ubons (HPAHs) in Commence-
ment Bay]. Only a small fraction of over 400 storm drains that discharge to the bay have been
associated with sediment contamination. Control of storm drains and stormwater runoff is
addressed under the federal Clean Water Act, the 1989 PSWQA plan (PSWQA 1988), and state water
quality law. Under these programs. EPA and Ecology are required to develop :l permit system :md
issue discharge permitS for storm drains, :lnd city and county governments :lre required to deveiup
stormwater management programs.
Source ;ontrol ~nr"Grcement 1t :he CB,-NT site invokes many ~nvironmenta! ~rOl.Sr:lI11S :!:Ll
raws. RegulatOry authorities and programs under the Resource CJnservation J.na RecQvl:r:: -\~:
; R.C?~A I, ~he Clean Water ACt. the CIean Air .~ct. ,he Hazardous Waste Management "-\~t. .;nd fae
Washington Mociel Taxies C0ntrol Act are critical r'or ~nforcing source control actions \ Table: L
[n addition to these laws, the 1989 PSWQA plan (PSWQA 1988) t::stablishes various programs lnd
reQuiremems :-elated to source control (as weil J.S sedimem contamination I. Programs ::lnd
ieQuirements under rhe PSWQA plan :lre designed primarily f'or ~nforccment and promuigJtion
QV :::co!ogy" Em"orcement ,)r" ~ourcc <.;omrol ~crions is accomolishea primaniv bv rhe CJmme:1c~-
mem Bay UBA T. :J. task force 0rganized under Ecology's Urban Bay Acrion Program. :lnd ,)ther
.;rograms 'Jr" Ecology, :he .::tV 'Jr" Tacoma. :;nd :he "'PC:lD. T"hese ;Jrograms doerate :nocoem1enu\,
)( -::RCLA. :)o[h within me CB/NT me :U1Q vrfsite. However. '-.'ERCL.';'-uirectea ~ourcc ':Olltrol
will be closely coordinated with the above programs.
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'fAilLE I. REGULATORV AUTHORITIES FOR
SOURCE CONTROL ACTIVITIES
. '
.".-.. -------_..u." ---- -
Allihuail}'
Activilies
. . ----------------- --
Coolamioalt;.i i ;..dhlic.s
Fcde..al .IIIJ :.Iialt; ha:wnJllu:> sul':>lalll:~ cleanup
prog..a.m 1111.1.:. III~ CUlllp..da':h:.iv.: Environ-
mCOlal 1(1.::>1);111:>1.:, CUIl1p,:u:'iali,lII. alld Liabilily
ACI (CU
-------
TAPL~ J.
u :mtHm'c~U
AUlholil}'
Activities
. - ---- .--- -.-.---..
.- '-- _._----~ -.."-." -.
Air Emw.iuu:..
Puget ~h'lIlId Ail Pulluliull CUlllhl1 Agcnl.)'
,and ELUJ. ,gy
saonn Draiu:>
NPDES
VI
TPCHU ,wJ dl}' u.. 'Uu;ullia 1\'1.11 illc I{csuurce
ProteLli.,1I Pr,'gl.un anJ S"H au I hain Program
City 01 't'h:UflIa SlUlm dl;lill LIIII~IIIII;lh)fl and

mainkll.llh:c
Prevention of Significant Deterioration permits are issued by either the Puget
Sound Air Pollution Control Agen~ or Ecology, depending on source type. Ecol-
ogy's air section issues permits for the aluminum, pulp and paper, and refinery
industries. (Notice of Construction permits are issued by the Puget Sound Air
, Pollution Control Agen~ for facilities under construction.)
The NPDES program has established a schedule for permluing Slorm drain syslems
based on Ihe size of the service area. Permits will require developmenl of plans
for conlaminant conlrol.
These programs include source mapping. Siorm drain sampUng, source control,
interagency coordination, nonpoint source investigations, and permit reviews,
Sewer inspections are conducted to assess physical integrity and proper function,
and verify sewer hookups and sanilary sewer!slormwater separation.
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3.2.1
Commencement Bay Urban Bay Action Team
Based on the results of the CB/NT remedial investigation, the Commencement Bay UBA T was
formed by Ecology to expand previous and ongoing source control activities at the CB/NT site.
Prior to 1987, the action team relied on state water quality and dangerous waste legislation (e.g.,
RCW 90.48 and 70.105) to enforce source control and remedial activities related to sources.
Unilateral :uimin;qtrative orden as well as consent orders and decrees are the primary enforcement
tools under these laws. After 1987, consent orders and decrees were issued pursuant to the
enforcement authority set forth in the state Hazardous Waste Cleanup Act (RCW 70.105B). RCW
70.10SB was replaced by the Model Toxies Control Act in March 1989, and all consent orders and
decrees were subsequently issued from the enforcement provisions of the new law. The Model
Toxies Control Act provides for direct intervention and cleanup of hazardous substances by the
state and includes a provision for recovery of treble damages.
Discharge permits are also used to enforce source control activities at the CB/NT site.
Discharge permits, provided for by NPDES under the Clean Water Act. are written and enforced
by three programs at Ecology: the Commencement Bay UBA T, the southwest regional office water
quality program, and the industrial section. NPDES permits are used to regulate direct surface
water discharges. However, the effluent limits set in the permits have rarely included limits for
toxic conmminants. The 1987 Clean Water Act and Element P-6 of the PSWQA plan (PSWQA
1988) both require adding toxic contaminant limits to NPDES permits. In addition to direct
discharges. NPDES permits cover diffuse discharges such as sandblasting waste from shipyards and
ship repair facilities.

Under the 1987 Clean Water Act. NPDES pennits will be required for industrial storm drains
and for cities with storm drains serving total populations of more than 250,000 by February 1991.
NPDES permits will be issued to smaller cities .serving populations of 100,000-250,000 by February
1993. In addition, the PSWQA plan requires that local governments begin developing stormwater
management programs by I July 1989, and demonstrate significant progress by I July 1991. By
the year 2000, the programs must be implemented.
The Commencement Bay UBA T coordinates its efforts with several other Ecology programs
in enforcing source control activities. The solid and hazardous waste program and the hazardous
waste investigations and cleanup program control dangerous or hazardous wastes that have been
handled, stored, treated, or disposed of at the CB/NT site. The industrial section of Ecology
administers NPDES permits; regulates solid and hazardous waste; and oversees cle:mup of soil, air,
and water for the aluminum, pulp and paper, andpecroleum industries at the CB/NT site.
3.2.2
TPCHD Marine Resource Protection Program
The marine resource protection program was initi:lted by the Tacoma city .:ouncii in .-\Dril
; 985 :0 ;mprove water quality in Commencemenc 3:lv. Ylarine resource prOtection 1cti\',ri~s :nc:uue
:napping of pOllution. sources and new ouctails. routine scorm drain sampiing, '50urce.:oncrol.
.ntera~ency coordination. investigation .)1 i1onpoinr pOllution. monitorin~ or" t:lcoma's inauscriJi
;Jretreatmenr program. Jna review 01 NPDES permits (Pierce ~t ai. ! 987). When -=ontarninatlon
problems are discovered. marine resource procection personnel work with rhe source tOacility Qwtrer
,Jr 0perator; Ecolo~y, ciry of Tacoma. :lnd TPC:1D (0 implement best management practices .Jr ocher
me:lSures :0 minimize or ~Iiminate -=ontaminanr dischar~es.
J':':
.::ty of T~coma
In 1984, under authority of Clean Water Act Section 307, the city of Tacoma ~stablished an
industrial pretreatment program. Under the program, EPA sets effluent standards for certain
categories of industries. Industries that discharge effluent to sanitary sewers must meet these
standards. Stricter standards may be set by the municipal wastewater treatment plant receiving the
effluent. to meet the permitted effluent limits of municipal NPDES permits. In addition to self-
-------
monitoring requirements imposed by the permits, the city of Tacoma monitors all industries twice
yearly. Source control activities that involve the discharge of effluent to Tacoma sanitary sewers
must comply with. the substantive requirements of the pretreatment program (e.g., discharge
limitations and monitoring).
3.%.4
TPCHD/CIty of TaCOlll8 Storm Drain Program
Pursuant to a memorandum of agreement betWeen Ecology, the city of Tacoma. and the
TPCHD, a program was initiated in August 1986 to identify and characterize sources contributing
COD~minSints to several publicly-owned outfal15 in Commencement Bay. The program currently
focuses on a drainage system at the head of Sitcum Waterway, three drainage netWorks in City
Waterway, and one drainage netWork in Wheeler-Osgood Waterway.
Tasks undertaken by the program include drainage basin characterization (inspection and
documentation of industries and comprehensive drainage basin mapping), quarterly wet weather
and dry weather monitoring of storm drain effluent, periodic monitoring of key catch basin
sediments, and identification of sources (including roadway con~minSint characterization). While
most of the program has been completed, it is expected that storm drain monitoring and other
activities (e.g., source identification) will continue over the long term.
3.2.5'
CERCLA Pre-remedia1 Program
Various contaminated industrial sites listed in the Comprehensive Environmental Response,
Compensation, and Liability Information System (CERCLIS) are located within the CB/NT site.
Contaminated sites listed in CERCLIS are either CERCLA sites or have the potential to become
CERCLA sites. Twenty-six CB/NT CERCLIS sites do not require further action by the federal
Superfund pre-remedial program because they are already addreSsed by non-CERCLA programs.
Table 2 summarizes these 26 sites. Of the 26 CB/NT CERCLIS sites, 14 are currently considered
to be potential sources of contaminants to the CB/NT problem areas addressed here. They are
referred to as CB/NT source control sites in Table 2. Eighteen of the CERCLIS sites are being
tracked and managed under non-CERCLA programs by Ecology's Commencement Bay UBA T.
Enforcement authorities for these sites are described in Table 1. Eight CERCLIS sites are being
managed under non-CERCLA programs by EPA, Ecology (non-UBA T), or TPCHD. Enforcement
mechanisms for these eight sites include RCRA and state dangerous waste and county solid waste
regulations.
3.1.6
Coordination of Source Control with' Other Programs
Existing programs :lnd requirements will provide the basic regulatory frame'.vork ~'or :he
~ecuc.ion 'Jr elimination of ongoing :eleases ,)f roxic materials :0 :he marine ~nvironment. ~')r
~xamDte. wastewater dischar~es from industrial Jnd municipal fJcilities have been :md '.viil continue
~o be regulated. under NPDES and state waste aischarge- permit programs. Reieases uf haZJrdous
suostances have' been' J,nd will continue- (0 be regulated under state Jnd federal hazardous '.vaste
management laws. rn most cases. discharge requirementS are similar co requirementS for .;omparnble
;'aciiities in other parts of Puger- Sound. .
3.3
\1AfOR SED[MENT \tfANAGEMENT ?ROGRAMS
The major focus oi the CB/ NT Record of Decision is to correct sediment .;omaminauon
problems via source control and sediment remediation. Sediment remediation may occur by natural
recovery or sediment confinement. Removal of marginally contaminated sediment outside the
designated problem areas may occur irrespective of remediation during routine navigational
dredging. Sediment remedial activities in problem areas at dte CB/NT site are driven by CERCLA.
. rn addition, routine dredging in problem :ueas will be subject to the requirements of the multi-
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TABLE 2. SITES AT THE COMMENCEMENT BAY NEARSHORE/TIDEFLATS SITE
LISTED IN SUPERFUND INFORMATION SYSTEM
.
CERCLIS  
Identification  Managing
Number Site Name Agency
W AD980738025 BetL tandfill UBAT'
W AD008958357 Cascade Pole Co., Inc. (McFarland) EcologyC
WAD981763162 Cascade Timber Log Sorting Yard .1 UBAT
W AD988466413 Cascade Timber Log Sorting Yard -.2 UBAT
W ADOO9281 007 Coski Industrial Dump UBAT
W AD980S 14566 Dauphin Site UBAT
W AD980639645 Don Oline Landfill UBAT
W ADO09248774 Georgia- Pacific UBAT
W AD00925329S Louisiana- Pacific Corporation UB~T
WAD980511653 Marine View Drive Site UBAT
W AD08933S 160 Murray Pacific Log Sorting Yard #1 UBAT
W AD009253246 Pennwalt Chemical Corporation UBAT
W AD980S 11711 Petarcik Site UBAT
W AD0676 162586  Tacoma Boatbuilding Company UBA T,Ecology
W ADOO9281403 TAM Engineering UBAT
W ADOO924202S USG Company UBAT
W AD980639140 USG Company, Hylebos Creek Dumpsite UBAT
W AD981761794 Wasser- Winters Log Sorting Yard UBAT
W ADOO I 829522  Allied Chemical Corporation - Tacoma Works TPCHD
W AD08335023I  American Plating Company E-P.-\
W A D070046511  Champion International (Simpson Tacoma Kraft) Ecology
W ADOO 1882984 Kaiser Aluminum :lnd Chemical Cvcpocation E~oiog~:
.v.~D02754:>03~ L.,jlyblaG Petroleum. [nc., Sol-?:-o :':Jivgy
'V A D009242314 'Jccidencal Cilemical Cucoorntion ::?A
W AD009252628 Stauffer Chemical 7PC: fD
WAD009252719 U.S. Oil & Refining Company ::colo~y
- CB/NT Source
Control Site
..
.
.
.
.
.
.
.
.
.
.
.
, . = ~:;jrrently ':onsidered to be ';:Jotencial sources of -:oncaminancs to CB/NT problem Jre:lS.
., ~he '':ummenccment gay rJrban ~av Action Team (UBA T) :It '.Vasningron Deoarcment ,)1" :::coio~n"~ :-;outhwe~r
~~c:;jonal <)fficc.
hington Department of Ecology programs other than the Commencement Bay UBA T.
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agency Puget Sound Dredged Disposal Analysis (PSDDA). If sediments in problem areas fail
criteria for open-water unconfined disposal. sediment remediation will proceed as a CERCL.-\
action.
Dredging and dredged material disposal in Commencement Bay are regulated by Clean Water
Act Sections 404 and 401 (i.e., the state water quality certification process), Washington Department
of Fisheries and Washington Department of Wildlife (hydraulics permits), Washington Department
of Natural Resources (aquatic disposal site permits), city of Tacoma (shoreline substantial
development permits), and PSDDA (procedures and guidelines for dredged material and disposal
site testing). These authorIties address the fOllowing aspects of sediment removal and disposal:
.
CIean Water Act .Section 404 Permit Federal Clean Water Act Section 404 specifies
requirementS and guidelines for dredging and dredged material management,
including designation of disposal sites. The U.S. Army Corps of Engineers (Corps)
is responsible for processing and issuing permits under the Section 404 program.
Federal guidance specifies procedures and criteria for achieving compliance with
guidelines, evaluating and testing dredged material, developing and considering
actions to minimize adverse effects, and issuing permits for the disposal of dredged
material.

Puget Sound Dredged Disposal Analysis Procedures aad Guidelines: The Corps,
EPA, Washington Department of Natural Resources, and Ecology have adopted a
management plan for dredged material, which is suitable for unconfined open-water
disposal, including disposal site locations, site conditions, dredged material evalu-
ation procedures, disposal site management, disposal site monitoring, and dredged
material data management (PSDDA 1988). These procedures and guidelines were
developed under Clean Water Act Section 404. .

State Water Quality CertiCication: Pursuant to Clean Water Act Section 401. state
water quality certification by Ecology is necessary for any project that may cause
the violation of a state water quality standard.

Washington Department ot Fisheries and Washington Department ot Wildlife
Hydraulics Permit Hydraulics permit regulations. require the issuance of a
hydraulics permit by the Washington Department of Fisheries and Washington
Department of Wildlife for any project that may interfere with the natural flow of
water.

Washington Department of Natural Resources Aquatic Disposal Site Permit: W.-\C
332-30-166 establishes a procedure for site selection and a fee structure for site use.
General requirements specified in WAC 332-30-166 are mirrored in PSDDA
guidelines (see PSDDA Procedures :lnd Guidelines. above).
.
.
.
.
:8
City of Tacoma Suustantia! Developmen( Permit: The ~ity of TJcarn::1 has prep:ued
:1 ';iloreline man:1!~ement pl::1n pursuant (0 the ~[are Shoreline \-!anagement .-\~r. Ti~:;:
TJcoma shoreiine management pian csraiJiishes cnvironmencai JesignatlOns ;ur
:horeiine segments wimin city iimits ana cs(ablisnes :.lilowable uses ana restrictions.
:-eauiremems. and :imltations ~'or those uses. Shoreline management pi::1n tJrdinances
inciude provisions for apptic::1tion for a substantiat development permit for projec:s
'.vi thin the shoreline :lrea that .are valued at more than 52.500.
:\ourine :1avigational ureaging :J.ctions must meet ail subscamive :1Od procedural ,eauiremenrs 'Jf
these ?ermit :1Od certification programs. Sediment removal and disposal JCtlOns conaueted '.moer
.':?.C:'.:" ::luSt :neet '.)niv .he .;ubst:lntlve ~eaUlremenrs.
CERCLA requirements and procedures will be used to implement sediment remediation,
including both monitoring for natural recovery and active remediation (e.g., capping, or removal
and disposal). Sediment remediation wiII be developed in ~ phased ~proadl according [0 prioriries
for action described in the Commencemem Bay Nearshore/Tide[lals Illlegraled Action Plan (PTI
1988) and clarified in this Record of Decision. Under CERCLA. sediment remedial :lction will be
-------
performed in compliance with the substantive requirements of exi'sting environmental rules and
regulations. Routine (i.e.. non-CERCLA) sediment removal actions that contribute to the selected
remedy must meet all permit requirements.
The U!tii~t cleanup strategy proposed in the CD/NT feasibility study is consistent with and
supportive of the major sediment quality management initiatives and programs of PSDDA. the
PSWQA plan (PSWQA 1988), and the Puget Sound Estuary Program. Many of the actions proposed
for the CD/NT site depend upon the successful implementation of these programs.
3.4 ENFORCEMENT ROLES OF EPA, ECOLOGY, AND THE PUYALLUP TRIBE
This Record of Decision represents a significant transition in agency management and
oversight of the CB/NT project. During the remedial investigation/feasibility study phase of the
project, Ecology had the lead management role through a cooperative agreemeAt with EP A.
Ecology was responsible for developing the remedial investigation/feasibility study and for
implementing source control measures for many of the major sources that were identified during
the remedial investigation/feasibility study.

In March 1988, a manaaement strategy was developed by EPA and Ecology that was intended
to define responsibilities following the Record of Decision. It was agreed that Ecology would
maintain the lead for source control because of the multi-programmatic enforcement capability of
the Commencement Bay UBAT, and EPA would assume the lead for sediment remedial action
because of EPA's experience in managing multi-party cleanup actions. \
The dual-lead concept of CB/NT project management was formalized on 30 June 1989 in a
cooperative agreement betWeen EPA and Ecology. The agreement provides for an additional level
of federal funding to Ecology that will double the size of the Commencement Bay UBA T during
the active cleanup phase of the CD/NT project. Under the terms and conditions of the agreement.
Ecology assumes responsibility for CB/NT source control actions which are to be implemented
under various enforcement authorities in a manner that closely paral1els the Superfund process. For
example, community relations activities are to be included in accordance with the requirements and
guidance of CERCLA and the NCP.
The primary purpose of the cooperative agreement is to significantly enhance the Commence-
ment Bay UBA rs ability to meet the project goals for source control in a timely manner. The
agreement is also. intended to ensure coordination with other environmental programs that continue
to playa key role in successful project implementation (see Section 3). Under the terms and
conditions of the agreement. source control will be implemented by Ecology on a facility- or
property-specific basis according to the schedule outlined in Section 12.6. Reporting requirements
include periodic progress reports and submittal of a final Superfund completion report t'or ~ach of
the eight CB/NT problem :ueas described in this Record af Decision. Progress reportS will be used
:0 'lOaate 1nd revise Co/~T implementation sC:1eduies ')n :In ::mnual a:1Sis. CJmol~[jon ~eportS '-viii
summarize .he status of enforcement ;lctivities upon completion of source control, see S~crion ! 0..3)
.:na .viil :-eQuire approvai by :he SPA R.egional Administrator. .-\djustments co (hei~reemem
lnd/or utilization of other iesources by either agency may be necessary in \Jrder ~o meet :he
CB/NT objectives for source control.
In .:ontrast. sediment remediation will he imolemented in each problem lrea under EPA
'Jversight. EP A recently conducred :J. search to identify PRPs ~'or ~acn of :he ~ignt C3/ NT ;Jroblem
:ueas of concern. These PRPs were notified of their potential Superfund liability for sediment
:nvestigation .1Od de:lOUO 'lcrivities :n :1 C':RCLA senerai 'lOticeener :ssued 'w 2?:\ n ~Orti
: 9R9. The ietter iequested (he ?RPs co ciarify the status ,)(. their lnvolvemem It :ne jlte loa
respond to questions regarding the use and disposal of hazardous substances at the site. As
appropriate. EPA will pursue CERCLA settlements with PRPs for sediment remediation in each
of the problem areas. EPA's legal enforcement and cost recovery eff01ts for Operable Units 01
and Q2 will foc:us. on. those PRoPs iden.tified by EPA for ~ of the eight CB/NT problem ueas
described in this Record of Decision. Owners and operators of businesses and properties within
-------
the CB/NT site, but not associated with sediment contamination problems in the eight CB/NT
problem areas, will not be issued special notice letters or designated as PRPs in conjunction with
this project. EPA may conduct additional investigations or name additional PRPs if new inform-
ation is received that demonstrateS that a party may be liable for response actions described in this
Record of Decision.
In addition. some property owners and operators may be Dotified by Ecology of potential
liability for response actions in the tide flats area. In some cases, notification by Ecology may be
related to CB/NT source contrOl efforts. Source control actions by Ecology will be very closely
coordinated with EPA efforts to clean up sediments in waterways and shoreline areas. In other
cases. Ecology may contact property owners and operators in the tideflats area for reasons unrelated
to the CB/NT Superfund project.
The role of the Puyallup Tribe of Indians was limited durin a the remedial investigation/
feasibility study phase of the project. As a member of the CB/NT technical oversight committee
(see Appendix B. Responsiveness Summary) the tribe's primary role was to review project
documents. In 1986, Congress expanded the tribe's CERCLA role under SARA, giving it
substantially the same opportunities for project oversight and implementation afforded the state.
In response, EP A entered into a Superfund memorandum of agreement (27 April 1989) and a
cooperative agreement (28 April 1989) with the tribe that provided for participation as a supporting
agency, especially with regard to evaluation and restoration of threatened or impacted natural
resources and important habitats within the project boundaries.
3.5 SCHEDULING AND COORDINATION OF SOURCE CONTROL AND SEDIMENT
REMEDIAL ACrION
Correction of sediment contamination problems at the CB/NT site will be implemented over
a period of several years. In the short term, regulatory efforts will focus on measures to reduce
or eliminate the ongoing release of conaminants. These measures, in conjunction with natural
processes such as biodegradation and sedimentation, will reduce exposure to contaminated
sediments. After source control measures are implemented in a particular problem area, sediment
remedial action will be initiated (see Section 10.3).
As indicated in previous sections, correction of sediment contamination problems, including
source control, will be implemented by several agencies using a wide variety of existing regulatory
authorities. Relationships among the CB/NT project and other federal, state, tribal. and loc:ll
programs are important jurisdictional considerations during the cleanup phase of the project. For
example, during this period it is anticipated that routine dredging projectS (Le., projectS not related
to Superfund) will continue to occur. The relationships between the CB/NT proje<:t and various
non-Superfund projects are described in more detail in the fe:lsibiIity study.
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4.. HIGID..IGHTS OF COMMUNITY PARTICIPATION
A revised community relations plan was recently completed by EPA, in cooperation with
Ecology and TPCHD. The plan summarizes past site activities for all operable units of both the
CB/NT and CB/STC Superfund sites since 1981 when both sites were incorporated as the
Commencement Bay site. The plan also describes ongoing community concerns and outlines agency
plans for present and future community involvement.
The ag~ncies interviewed community members in 1983 to determine community concerns. and
to plan community relations activities and opportunities for public involvement. In 1987, the
agencies interviewed 30 additional persons to reassess community interest and concerns, and to
revise the community relations plan.

The most interested groups, on a continuing basis, have been local officials, the Puyallup
Tribe of Indians, loc:al businesses, loc:al environmental and citizens groups, and other federal, state.
and local agencies. The most consistent community involvement has come from a Citizens
Advisory Committee and a Technical Oversight Committee.
Media and community interest in the CB/NT site increased as the feasibility study neared\
completion, focusing on the costs, benefits, and other considerations of cleanup. At the request of
several parties, the agencies planned for a 120-day public comment period on the CB/NT
feasibility study and proposed plan. The agencies held two formal public meetings while agency
site managers met with over 20 interest groups. The public meeting transcripts are in the
Administrative Record. The Citizens Advisory Committee attracted approximately 50 people to a
citizens workshop designed to inform community members about these projects. During the public
comment period, EPA and Ecology established an information booth at the Tacoma Fire Depart-
ment Fireboat Station. Agency representatives were available at the booth one day per week to
answer questions from members of the community. During this period. the print. radio. and
television media increased their coverage of the issues.
The CB/NT remedial investigation (Tetra Tech 1985) was published in August 1985. The
CB/NT feasibility study (Tetra Tech 1988a) including the integrated action plan (PTI 1988), the
sediment quality goals report (PTI 1989), and the proposed plan were released to the public in
February 1989. Ecology and EP A have met the statutory public participation requirements of
SARA Section 117 by:
II
Establishing 5 main :lnd I: s:uellite information repositories :lnd :naking rh~
1dministrative record of site information :J.vailable 1t the T:J.coma Public Libr:J.ry
:nain 1ranC:1 i near ,he 3 i ce I

?ublisi1in~ :l notice :lnd ~riei ,:naiysis of ,he ;JroDosed plan in the Tacoma 'Jews
Tribune on :4 F~bruary [989
.J
~
Providing J. 120-day public comment period (from ~4 February 1989 until :4 lune
[989) on the proposed plan :lnd. cleanuD alternatives

;10idin~ two public meetin~s .jurin~ rhe public -:omment 'Jeriod lt ,he Tacoma
"{acht Cub. cranscriptS 01" wnien were piaced in the iniormation reposicories JnG
laministrative ~ecord
.
.J
'-':,msidering :lnG ,esponaing to .;ommentS '.yhen seiecting :he remedy. (A ..;ummary
of significant commentS and responses is included in Appendix B. Significant
changes from the proposed plan and the reasons for such changes are tlescribed in
Section 12.)
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EPA will publish a notice of the final remedial action plan in the Tacoma News Tribune and
will mail a fact sheet describing the plan to rhe mailing list of interested persons wirhin 30 days
of signing this document.
The agencies will continue to encourage public involvement and provide information about
site activities. For example, the agencies will continue to maintain information repositories to
ensure that relevant documents and information are conveniently available for public review. The
agencies also will maintain the mailing list and send periodic fact sheets describing ongoing
activities. The Citizens Advisory Committee is continuing to meet. EP A and Ecology will provide
the committee with information and attend meetings as requested. Agency representatives also
will meet with other groups of interested citizens as requested.
In recognition of the scope and complexity of the CB/NT site, EPA is establishing a Technical
Discussion Group for the remedial design and remedial action phase, and to integrate and expand
the information exchange of the Technical Ovenight Committee and Citizens Advisory Committee.
Membership of the Technical Discussion Group is intended to include the CB/NT site management
team, representatives of regulatory agencies and programs, PRPs, local government, interested
citizens, and orsanized citizens groups. The Technical Discussion Group will provide a forum for
the general review of technical and planning issues during the cleanup phase of the project.
Discussion topics may include a wide range of issues related to project statuS, planning, sediment
management and habitat concerns, health issues, and local development. It is hoped that the
Technical Discussion Group will provide EPA with valuable insight into issues of concern, and
thereby conaibute to project direction and findings. However, group input will not form EP A \
policy or determine EPA's course of action, nor will it preclude the 30-day public comment period
required upon completion of negotiated agreements betWeen EPA and PRPs for sediment cleanup
in each of the problem areas. Meetings will be scientific and technical in nature; legal matters will
not be discussed.
In addition, most source control activities will include public involvement as part of the
project implementation. For example, major source control enforcement actioDS conducted by
Ecology under the state's Model Toxics Control Act, and other actions requiring permits, will
include formal public comment periods. The CB/NT cooperative agreement with EPA also requires
Ecology to conduct community relations activities in accordance with CERCLA and the NCP.
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s. SCOPE OF RESPONSE AcnON WITHIN OVERALL SITE STRATEGY
This Record of Decision is Imal and comprehensive for two of the six operable unitS at the
CD/NT site, Operable Unit 05 (Source Control), and Operable Unit 01 (Sediment Remediation).
All six operable unitS, including the Tacoma tar pitS and three ASARCO-related projectS, are'
described in the fOllowing subsection. The purpose of CD/NT response actiODS addressed in this
Record of Decision is to mitigate or correct impacts directly associated with conrnmin~ted marine
sedimentS in the CD/NT site. The Record of Decision is therefore focused on contaminated
sedimentS, contaminant sources, impactS to marine organisms, and specific human exposure
pathways (i.e., coosumption of seafood and dermal contact with sediment). However, the CD/NT
Superfund project is not intended to address other typeS of environmental or public health
problems within the site boundaries that should be adequately covered by other federal, state,
tribal, or local programs. Problems noc within the scope of the CD/NT project include contami-
nated properties and sources within the sice boundaries thac do noc appear to impact marine
sediments.
The scope of the CD/NT response action is also distinct from other federal Superfund projects
that were originally combined in the Commencement Bay investigation in October 1981. The
Commencement Bay sice was divided into four areas: deepwacer, nearshore, tideflatS and south \
Tacoma channel. Subsequently the deepwater area was eliminated as a prioritY site because water
quality studies indicaced less severe contamination in thac area than was originally suspected. The
remaining areas have been separated into tWo discrete Superfund sites since December 1982, the
CD/NT site and the CB/STC site.
The CB/STC site, located approximately 3 miles southwest of City Waterway, includes three
projects: Well 12A, the Tacoma municipal landfill, and the Tacoma swamp. Although there is no
ap.parent groundwater connection between the tWo Commencement Bay Superfund sites, there is
a surface water link. A major storm drain network directs surface water runoff from the CB/STC
site to the head of City Waterway. However, none of the CB/STC projects are currently considered
a significant source of contaminant loading in the CD/NT site.
5.1 SCOPE AND ROLE OF COMMENCEMENT BAY NEARSHORE/TIDEFlATS OPERABLE
UNITS
Superfund response actions at the CB/NT sire are currently coordinated under six separate
oper.lble unitS. The six operable unics ~onstirure :1 ~omprehensive remedial response ~o lcrual or
:h:r~tened re!e:lSes of hazardous substances that lre :lssociated with the Tacoma car pits. che
.l,SA~CJ Tacoma $meirer. lnd :he eBI ~T marine ~nvironmenr. The ~ix C3, NT lperaOJe 'Jnics
'lre: 1 isted Jetow:
.
Operable- Unit 01 - CB/NT SedimentS
Operable Unit 02 - .-\SARCO Tacoma Smelter'
ODerable Unit 03 - Tacoma Tar ?irs
:I'
....
.
Operable Unit 04 - ASARCO Off-Property
')oerab!e 'Jon 1)5 - ,:J/NT :~ources
Operable Unit 06 - ASARCO SedimentS.
.
The CB/NT operable unitS have been' designated by EP A over the course of several years in
teSOQDSe [0 changing project needs as the agencies develop a better understanding of the overall
CB/NT site. The numbering sequence used to identify each operable unit is simply chronological.
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For example, Operable Unit 06 was established most recently. The role of the CB/NT operable
units within the overall site strategy has been redefined and adjusted by EPA management during
the public comment period for the CB/NT feasibility study, as described below. For. each operable
unit either EPA or Ecology is described as the lead oversight agency. In each case, when one
agency is the lead agency, the other acts as a supporting agency.
5.1.1
Operable Unit 01 . Commencement Bay Nearshore(fldellats SedIments
Until recently Operable Unit 01 was described as CB/NT A.reawide, which referred to the
entire site, exclusive of the Tacoma tar pits and ASARCO-related upland projects. Operable Unit
o I included response actions designed to combine both source control and sediment remediation to
address problems related to contaminated marine sediments throughout the site. Thus the CB/NT
remedial investigation/feasibility study, for which Ecology had the lead management responsibility,
characterized and evaluated sources as well as sediment problems within the site. In March 1988,
EPA and Ecology developed a management strategy designed to take maximum advantage of
agency resources during continued response actions at the site. That strategy identified Ecology
as the lead agency for continued source control effortS and EPA as the lead agency for subsequent
sediment remediation. As a result, Operable Unit 01 was redefined to include response actions
related to sediment remediation, and Operable Unit 05 was created to address source control
activities.
This Record of Decision COniums the CB/NT site boundaries described in the CB/NT
feasibility study and serves as the blueprint for funher response actions within the site. As stated
in the CB/NT remedial investigation/feasibility study, sediment contamination problems in low
priority areas of the site do not appear to warrant further action under the federal Superfund
program. Therefore, while the CB/NT site boundaries remain unchanged, continued response
actions governed by this Record of Decision are limited to source control and sediment remediation
within the priority areas defined in the CB/NT feasibility study;

Response actions governed by this Record of Decision are further limited to eight of the nine
CB/NT problem areas that were defined in the remedial investigation/feasibility study. As
described below under Operable Unit 06, a final decision regarding the Ruston-Pt. Defiance
Shoreline problem area is deferred entirely to the subsequent ASARCO Sediments (Operable
Unit 06) Record of Decision.
Oversight management of Operable Units 01 and 05 will be coordinated by EPA, Ecology and
the Puyallup Tribe. Remedial design and remedial action tasks will be tracked separately for
source control and sediment remediation. in each of the eight CB/NT problem areas addressed in
this Record of Decision. The management strategy for the site identifies Ecology as the lead
agency for source control. EPA :1S the lead agency for sediment remediation. :lnd the PUY:lilup
Tribe JS J supporting agency for continuing response Jctions with a particular focus on n:ltur:ll
iesource issues. CJoper:ltive Jgreements defining these rei:ltionships 'Nere ie:lc~ed Jerwe~n ::?\
.md ,he ?uvaJlup Tribe on Aoril :9. 1989 Jnd between EPA Jnd Ecology on June 30. : 989. These
:hree :lI~encies will share responsibility for coordination with other onl~oin~ :md related pro~rams.
JS described in Section .3.4. Enforcement Coordination.
5.1':
Opernble. Unit 02 - ASARCO Tacoma Smelter
Arsenic and IJther hazardous substances contaminate the ASARCO Tacoma smelter site. ariv:ue
':na public aropenies in rne :;urrounain~ ,,:ommunity. :nd the ::ajacent :snoreline. ~[:lCK ..:mlssions.
$iag, 1I1d fugitive dust ;rom the ASARCO taeiHty are the confirmed sources or" ~ontaminants. The
smelter operated for almost 100 years before closing in 1985 for economic reasons. ASARCO,
Inc., the current owner and former operator of the smelter, has agreed to the terms of an EPA
administrative consent order (September 1986) to CQDc1I'~t a remedial investigation/feasibility study
for me facility.
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The remedial investigation for the ASARCO facility was completed in July 1989, and the
public review draft of the feasibility study is to be completed in October 1989. Both reports
include significant new information regarding marine sediment problems near the ASARCO
facility. A Record of' Decision for Operable Unit 02, including plans for cleanup and stabilization
of the site, is expected to be completed this year. EPA is the lead oversight agency for the
ASARCO facility.
5.1.3
Operable Unit 03 - Tacoma Tar Pits
The Tacoma tar pits, an histOrical coal gasification site located near the mouth of the PuyalIup
River. was operational from the 1920s through 1956. The site is currently used as a scrap metal
yard. Contaminants including tar wastes (PARs), PCBs, and heavy metals have been found in site
soils, surface water, and groundwater. A Record of Decision for the site, completed in December
1987. called for a combination of excavation and treatment of the most highly contaminated soils,
capping of the remaining areas of the site and continued monitoring of groundwater near the site.
The site is now in the remedial design phase with remedial action expected to begin in 1991. EP A
is the lead oversight agency for the Tacoma tar pits.
,
5.1.4
Operable Unit 04 - ASARCO OW-Property
\
Federal, state, and local environmental and public health agencies have conducted extensive
studies to determine the risks associated with arsenic exposure in areas surrounding the ASARCO
Tacoma smelter. An exposure pathways study identified young children as the population most
at risk and conmminated soils as the medium of highest concern. In March 1989. ASARCO agreed
to an EP A consent order requiring the company to perfonn an expedited response action at
II publicly accessible off-property areas. The expedited response action will provide cleanup and
capping of the areas and will be followed by a. more comprehensive remedial investigationl
feasibility study of off-property problems in the surrounding area. EPA has the lead oversight role
for the ASARCO o(f -property response actions.
5.1.5
Operable Unit 05 . Commencement Bay Nearshore/Tideflats Sources
The identification and control of sources of contamination in the marine environment at the
CB/NT site is recognized as the most challenging and critical component of the overall response
strategy. Ecology's Commencement Bay UBA T has been established in direct response to this
challenge. Although the action te.am operates within a jurisdictional area that e:tceeds the CB/NT
site boundaries. its enforcement activities have focused on major sources within CB/NT priority
problem areas since publication of the CB/NT remedial investigation in August 1985. The Jcrion
ream's role in the CB/NT Superfund project is clearly defined in the cooperative Jgreeme!1t ~'or
30urce .:ontrol Jwarded co Ecology oy EPA on June 30. [989. That role :s speciiicaily :imited :0
1crivities that pose :m :lctUa! or potentia! threat to marine sediments in the ~ight problem 1reas
;overned by this Record. or Decision. ecology is the iead oversight agency (or Operaoie Unit 05
; Sources J.
5.1.5
Operable Unit f)6 . ASARCO Sediments
The Ruston-Pt. Defiance Shoreline problem 1rea described in [he feasibilitv 5tudy 1as 1een
..esi~nateQ OoeraoleJnu ;)6. This <.:han~e ~er'!ects 'leW :nr'ormatlon ~ecejved ]unn~ .ne 'Juoiic
-::omment penod. At [hat time. the agencies received as puolic comment a remedial investigation
for the ASARCO Tacoma smelter and off -shore sediments. This report included detailed new
information about characteristics, areal extent, and volume of contaminated sediments along the
Ruston-Pt. Defiance Shoreline. The agencies have reviewed this information and. believe that
further detailed analysis of remedial alternatives for this problem area is needed. The new
. information submitted during the comment period indicates that sediment toxicity problems
-------
associated with coarse-grained slag particles in tJUs problem area may be less severe than predicted
in the CB/NT feasibility study. Therefore, significant changes regarding the estimated volume of
contaminated sediments, the preferred sediment remedial alternative, and the cost of this remedy
can be anticipated.
The portion of the CD/NT feasibility study for the Ruston-Pt. Defiance Shoreline problem
area is currently being revised. Once the agencies have re-eva1uated the feasible remedial alterna-
tives for this problem ar~ EPA and Ecology will issue a new proposed plan for a 30-day public
comment period. After consideration of public commentS, the agencies will select a remedy for
the operable unit and. issue another Record of Decision specific to the CD/NT Ruston-Pt. Def'Wlce
Shoreline problem area. .
5.2 . COORDINATION OF OPERABLE UNITS OS (5qURCES) AND 01 (SEDIMENTS)

Operable Unit 05 (Source Control) and Operable Unit 01 (Sediment Remediation) are
addressed in a single Record of Decision because these tWo response activities must be closely
coordinated to ensure successful implementation of the overall site remedy. Sediment remedial
action cannot proceed until major sources of cOnrnminAtion have been controlled, because ongoing
sources could reconrnminAte clean U!tii~nt:s exposed by dredging or laid down as capping material.
Comprehensive source control as defined by this Record of Decision is essential to ensure that the
overall remediation is permanent. Consequently t source identification and control programs are
ongoing and will continue beyond the completion of remedial actions.
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6. SITE CHARACI'ERISTICS
Hazardous substances and waste materials have been released into the Commencement Bay
environment since the beginning of industrial activity in. the area. As a result of various uses and
releases of waste materials, the chemic:al quality of the waten and sedimentS in many areas of
Comme.ncement Bay has been altered. Con~minaQts found in the area include arsenic, lead, zinc,
cadmium, copper, mercury, and various organic compounds such as PCBs and PAHs.
ContaminantS in the CB/NT area originate from both point and nonpoint sources. Industrial
surveys conducted by the TPCHD and the Port of Tacoma indicate that there are more than 281
active industrial facilities in the CB/NT area. Approximately 34 of these are NPDES-permitted
dischargers, including tWo sewage treatment plants. Nonpoint sources include tWo creeks; the
Puyallup River; numerous storm" drains, seeps, and open channels; groundwater seepage;
atmospheric deposition; and spills. The TPCHD has identified approximately 480 point and
nonpoint sources that empty into the CB/NT area (Rosen et al. 1983). The netWork of channels,
streams, and pipelines discharSinS to the CB/NT site is illustrated in MSUle 3.
The primary objective of the remedial investigation was to define the nature and extent of \
sediment contamination. That investigation involved the compilation and evaluation of existing
data and an extensive field sampling effort to collect additional data. The CB/NT database
developed "during the remedjal investigation consisted of 23 data illes, each storing a different kind
of data. Data of different kinds were linked together by common identifiers (e.g., survey, station,
drainage). At the conclusion of the remedial investigation, the database contained over 25.000
records, each consisting of 15-150 separate variables. There were descriptions of over 50 surveys.
500 sampling stations, and 2,000 samples of water, solids, and biota. Over 400 components of the'
Commencement Bay drainage system had been identified. Included were data on sediment and
water column chemistry, bioassays, benthic invertebrates, f"1shpathoiosY, and bioaccumulation. All
data were subjected to rigorous quality assurance procedures before entering the database. The
distribution of sediment contaminants is described in detail in the remedial investigation report
(Tetra Tech 1985). .
There is considerable variation in the types and concentrations of chemical contaminants in
CB/NT sediments. Investigations of the nearshore waters of Commencement Bay have demon-
strated the existence of sediment contamination by toxic pollutants. accumulation of some of these
substances by biota. and possible pollution-associated abnormalities in indigenous biota (Crecelius
et a1. 1975; Riley et a1. 1980. 1981; Malins et a1. 1980. 1982; Gahler et:li. 1982: Tetra Tech 1985.
1988b: P:lrametrix 1987). The highest ~onc~ntr:1tions of ~~rt:lin met:1ls (i.e.. Jrsenic. ~opper, !~:ld.
Jnd mercury,! have been found in sediments in the w:1terways. Jlong the southwest shore. Jnd ne:lr
:he .-\SARC:J smelter. Seaimenc .;onraminatlon JY ;J~rsi$tenc ')rg:mlc ..;omcounds f ~.g.. ?C3s i was
jetected ~n ,he heavily industrialized waterwavs : e.g.. nylebos Waterway) :md Jlon~ the ~usron-
:'t. :Jet'iance Shoreline.
During the CB/NT remedial investigation. four inorganic :lnd six organic contaminantS were
jetected J[ concentrations 1.000 times JS great JS reference conditions (i.e.. .:onditions in sedimentS
:"rom :1onmaustriaJizea Jreas i)f ?uget Sound), Those .:oncentrntions ',vere detected tn samples ;'rom
~tations :oc:1ted off ,he Kusron-?t. Defiance Shoreiine. Hyiebos 'Vaterway. :lnd St. Paul Waterway.
~'.Venty-~i~ht .:hemicals or:hemical ~roucs had:oncentTations 100-1.000 times 1S '~re:1t 1S
-~!erence ';onaitions. ':0ntaminants ,)t' .:anccrn ;nc!uue :net:lIS . e.:;.. ~rsentc. .e:la. :nerc:.:.r'!. .::nc:.
?C3s. Jna ?AHs.
Sediments in many parts of the CB/NT area contain concentrations of one or more toxic
contaminants that exceed levels commonly found in Puget Sound reference areas. During the
remedial investigation, :r mulristeu decisiou-makiug process was used to I) define problem
sedimentS and identify areas containing problem sedimentS. 2) identify problem chemicals. and 3)
-------
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---- Plp.I'.1 or Cla.ed
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-------
identify problem areas for remedial action evaluation. This process resulted in the identification
of 11 high priority problem are:LS. which were subsequently consolidated into 9 are:LS (see Figure I).
The Ruston-Pt. Defiance Shoreline has been recently established as Operable Unit 06 (ASARCO
Sediments) reducing the number of problem areas addressed in this Record of Decision to eight.
. In the following section. the characteristics of sediments and sources in each of these problem
areas are described. FigureS present the estimated extent of conrnmination for each problem area.
As indicated in the figures, the depth of contamination varies. For the purposes of volume
calculations, average depths ranging from 0.5 to 2.5 yards have been utilized. Source control
activities are planned, underway, or completed for many of the sources in these problem areas.
Details of the status of these activities are presented in Appendix C and the integrated action plan
(PTI 1988).
6.1 HEAD OF HYLEBOS WATERWAY
Contamination in sediments at the Head of Hylebos Waterway is attributed to a broad range
of sources including chemical factories, log sorting yards, landfills in the Hylebos Creek drainage
basin, and storm drains.
Sediment Characteristics-Three chemicals were selected as indicators of the most severe
sediment contamination: arsenic, HPAHs, and PCBs. Approximately 381,000 square yards of
sediments at the Head of Hylebos Waterway exhibited chemical concentrations that exceed cleanup
objectives. Implementation of source control, measures was predicted to reduce this area to
approximately 217,000 square yards after 10 years (Figure 4).
Source Characteristics-Locations of existing industries and businesses in the vicinity of
Hylebos Waterway are presented in Appendix C. Kaiser Aluminum and Chemical Corporation was
identified as the major source of HPAHs in sediments at the Head of Hylebos Waterway (Tetra
Tech 1985, 1988a). HPAHs were associated with the historical onsite disposal of wet scrubber
sludge waste generated during air emission controls. Pennwalt Corporation was identified as a
major source of arsenic (associated with arsenic pesticides), chlorinated hydrocarbons, and low
molecular weight pOlycyclic aromatic hydrocarbons (LPAHs) in sediments at the Head of Hylebos
Waterway (Tetra Tech 1985, 1988a). Groundwater seeps and the main outfall are the major points
of arsenic release from the facility. Loading calculations indicate that groundwater seeps and the
main outfall are the major sources of chlorinated hydrocarbons. General Metals of Tacoma. Inc.
was identified as a potential source of PCBs in the Head of Hylebos Waterway. An ongoing source
of PCBs was not identified during the CB/NT remedial investigation (Tetra Tech 1985); however,
J subsequent reconnaissance survey t'ound high levels of PCBs in c:uch basin sediments :It G~ner:J.I
'vfetals (Stinson et a1. 1987).
various sources have been associated with metal contamination. Lug sorting yaras that have
Qeen identified. as sources Ot' Jrsenic. .:opper, tead. :lnd :inc :n the 1e:1d or' Hylebos 'Vaterwav
I Tetra Tech 1985. i 988al include the 3009 Taylor Way log sorting yara. Cascade Timber Yard ==2..
Wasser Winters log sorting yard. Jnd Louisiana-Pacific log sortin~ yard. ASARCO smelter slag
:lSed as bailast for many of ;he lo~ sOrtin~ yards is the original source of the metals. Surface water
~unoff has 'Jeen identified JS the !nechanism by ',yhich metals were :ransoorted co :he ~lajacent .
;ediments (Norton ~nd Johnson: 985).
3&L :"':lI1afiil .~na USG ~:::.nafii1 ! t'ormerlv :J.S.JVpsumJ \Vere :lSSOCl:uea 'vl£h ::rscnl~. .:ooper.
Jna ieaa in :>eaiments Jt :he Heaa 'Jr' nyiebos Waterway. Leachate Jna runorf r.rom ,l1e sites
transport metals to Hylebos Creek, which discharges to the Head of Hylebos Waterway. The fill
at B&L Landfill consists primarily of soil and wood waste scraped from the log sorting yards.
ASARCO smelter slag, which was used as ballast at the log sorting yards, is probably the original
sou~ of the ~ls. Arsenic from USG Landfill was attributed to me dispos:LI of bag house dust.
-------
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indicator Chemical.
AT PRESENT
DEPTH(vd)
AREA(~2.
VOlUME (~3 .

IN 10 YR
DEPTH (yd.
AREA (~2)
VOlUME (~3)
1
381.000
381,000
1
211.000
217.000
.
FEASIBILITY STUDY SEDIMENT
PROfLE SURVEYS (1888.

SEDIMENT SURVEYS CONDUCTED
IN 1884
.
.
SEDIMENT SURVEYS CONDUCTED
BEfORE 1984 (187...1881.

PCB (AET '" 150 ..gAls.
~
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HPAH (AET . 17,000 "gAls.
ARSENIC (AET . 67 mgAIg.
~i91U u ~'t)u~illlenb Lil '~;~ ;Ioad of Hylebos Waterway' not ~eetlng sedJ~ent quality obJectlv8fi for Indicator chemicals at
p,-i;56nt aud 10 year:) after Implementing feasible source control

- --. -. - ~ _.- _.. .-.
-------
o
Tacoma BoatbuiIding Company may be associated with problem metals in sediments at the Head
of Hylebos Waterway. Metals from the site probably originated from sandblasting and painting.
Several storm drains may discharge contaminants to the Head of Hylebos Waterway. The
most important of these are East Channel, Morningside, and Kaiser ditches. In general, problem
chemicals associated with these drains are poorly characterized, and the relationships among
activities in the basin and problem chemicals observed in the V!dimencs near the points of discharge
are not well understood.
6.% MOUTH OF HYLEBOS WATERWAY
Sediment Characteristics-PCBs and hexachlorobenzene were selected as chemical indicators
at the Mouth of Hylebos Waterway. Approximately 393,000 square yards of sediments exhibited
chemical concentrations that exceed cleanup objectives in this problem area. Implementation of
source control measures is predicted to reduce this area to less than IlS,OOO square yards after
10 years (Figure S).
Source Characteristics-Occidental Chemical Corporation is the major source associated with
chlorinated organic compounds, the major class of problem chemicaJ.s found in sediments at the
Mouth of Hylebos Waterway. The locations of existing industries and business are provided in \
Appendix C. Groundwater seeps and the main plant outfall transport chlorinated organic
compounds to the adjacent sediments. Loading calculations indicate that groundwater seeps are the
most important sources (Tetra Tech 1985). Chlorinated organic compounds in groundwater are
attributed to the historical disposal of wastes from solvent production in unlined lagoons on the
site (Tetra Tech 1985, 1988a). Chlorinated organic compounds in the main outfall are associated
with effluent from the chlorine stripper. The main outfall is classified as a major industrial
discharge under the NPDES program.
6.3 SITCUM WATERWAY
Sediment Characteristics-Copper and arsenic were selected as chemical indicators of the
most severe environmental contamination associated with biological effects. Approximately
167,000 square yards of sediments in this problem area exhibited chemical concentrations exceeding
cleanup objectives. Implementation of source ~ontrol measures is predicted to reduce this Jrea t.o
less than 66.000 square yards after 10 years (Figure 6).
Suurce C:ulr:1c:eristics-Cunt:lmin:Hion :n :he sediments .)1' Sitc:Jm 'V:aerwJY :s Jttr:cured :0
'Jre loading facilities lnd <;torm ,irains. The iocations 1)1' existing industries. businesses. lna
iischarges are. providea in ,->.,ppenaix C. The POrt 1)[" Tacoma Terminal; ')re :oauing :':lcliity
: wnicn :nc1udes Storm Drains SI- i 68 :lnd SI-169) is :lSsoci:lted particularlY with metai ..:oncamina-
cion in the sediments of Sitcum Waterway. Ore spilled durin~ unloading 1nd transfer uperations
lnd runoff trom che site :lre che sources 01 ,he meta1s. Spilled ore is no lon~er washed into the
Naterway but instead is .;ollected in J. ;jWeeDer truck lnd soid to ~melters.
:-Jumerous 5torm drains dischar~e to Sitcum Waterway. Storm Drain 51-17::. :he !ar~est
~~rvin~ :Dproximateiy ,70 ,c:cs I. 1as iieen :uencir'iea:s :he "ource )1' :nost Jr' 'ne 'ne!J.lS
.;;)ntnouted by 3torm 'lrains 1 Tetra Tech! 985). Storm Dram 31-172 is 'Jne ur" (ive major 3tOrm
drains discharging to Commencement Bay waterways th:lt is included in the pollution control effort
underway by the city of Tacoma under a memorandum of agreement betWeen the city, TPCHD,
and Ecology. Other storm drains potentially discharge conrnminants to Sitewn Waterway via runoff.
. The mOSt important of these is Storm Drain sr~ 176, which may contribute remaining waste materia!
from the Milwaukee railroad yard located in its drainage basin. In general, problem che.nicals
-------
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'\ i
.J
AT PRESENT
DEPTH (rd)
AREA (ydi!)
VQ.UME Ivct3 t

It 10 YR
DEPTH (vd)
AREA (rd2)
VOLUME (vd3 t
2
115.000
230.000
AT PRESENT
2
383.000
786.000
2~
.
f~SIBUTY 81UDY SEDIMENT
Pf\OfLE SURVEYS (1886t

S~D"'ENT SURVEYS CONDUCTED
IN 1 884
.
.
IU 10 VH
.
S~OIMENT SURVEYS CONDUCTED
BEFORE 1984 (187a-1881t

PCB. (AET . 150 I1pg)
~
~
HEXAGLORCBENZENE (AET .221'9"'9)
.
~t;Jjllleub dt till; Mouth of Hylebos Waterway not meeting sediment quality objectives for Indicator chemicals at
-------
--...-.------
I
I
/

I.
Slicum Waterway
indicator Chemical.
A I "III,:,i:'fl
~


.. '-
.. '\
IN 10 YR
AT PRESENT
DEPTH (wd)
AREA ()'d2)
VOlUME ()'d3 )
.. 10 VR
DEPTH (yd)
AREA ()'d2)
VOlUME ()'d3 )
1
161.000
161,000
,
,
I.
~-"
\:'"
'" -.J
.
1
66,000
66,000
...'
~
~ .:.;..

yAA~jf~~il~!.. .


,,,. ~...-t.. . ...



:~~~}ij~.;'i' r....
. .:


~~;~llj
.
 . FEASIBILITY enJDY SEDIUENT
  PROFILE SURVEYS (1886)
 . SEDIMENT SURVEYS CONDUCTED
  IN 108-4
 . SEDIMENT SURVEYS CONDUCTED
. BEFORE 11184 (1878-1881)
 ~~J.#MM ARSENIC (AET . 51 .11)
 r:2m COPPER (AET . 390 mg.1Ig)
. '. t
 . BiOlOGICAL EFFECTS OBSERVED
 FOR NON-INDICATOR CO&.tPCUIDS
@
~ . '4
L -.=--..--1..1
~.,,~......
J IW
1~I'd ILLh(ltJlJdd)
~Fi9-IHU ~. - ~uJjlllent:) ill Sitcum Waterway not meeting sediment quality objectives for Indicator chemicals at present and
'0 YcliU~ i.tH,;r ililplementing feasible source control /

l
-------
associated with these drains are poorly characterized. and the relationships betWeen activities in the
basin and problem chemicals observed in the sedi"ments in Sitcum Waterway are not well
understood. '
6.4 ST. PAUL WATERWAY
SedIment Characteristics-Problem chemicals in St. Paul Waterway were mainly organic
chemicals. 4-Methylphenol was selected as an indicator chemical. Approximately 118,000 square
yards of sediments exhibited levels of 4-methylphenol that exceeded cleanup objectives. Contami-
nated sediments were capped in place in 1988. Habitat restoration in the intertidal zone was
conducted during capping operations.
Source Cbaraderistks-Htorical discharges from what is now known as the Simpson Tacoma
Kraft pulp mill was the major source of problem chemicals found in the sediments of St. Paul
Waterway. The locations of existing businesses, industries, and discharges are presented in
Appendix C. The primary historical source of contamination from the site appears to have been
effluent from the wastewater treatment system. Extensive remedial action has occurred at the
Simpson facility. In-plant process modifications that improved effluent Quality and relocation of
the secondary treatment outfall were completed in September 1988. Relocation of the outfall and
consequent increase in the dilution ratio are predicted by Simpson to virtually eliminate sediment
accumulation of any problem chemicals that have not been removed from the effluent stream by
in-plant process modifications. Monitoring results will be used to verify this prediction.
6.5 MIDDLE WATERWAY
Sediment Characteristics-Mercury and copper were selected as chemical indicators of the
most severe sediment contamination. Approximately 126,000 square yards of sediments in this
problem area exhibited chemical concentrations exceeding cleanup objectives. ImpJementation of
source control measures is predicted to reduce this area to less than 114,000 square yards after
10 years (Figure 7). .
Source Charncteristics--Contamination in the sediments of Middle Waterway is attributed to
maritime industries and storm drains. The locations of existing industries. businesses. and
discharges are presented in Appendix C. ' Land use in the drainage basin is entirely commercial
:md industrial. Marine Industries :'-iorthwest and Cuoks y[arine Specialties are the two 5hipyards
JSsociated with problem metals in sedimentS in Middle Waterway (Tetra Tech t 985. 1983al. \'Ietals
:'rom ,hese sites :.lre ;)robably Jerived rrom 5andbi:.lstin~ :.lnd painting. Both ,ites .lre :\J..::.teu ,~n
prooerty previously occupied by Foss Launch 'lnd Tug Jnd by Peterson Boat. 'vhere ~imiiar
'.:.ctivities were conaucted datjn~ back w the i 900s. The largest ot" :ne storm Jrains Cijscnar~lOg :0
.'lIiddJe Waterway is Storm Drain MD-lOO. which Jrains an area of approximately 30 ;lcres :nd
qischarges to the head of the waterway. Storm Drain MD-ZOO has been identified :lS a probable
,ource 0f :Jroblem organic chemicals in the head ot" the waterway. Several other storm ,jrains
discharge to :vtiddle Waterway. In 3enerai. problem chemicals Jssociated with these Jrainslre
poorly ';haracterizea. Jna the relationsnips '.lmong :1ctivities in :he ;)asin ~,nd problem <.:;,emicals
,)bserved in the sediments in Vliddle Waterway 'lre not weil understood.
6.6 HEAD OF CITY WATERWAY
Sedimmt Cbancterlstic:fPAHs, c:rdnrium. le:Id. and m~ry W~ selected JS chemical
indicators of the most severe environmentaJ contamination associated with biological effects.
-------
__4. ..--",,--.-- .. __a.
(
"'>
0\
~

l~)tW~'jJH~\\
~ l ~ 1~:,'!-' ~ ,'.~"!:I: . ,;,:/i
1.~4..~- f ,f~,,,,,:,.:-!: ..}
W];wr rj~t~f(i~,
S v.~;d;j.
\)':;..."
AI """"" ,:/;~
It 10 YR
@
" .~
L.. ........... .1
~~......"
. '6>
1..~..IU~I(lUUd
-------
Approximately 230,000 square yards of sediments in this problem area exhibited chemical
concentrations exceeding cleanup objectives. Implementation of source control measures was not
predicted to effect rapid natural recovery (Figure 8).
Source Characteristics-Contamination in the sediments at the Head of City Waterway is
attributed to storm drains, maritime industties, and electroplating facilities. The locations of
existing industries and businesses are presented in Appendix C. American Plating was identified
as the most likely source or nickel conrnmln~tion in a small area along the east shoreline of City
Waterway, but appears to be a minor or negligible source of other metals in the waterway.
Electroplating operations were conducted at the site between 19S5 and 1986. The major mechanism
transporting onsite contamination to the sediments is probably surface water runoff. Martinac
Shipbuilding was associated with problem metals (especially copper and zinc) in sediments at the
Head of City Waterway (Tetra Tech 1985, 1988a). Martinac, which has operated at the site since
1924, is involved primarily in design and construction of large commercial vessels, and some ship
repair work is also conducted. Metals from the site are derived from sandblasting and painting
operations. The Tacoma spur highway construction site is potentially associated with aromatic
hydrocarbon contamination (i.e., PARs, benzene, toluene) at the Head of City Waterway. A
previous study (Hart Crowser 1984) reported extensive groundwater contamination at the site;
however, the source of this conrnmination is unknown. Other potential sources of groundwater
hydrocarbon contamination include an abandoned gasoline station at Puyallup and A streets, an
equipment storage yard, a coaJ- and wood-powered electticity generating plant, and petroleum
product and storage tan.Ia (Tetra Tech 1988a). \
Gradients in the concentration of contaminants in the sediments as well as known historical
disposal practices indicate that the Nalley Valley and South Tacoma storm drains are major
historical and possibly ongoing sources .of organic matter and metals (e.g., lead) in the Head of
City Waterway. The Nalley Valley storm drain serves approximately 2,800 acres to the south and
east of the waterway. Commercial and industrial development in the basin is concentrated around
the Interstate-5 and South Tacoma Way corridon. The South Tacoma storm drain serves 2,200
acres directly south of the head of the waterway. Land use in the basin is primarily residential,
with commercial development concentrated in the northern portion of the drainage basin near the
Interstate-S conidor. These two storm drains are included in the ongoing pollution control effort
underway by the city of Tacoma under the memorandum of agreement betWeen the city of Tacoma.,
TPCHD, and Ecology. The Tacoma sewer utility is evaluating the feasibility of settling basins to
control contaminant discharge from these drains. Storm Drain CI-230 serves approximately
530 acres consisting of a large part of the downtown Tacoma business district and a portion of the
residential section west of the business district. Storm Drain CI-230, one of five major storm
drains discharging to Commencement Bay waterways, is included in the ongoing pollution control
effort implemented by the city of Tacoma under the memorandum of agreement between the city
of Tacoma. TPCHD, and Ecology. Numerous other storm drains discharge to the Head of City
Waterway. In gener:1l. problem chemicals JSSociated with these dr::lins :lre poorly ;h:lr:lcteriz~d. :lnd
,he iel:ltionshios among. :lctivities in ,he basin :lnd probiem ,..:hemi<'::lls in ,he ~ediments lre noc ....d
understOod.
6.7 WHEELER-OSGOOD WATERWAY
3~iment Clarncteristics- The ~ntire :lrea .>t' Wheeler-Osgood Waterway, .lpproximateiy ::.000
square yards. contained oroblem chemicals in concentr::ltions that e:'Cceed cIeanuo objectives.
:moiementatlon ,)r" '.:ource .;omrols ;s .,Ot jredicted :0 ~r"fect .j~nifi<.::.nt :1atural-ecOverv v1Chin
:0 :;ears ;. Figure '». nPAHs :1Od :inc .,vere :;electea lS ..:hemicai indic:.tOrs 'Jr" .:ne .nost :ievere
sediment contamination.
~ Clta.l4lcteristfG-Storm Draill CW-2'4 is nn, major source associated with problem
chemicals in the sedimentS of Wheeler-Osgood W:1terway. It is likely that problem chemical
-------
w
00
~
---...
~I I'HI:;'lOUf
! ~.- .._~ 'hi
~.- "~'I.~,.
)(.)
~Y"'"8
j ~11i' f udl( HiUU..j
"-..,
", '. .
'- .'
'(c' .
\\3 i,:
: I:::: .- ,
. 1~~-=';"1
r';--;'~ I
t .' ~~ ~ IlfAU Of ClfV
9.._:~:~:?t -- '--"

. . "J' ~1'-- - -----' .~~ -
.: :1'. I
':,' -t'
. I
ill, II )

,~~J. ':~"'j
h" "1>:'
.~,~~ :;" ~
:; 'f:; J
:;i/,:./
~r.~l
~lM'
t:,':'l(
. :.:
'. ~.
4- '.',
'~ l"jl
M ",- - --- ,-
IN 10 YR
Head 0' CIIV WaterwaV
indicator Chemical.
AT PRESENT
DEPTH (wd)
AREA (wd2)
VOUJME (wd:t )
.. 10 YR
DEPTH (~d)
AREA (~2j
VOlUME (yd3 )
2.5
230,000
675.000
2.5
171.000
426.000
.
FEASIBILITY STUDY SEDIMENT
PRoFILE SURVEYs (1886)
SEDILfENT SURVEYs CONDUCTED
"'884
.
.
8EDILfENT SURVEYS CONDUCTED
BEFORE UI84 (187e.1881)

HPAH(AET.. 17.000flg.tlg)
fWZ2J
fi':{iHWH
MERCURY (AET . 0.68 mg.1lg)
CADMIUM (AET . 6.1 mg.1lg)
f.!?~> J]
.." a.... .
~
~
LEAD (AET ; 450 mg.1!g)
"
';"d;","lIlo ullllU I load 01 City Waterway nOI meeUng sediment quality objectives lor Indicator chemicals al
-------
- ~--
-,
j
~ -:
" .:-
J.IIII":>llll
\\5 t) .
'\; "-
\6- (
W. t.~
. ~-_.---
... . .----.:~
., Wilt U ER.
. OSGOOD
'1
I. II _I

\:-1f1
) J
~ I,
\ If
\ \\
~ \
~.
\D
~
t. ~....~I"I
p'''' -""'.'.
I 1<-,
1..1. o. T "'~lp~UII...)
--. ..-.-..--
~"'"-
..
Wheeler-Osgood Waterway
indicator Chemical.
AT PRESEIfI'
DEPTH (Vd)
AREA (wd2)
VOlUME (wd3 »

.. 10 VR
DEPTH .wd)
AREA 'Vd2»
VOlUME 'wd3 »
. .
05
22.000
.. .000
IN 10 VR
0.5
22.000
.. .000
.
fEASIBILITY STUDY SEDIMENT
PROfILE SURVEYS (1886)

SEDIMt:NT SURVEYS CONDUCTED
IN 1884
.
.
SEDIMENT SURVEYS CONDUCTED
BEfORe 1884 (1878-1881)

HPAH,AET" 17.000 pglkgl
~
I t:::::::::::::?1
ZINC(AET" 410mgAlg)
::i1.;lJullelll:. III Wlludo(.Osgood Waterway nol meeting sediment quality objectives for indicator chemicals at
-------
discharge was mainly historical. In the past, process wastes from Carstens Packing Company, a
slaughterhouse and meat packing plant, were discharged direcdy to the waterway. [ndustrial
facilities active in the drainage basin include Hygr:lde Food ProductS Corporation, Rainier Plywood
Company, Kleen Blast, Northwest Container Corporation, Inc., and Chevron USA Incorporated.
Storm Drain CW-254 is included in the ongoing pollution control effort implemented by the city
of Tacoma under the memorandum of agreement betWeen the city of Tacoma, TPCHD, and
Ecoloay. .
6.8 MOUTH OF CTY WATERWAY
Sediment CharacteristiCS-An estimated 27,000 square yards of sediments at the Mouth of
City Waterway exhibited chemical concentrations exceeding cleanup objectives. Implementation
of source controls is predicted to eliminate this problem area entirely within 10 years (Figure 10).
HP AHs and mercury were selected as chemical indicators of the most severe sediment contamina-
tion. .
Soan:e Charaderisdc:s-Connmin!ltion in sediments at the Mouth of City Waterway is
attributed to petroleum stOrage facilities and unknown sources. The locations of existing industries
and businesses are presented in Appendix C. The D Street petroleum facilities are an identified
source of LPAHs in the Mouth of City Waterway. and they are the only identified source of
problem chemicals in the waterway. Potential sources of other problem chemicals (e.g., mercury
and HPAHs) in this portion of the waterway have not been verified (e.g., marina operations on the
west shoreline). At the D Street petroleum facilities, spills and leakage of petroleum product have
led to the groundwater COD~min!ltioD. Intermittent seepage of petroleum product has been observed
along the City Waterway embankment since the early 19705. An interceptor trench was installed
in late 1987 to mitigate offsite transport of floating product.
-------
\
~
\
.
. ~.
') !.....
\(. j .'
,..
"IP..(;;I;.III
~
.
L--~.~I...
a=.=-.'t ""_I'
. au
1..11..1 rULlltl~dtl.1)
.....---.
., ~
~
1:'
I
./

",

\-{\ 1
1 J
\ I!'
\ \
\
-..
...
. -.--'
.. 10 YR
.
. .
Mouth o. City Waterway
indicator Chemical.
ATPRESENJ
DEPTH Iwdl
AREA Iwd21
VOlUME (wd31"
.. 10 VR
DEPTH Iwdl
AREA (yd21
VOlUME (wd3)
1
21.000
21.000
1
o
o
.
fEASIBILIlY STUDY SEDIotENT
PROFI.E SURVEYS (1186t

SEDIMENT SURVEYS CONDUCTED
1N18j.4
.
.
SEDIMENT SURVEYS CONDUCTED
BEfORE 1884 (f878-1881t

HPAH (AET - 17,000 Jlw\91
~
.
BIOlOGICAL EfFECTS 08SERVED
fOR NON. INDICATOR COMPOUNDS
c:i91_1I~ I; ~:W(jillldlib LJIIIII; Moull. 0' City Waterway not meeting sediment quality objectives for indicator chemicals at
pi (;~UI,t iJlld I fj ~/I:aJ:j altor implementing feasible source control

-------
,
...
7. SUMMARY OF SITE RISKS
CERCLA re5I)ODSe actions at the CD/NT site as described in this Record of Decision are
intended to protect the marine environment and human health related to the marine environment
from current and potential exposure to hazardous substances at the site. To assess these risks at the
CB/NT site; human health and environmental risk assessments were conducted as part of the
remed.ia1 investigation. The risk !I~~nts were used in me ~u.1 investiption to characterize
the magnitude of risks associated with eXl)Osure to contaminated sediments and to prioritize areas
within the CD/NT site for remedial action. The results of the risk assessments were also used in
the feasibility study to develop sediment cleanup guidelines to protect human health and the
environment.
Releases of hazardous substances to the marine environment at the CB/NT site have resulted
in conmmination of bottom sediments in the waterways and alonl the Ruston-Pt. Defiance
Shoreline. The human health and environmental risk assessments are based on exposure of marine
bioca to CODmmin~ted sediment and exposure of humans to conftlminated seafood. Risks to marine
bioca were estimated based on field and laboratory testing of sedimentS at the CD/NT site. Human
health risks were estimated by assessing the potential for health impacts caused by consumption ofl \
local seafood containing contaminants also found in sediments.
7.1 HUMAN HEALTH RISKS
7.1.1
General Strategy
Human health risks from seafood consumption at the CD/NT site were evaluated in a tWo-
phase process:
1.
Baseline human health risks were estimated for chemicals detected in fISh and crob tissue
samples from the CB/NT site and a reference area. These analyses were used to identify
chemicals that accumulated in organism tissues and resulted in significant risks to seafood
consumers. Chemic:1ls posing signifiC:1Dt risks were identified by c:liculating c:ucinogenic
risk levels or by comparison with EPA.s acceptable daily int:1ke (ADO values. Risks of
seafood consumption at the CB/NT site were also compared with risks of seafood
consumption in :m uncontaminated reference area. Carr [nlet. Chpmicals posing risk
levels ~t the CB/NT site th:1t were 3imil:lC to those at the reference area wer~ !1r,
.:onsidered for further site deanUD ~vaiuation (i.e.. it was not ..:onsldered f~:lsicle
,;:eanup co iess .-han reference :eveis I.
..
'::.emicals Dosin~ signific:mt risks were r"urther ~' aiuated f'or determinatJon or' ';ediment
;le:mUD leveis chat wowd reduce site risks co acceDtable levels. ;:'or :hese :ll1:uyses. :lssue
concentrations of contaminantS in fish from the reference :uea were selected :lS the target
,;eveis. Therefore. the ,)bjective of :his phase of (he risk JSsessment ',vas :0 :aenuf"
,edimentJuatity 'evels :hat ',vould cesuit in :he :lttainment ,)t' ~eierence :evels )f':ish
:lssue ~ontamination.
~;1e 'lOtaKe ,)I' :ontaminants :'1 :J/NT :Ice :e:J.t'ooa 'vas ~\':l.luatea~\' ,;hemic:l :n:J.I\'sis Jf'
:hree kinas or' tissue samples: Znqlisn 50[e muscle tissue I i.~.. r'iiletsl. En~lisn sole :ivers. .lna ..:r:J.o
muscle tissue (legs and body meat). English sole and crabs were selected for study because they
live near the bottom in close association with contaminated bottom sedimentS. Although other
species may have higher or lower COQr~min~nr levels in some parts of Puget Sound, English sole
provide a 1 epl eseiltati~ measure of contaminant uptake b.y fishes and were present in large
numbers in the CB/NT study area. Fish liven are probably e:1ten by only a very sm:lil number of
-------
anglers. However, the uptake and retention of contaminantS in fish liver tissue is much higher
than in muscle tissue. Thus, the use of combined muscle tissue and liver tissue data was also
appropriate as an assessment of maximum potential exposures to a small part of the :lI1gling public.
1.1.2
IdeDtUJc:atioD. of Chemica1s of CODcem
Contaminants of concern were identified by evaluating the concentrations in CB/NT biota
and by a comparison of concentrations in seafood organisms from an uncontaminated reference
ar~ Carr Inlet. Of the more than 100 chemicals analyzed for in CB/NT biological samples, only
16 organic chemicals were detected in English sale muscle tissue. Eleven organic chemicals were
measured at sufficient frequencies and concentrations to be subjected to further evaluation:
tetrachloroethene, ethylbenzene, hexachlorobenzene, 1,3-dichlorobenzene, hexachlorobutadiene,
naphthalene, bis(2-ethylhexyl)phthaJate, di-n-buryi phthalate, di-n-ocryl phthalate, DDE, and
PCBs. Metals were detected in all samples, but the concentrations in CB/NT biota were similar to
levels measured in Carr Inlet samples. However, arsenic was identified as a chemical of concern
because of its widespread contamination of CB/NT sediments and because it is a suspected human
carcinogen, even though it was not measured in biota at statistically significant levels above
reference conditioDS.
PCBs were the most frequently detected chemicals in English sole and crab samples from the
CBINT site. For English sole, there was coDSiderable variability in PCB concentrations among the
waterways (Figure 11) and within the waterways. Maximum PCB levels in English sole muscle\
tissue were measured in Hylebos Waterway (1,300 JJg/kg wet weight). Sole from Hylebos Waterway
had an average PCB concentration of 332 JJg/kg wet weight. This average level is approximately
an order of magnitUde higher than the PCB concentration measured in English sole from Carr Inlet
(36 JJg/kg wet weight). Other organic chemicals displayed more localized contamination in CB/NT
biological samples and were generally less elevated with respect to Carr Inlet samples. For example,
hexachlorobenzene and hexachlorobutadiene were detected only in English sole from Hylebos
Waterway at concentratioDS similar to the analytical detection limits (10-40 JJ8/kg wet weight).
1.1.3
Basellne Risk Assessment
The baseline risk assessment described. in the CB/NT remedial investigation included a site-
specific exposure assessment. The exposure assessment for consumption of fish and crnbs from the
CB/NT site included two elementS: I) estimating the exposed population, and Z) estimating the r:lte
of fish and crnb consumption. A survey conducted by TPCHD (Pierce et a1. 1987) indicated that
there are 4.070 shore and boat anglers in the Commencement Bay are:1. The aver:1ge family size
of the angler group was estimated at 3.74 persons. Thus. assuming that all members of a family
~at the lngler's c:1tch. the total exposed population would be lppro:tim:1tely 15.":00 ;Jersons.
rniormation on the lverage catch per trip lnd t'requency 01 lngling trips indicated chat fish
::Jnsumptlon rates '/ary considerably lmong the ~:'(oosed ;Jopuiation. Estimated..:ansumpt:un -:tcS
~:lD~ea :.rom ! oound/year II.: grams/day) .0 1 pound/dav (~53 ~ramsiday). Aoproximateiv
).: :ercent 01. ,ne exposea ;Jopulation I i.t:.. :0 persons I ..vere cstimatea co .:onsume Cummencement
3ay t.isn It the very high rate 0I" l pound/day (453 ~rams/daYJ. I)niy :.lDout 7 percent aI' (he
~xposed pooulation consumed greater than 1 pound/ month (15 grams/day). Therefore. lbout
)3 jercent or" ~he exposed group consumed I 'Jound/month or less. These tWO consumption rates
.vere '.1sea JS ~stimates ,)t' ~) che :t1aximum 'Jotenuai ~xoosure ()r" 1 very ~m:1ll oart :)1. .he "oouiauon
,I ;)ouna/daYJ, :ma .:) the :naximum ~xposure ,ate ~xperienced :JY l1ign percenta~e ,j(' ~i1e
,ooUlation I I ,ound/month)' !n .:omo:1rison. 1 more recent >urvev ,)r" se:1iood ,.:onsumotion
'!1rou~nou[ ?tl~et :~ouna Tetra ~t.:Ci1 : c)R8bl ;naic:ltes :hat ~he :ne:m .;onsumorlOn -::[e S :OOU[
).027 pounos/day 112..3 srnms/aay) lnd ,he <-)5tn percenuie ..:onsumpuon ..lte :s about 0.":! ,Jounosl
day (95 grams/day).
Health risks were estimated for consumers of CB/NT fish and shellfish on a chemical-by-
cnemicaJ basis for c:arc.inosem (e.g., ~ met arnmic) and noncarcinogem (e.8.. co~ and
mercury). For c:1J'cinogens, risks were calculated by multiplying EPA's cancer potency factor for
-------
TOTAL POLYCHLORINATED BIPHENYLS (PCBs)
.,
 -
~ 
J: 
0 
u; 
~ 
~ -
w 
~ II
at 
, 
~ 
 100
o
HY
BL
51
MI
SP
Me
a
AS
CR
Tetra Tech (1985)
. AREASSTAT1ST1CALLV OIFFERENT FROM REFERENCE (P
-------
each chemical by the estimated intake of that chemical. The resultant individual lifetime cancer
risks are expressed in scientific not:ltion (e.g.. IxIO~). An estimated risk of IxIO~ indicates that.
as a plausible upper bound, an individual has a one in one million chance of developing cancer
as a result of site-related exposure to the carcinogen over a 70-year lifetime (under the specific
exposure conditions assumed at the site). EPA gener.illy considers excess risks in the range of 10~
to 10.7 as acceptable; however, the 104 level is used as a point of departure for setting cleanup
levels under CERCLA response actions when promulgated criteria are not available. Potential
concern for noncarcinogens was evaluated by comparing the estimated lifetime intake rate of a
chemical with EPA's ADI value for that chemica1.
The iU'St step in the risk assessment as described in the CB/NT remedial investigation was to
calculate the individual lifetime risks for ingestion of carcinogens in iIsh muscle tissue. For the
purposes of this risk assessment, the average concentration of each chemical in English sole from
the study area was used to calculate exposure. Based on thes~ calculations, only six chemicaJs were
predicted to result in a risk >104 at the maximum fISh consumption rate of 1 pound/day (Table 3)
and only PCBs and anenic had predicted risk levels greater than lxlO~. At a fISh consumption rate
of 1 pound/month, only PCBs and arsenic would exceed the 10. risk level.

For PCBs and arsenic, the risks of consuming crabs from the CB/NT site were approximately
the same as the risks of eating fish. All other carcinogens measured in crab muscle resulted in
predicted risks less than 104 at the maximum consumption rate of I pound/day. No site-specific
data were available for crab consumption rates. Therefore, the consumption rates for fish were
used in the crab risk assessment. ,
Consumption of PCBs in fish liven could result in a relatively high individual lifetime risk
of 2xlO.2 for individuals in the maximum fISh consumption group (Table 4). The actual consump-
tion of fISh livers is unknown; therefore, this estimate was based on the assumption that the amount
of fISh liver consumed was proportional to the liver weight relative to total fISh weight (Le.. 0.12).
For noncarcinogens, three metals (antimony, lead. and mercury) were present in fish muscle
tissue in concentrations that would exceed the ADI values at the very high consumption rate of
1 pound/day. However, the ADI values would also be exceeded for fish from Carr Inlet at the
I pound/day consumption rate. Limiting consumption of fish to 0.5 pound/day would result in
exposure below the ADI values for all three metals. Bioaccumulation data indicated that sediment
contamination by metals in Commencement Bay was not resulting in significantly'increased tissue
levels for metals. Therefore, risks of noncarcinogens in fish tissue was not evaluated further in
estimating sediment cleanup levels. Moreover. source control and sediment remediation or recovery
throughout the site is expected to reduce even this small excess risk of metals to insignificant
levels.
The baseline risk assessmentS conducted for .he CB,:'-IT site indicated that .he :i10St signiiic::nc
human health risks Jre associared with ~!evated ..:onc~ntr:ltions of PCBs in :he .issues ')1' ~~sili~:1t
:eaI'aod. Arsenic was not 5ubjected co r"urther ~' 1Iuation r~i:lti'.'e :0 ;1Um:ln ne:lith -.:e'.:::use )( ,:s
'ower ~isk level and because arsenic concentrations :n C3/ NT fish Jre simiiar co ...:onccntr:ltlons !n
;'ish (rom :he :-eierence :.lrea.
7.~.'"
~ejaEionshiD to Sediment QuaJity Objectives
-:-he ,1ext step :n :he risk :lSsessment was :0 :~' :lIuate :ne :-ei:ltionshio :,etween ~eaiment
,:ontamination lnd fish ~issue contamination 50 :hat J PCB cleanuo level .;ould be ~vajuated t'or
cs ,::'fectlveness :n reauc1D~ ;IS"5 ,0 ';e:.liOOCl \;onsumers. ~et:l1is dr' :he 'JUalltH:ltl\'P- ::1ernous:sea
:0 ~stlmate seaiment '.::eanup levels [0 protect iluman ilealth Jre prOVtaea in T~tra !~C:1 1 [1,)88al.
The calculation of a sediment cleanup level for PCBs to protect human health was established in
relation to reference conditions, assuming that more stringent cleanup levels would be infeasible.
The calculation therefore involved three key deter~na.tions and assumptions:
-------
TABLE 3. ESTIMATED INDIVIDUAL LIFETIME RISKS FROM
EATING FISH MUSCLE TISSUE CONTAINING ORGANIC COMPOUNDS
 A verale Consumption Rate
. . Concentration
Chemical (wet weilht) 1 pound/day 1 pound/month
PCBs 210 #lllkl 6x 10.J lxlO'"
Arsenic 4.1 mllkl 4xl0'" lxl0"
Hexac:hlorobenzene 11 #lllml lxl0'" 4xl0"
Hexac:hlorobutadiene 40 #lllkl lxl0'" 7xl0.1
Bis(2-ethylhexyl)pbthalate 194 #lllml lxl0'" 6xlO.1
Tetrachloroethene 66 #lllkl lxl0'" Sxl0.7 \ \
-------
 TABLE 4. PROJECI'ED LIFETIME CANCER. RISKS 
  FOR PCBs AND ARSENIC  
Consumption  Fish   
Frequency Intlke Exposure Individual Exposed
(1 pound) (grams/day) (ms/kg/day) Risk Population
PCBs     
Daily 453.0 1.36)( 10.3 5.9Ox10.3 30
Weekly  64.7 1.94)( I O~ 8.42x10~ 1,005
Monthly  15.1 4.53)( 1 0.' 1.97)(10~ 1,735
Bimonthly  7.4 2.22xl0"" 9.63)(10"" 1,111
Twice/year  2.5 7.50)(104 3.26)(10.' 2,618
Yearly  1.2 3.60)(104 1.56)(10"" 8,721
     "
Total     '
    15,220
Aneaic     
Daily 453.0 3.16)( I 0.' 4.42)( 1 O~ 30
Weekly  64.7 4.51)(104 6.31)(10'" 1,005
Monthly  15.1 1.05)( 1 04 1.47)(10.' 1,735
Bimonthly  7.4 5.16)(10.1 7.22xl0. 1,111
Twice/year  2.5 1.74)(10.1 2.44)(104 2,618
Yearly  1.2 8.37)(104 1.17)( 1 04 8,721
Total     15.220
-------
.
Flsb Tissue Concentration Objective: The average PCB level measured in English
sole from the Carr Inlet reference area was selected JS the :ar3~t tissue concentra-
tion following sediment cleanup at the CB/NT site. This PCB level in fish tissue
(36 ",g/kg) results in an individual lifetime risk in the 10-5 range for :i seafood
consumption rate of I pound/month.

Retere.ce SedlmeDt CoDceatndoas: AppJ.ic:able sediment ~u.1 teChnologies (e.g.,
removal or capping) were assumed to result in the attainment of background
sediment PCB levels (20 ",g/kg) at the actUal cleanup site by either dredging and
exposing clean sediments, or by capping with clean material.

Metbod of Qu8lldtad~. Reladoubtp: The equilibrium partitioning method was
selected to determine quantitative relaUonsbips betWeen sediment c:on~mln!ation and
ilsh tissue con~mination. This method assumes tbat a thermodynamic equilibrium
exists betWeen contaminants in sediments and contaminants in fish tissue. and that
the relationship can be described quantitatively based on the distribution of a
pollutant as a function of ilsh lipids and sediment orgazW: carbon. Because of fish
movement and the time required to reach equilibrium, it is also assumed that the
equilibrium f"JSh tissue concentrations are representative of the average sediment PCB
levels in a waterway.
.
.
Application of the selected equilibrium partitioning equation to the CD/NT data indicated
that a sediment PCB level of 30 ",g/kg would result in attainment of a ilsb tissue concentration of
36 ",g/kg wet weighL Based on this calculation, alternative sediment cleanup objectives ranging II
from 50 to 1.000 ",g/kg were evaluated for PCBs according to the following iterative method with
the intent of achieving an average fisb tissue concentratioD for PCBs similar to reference condi-
tions:
1.
An average reference sediment PCB concentration of 20 ",g/kg was substitUted for
all measured sediment concentrations exceeding a particular cleanup objective (e.g..
1,000 ",g/kg)

An overall post-cleanup sediment concentration was calculated as the geometric
mean of the post-c:leanup data set following substitUtion of all values greater than
a partic:u1ar cleanup objective (e.g., 1.000 ~g/kg) with values of 20 ~g/kg

The mean residual sediment concentration was used to c:1lculate the predicted mean
fish tissue concentration using the equilibrium partitioning .model

The mean predicted fish tissue concentration was compared to the- fish tissue
concentration objective (i.e.. 36 J,£g/kg).
2.
3.
4.
Compilation and evaluation of these results indicated th:!t 1 PCB sediment cleanuo level or
150 ~g/ kg would result in 1n lverage post-\;Ieanup sediment .;oncentration of 30 ,ug/ kg t'or H ylebos
'V'lterway or for the CBt~T site in gener:lL T~is ,;!e:lnuo i~vel 'Nould :11so result in ~Ht:llnm~nt ,)T"
:':sn. :'C3 levels similar to tnose ;n ?'Jget Sound .e:'~:"enc~ .lreas. 7:1e ~e::ith ;-:sks J[' .;~::foou
:ansumotion t'rom remediated waterways 'lfouid he :lbout Jx 10.5 for 1 seafood ..:onsumotion .:ue 'H"
:.z..: '~/day, lnd thereiore be comoarable [0 ,he :'ISKS in reierence :1reas.
-~ ZNVIRONMENTAL ruSK ASSESSMENT
--.
r,~ner::1i Strnte~
7he Co/NT investigations have had :1 major lOCUS on environment:!l risks because Jr" :he
adverse biological effects documented in past studies of the area and because of the high potential
for- exposure of marine biota to sediment-associated concuninancs. The historic::1l dam for the :lrea
i1Idicated that sediments. were CODf!amin!l'-d, by a wide variety of chem.ic::11s. with contamination
ganerns and potential sources differing considerably ;unong the waterways. Because of this site'
-------
complexity and the lack of available regulatory standards or guidelines for establishing cleanup
criteria for contaminnted sedimentS. a decision-making approach was developed specifically for the
CBjNT investigations that included characterization of sediment problems. development of
sediment quality objectives, identification of problem chemicals, and definition of problem areas
requiring sediment -remediation.

The enviroamentaJ risk assessment framework developed for the remedial investigation
incorporates a preponderance-of -evidence approach that is implemented in a stepwise manner to
identify and ranJc toxic problem areas and problem chemicals.
Ideally, sediment quality objectives and sediment management decisions would be supported
by definitive cause and effect information relating specific chemicals to biological effects in
various aquatic orpnisms and to quantif'13.ble human health risks. However, very little information
of this type is currently available, and it is unlikely that addirional information will be available
in the near future. In the interest of protecting human health and the environment, regulatory
agencies must proceed with sediment management decisions based on the best information available.
The application of the ecological risk assessment approach for the CB/NT site was based on
three important premises. First, it was assumed that the development of cleanup objectives to
define problem sediments and chemicals would require the analysis of site-specific data collected
as part of the remedial investigation. Second, it was assumed that no single chemical or biological
indicator could be used to define problem sediments. Therefore, the risk assessment would be
based" on several independent measures of contauUnation and biological effects. Third, it was
assumed that adverse biological effects are linked to sediment contauUnation and that these links
could be characterized empirically. Thus, a preponderance of field and laboratory evidence linking
contaminant concentrations with adverse biological effects could be used to establish an empirical
relationship despite the lack of information establishing cause and effect relationships.
The preponderance-of -evidence approach required the selection of several measurements to
serve as indicators of conrnmin~tion and biological effects at the CB/NT site. The fOllowing five
groups of indicator variables were selected:
.
Sedlmeat c:oatamiaatloa-Concentrations of chemicals and chemical groups.
Bioacc:umulation-Contaminant concentrations in English sole
Sediment toxicity-Acute mortality of amphipods and abnormalities in oyster larvae
Benthic inl3una-Abundances of major taxa
Fish histopathology-Prevalences of liver lesions in English sole.
.
.
.
.
.,.., .,
,--
Identific:1tinn ut' "Problem Chemic:1ls
The C3/NT investi~ations indicated that :lre:J. ~ediments were contaminated 1V numerous
:nor~antc :lna or~anic '.;nemic:us :lt levets ",uDstantially :loove ?uget Souno reference -.:onajrjons.
3ec:J.use of ~he extensive list of sediment contaminants. J. procedure was Jevetoped to identiiv :lna
::J.nk problem chemic::us so that source :lnd cie:J.nup dvaiuations eouid be focused on [he chemic:J.ls
,10sing [he 3reate~ ~nvironmental or auolic heaith risk. The overaH identific:ltjon ,)t' fJroblem
:hemic:Us :nvOlvea J three-~teo 'Jrocess. [n ~he first steo. historic:u Jata ~'or :he site "Vere :-eV1t~weQ
:0 select :l suire ()f ..:nemicals to :)e :matyzed in the remeOial invesugauon. 7his suire 1)[" "';:1emIC~IS
:nc!uded EPA "rioritv ,oilutants. many EPA Hazardous Substance List comoounds. 1nd )e'.'e~1
JrI~antc :omoounas :nat :';.re not Dn ",e ~?,\ :ists. :=ullowin2 :ne :-omeaial ;nve~ug:ltlon ::::mOlil1lz
.1 3roup 'Jt" ..,;nemlcais of concern ',vas ,hen identified {rom [he tJverail ~ist 01' Jnal~tes. '''::1emlca;~
of concern were defined as chemicals with concentrations exceeding aU Puget Sound reference
conditions. These chemicals are not necessarily considered problem chemicals because sediments
may be contaminated above reference conditions without exhibiting toxicity or biological effectS.
In m& final nep, m& cbemic:ds' of concern were evaluated for meir retariomtrip ro biotogjQt
effectS. The objective of this step was to define problem chemicals so that source identific:1tion
-------
and remedial alternatives analyses could be focused on a limited suite of chemicals that apparently
posed the greatest environmental risk. Problem chemicals were defined as those chemicals whose
concentration exceeded the apparent effectS threshold (AET) in the problem area. Because the
AET was defined as the con~minltnt corrcentration above wl1.ich toxicity or benthic effectS are
always observ~ chemicals present in concentrations above this threshold are likely contributors
to observed biologic:al effects.
Problem chemicals were further ranked according to their association with toxicity or biolog-
ical effects. Based on this approach. three priorities of problem chemicals were given for each
problem area. The highest priority (Priority I) chemicals were defined as those present above an
AET in a problem area and that also exhibited a concentration gradient corresponding to observed
changes in sediment toxicity or benthic effects. For example. strong linear relationships were
found betWeen sediment toxicity and PCB concentrations in Hylebos Waterway and betWeen
sediment toxicity and 4-methylphenol concentrations in St. Paul Waterway. Other contaminantS
were found at leveLs above AET in these problem areas. but none displayed these strong relation-
ships with sediment toxicity. Therefore. these tWo chemicals were given the highest priority for
source evaluation and cleanup actions because of their demoDStrated correspondence with observed
toxicity. Priority I chemicals included:
.
Mercury, lead. zinc. and arsenic
PCBs. 4-methylphenol. HPAHs. and LPAHs.
.
\
Priority 2 chemicals were defined as those that occurred above the AET in the problem area
but showed no particular relationship with effects gradientS (or insufficient data were available to
evaluate their correspondence with gradientS). Chemicals with concentrations above the AET only
at nonbiologic:al stations were therefore placed no higher than Priority 2 because of the lack of
biological data. These chemicals included:
.
.
Cadmium. nickel. and antimony

Hexachlorobutadiene. chlorinated benzenes. chlorinated ethenes. phenol. 2-methyl-
phenol, N-nitrosodiphenylamine. dibenzofuran. selected phthalate esters. and selected
tentatively identified compounds (e.g.. 2-methoxyphenol).
Finally, chemicals with concentr.1tions above AET at only one st1tion within the problem area
were assigned Priority 3. Problem chemicals for problem areas that were small hotspots of
sediment contamination usually fell into this category.
7.2..3
Identification of Problem Areas
.-\ series of simple indices was developed t'or ~:lch of the five indicators for ..:ontamin:ltion.
:ox ic: [y. lnd biologi~:ll ~ffec:s to ~!1:lble r::lnKing 0[' Jre:ls oasea 0n ;he rei:lti ve ~::l~ n Ituue Jr
'lbserved ..:ontamination :lnd effects. These indices were 4jefined in the general t'orm tJr' 1 ~:H10
:Jetween (he value.ot" J. variable,:1t the CB/NT ~i[e :ma the value ot. the vari:lole ;1t :l re['erence :ilte.
The inciicator Iiltios were structured so chat the value ot" the index increased J.S :he deviation r"rom
,eference conditions increased. Thus. each Iiltio was termed an elevation J.bove reference (EA R)
~nciex. The ~nvironmemai contamination :lnd ~tfectS indic:ltors (EAR) were used i:O ..;omoare ~he
~mire C3/ NT stUdy lre:!. lnd for inaividuat ',vaterwavs with indiviciual samoiin~ stations ,>r 1rouos
Jt" ~tat1ons I i.e..,vJ.terwJ.Y $egmemsl :.lS (he studv UDltS. .
:::emlc:l.l ;ontammation 0[. (:3/NTediments 'V:tS "er" 'jne'.'en. '::ome '.;::emic:::'ls ,e.:.!.. :rSe!11C.
..:opper, -+-methYlpnenOi. anci benzOIJ.lpyrenej were measured J.t ..:oncentr:ltlons ~:<:ceeQmg i.JOO
times reference levels. Biological effects were also highly varied :unong stUdy areas. For e:tample,
amphipod mortality reached 95-100 percent at two sites. while morulities in several ocher areas
were indistinguishable- from reference levels (7-15 percent). Similiuly, analyses of benthic infauna
indicated severe stress. zr evnillWuc;ed by. very low :1bund:lIt~. u same sampling mrions and
apparently normal benthic assemblages at other sites. English sole were very abundant in the
-------
CB/NT waterways. However, 2S-40 percent of the sale from several waterways had one or more
serious liver abnormalities. including cancers and precancerous conditions. Only about 7 percent
of reference area. sole bad these liver abnormalities.
Toxic problem areas were deimed as those areas with sufficient evidence of conmmin!ltion
and biological effects to warrant the evaluation of contaminant sources and possible remedial
alternatives. The identification of these problem areas required the specification of criteria
incorporating combinations of contamination and effects indices that would result in problem area
identification. It was assumed that an area or segment would require no action unless at least one
of the indicaton of con~minAtion, toxicity, or biologica.i effectS was significantly elevated above
reference conditions. Final prioritization of problem areas for remedial action was determined
based on three additional criteria:
.
Environmental significance (i.e., the number and magnitude of significant contami-
nant and effectS indices)

Spatial extent of contamination

Confidence in source identification.
.
.
Based on these criter~ nine discrete areas of sediment contamination were identified in the
feasibility study as priority problem areas warranting further evaluation and response under
Superfund (Figure 12). Overall, these priority problem areas displayed the following characteristics:
multiple biological effectS and significantly elevated chemica.Ls, relatively large spatial extent, and
one or more identified sources of contamination.
7.2.4
Relationship to Sediment Quality Objectives
The next step in the remedial investigation/feasibility study process was to evaluate the
relationship betWeen sediment contamination and biological effectS so that measurable sediment
quality objectives could be defined for both sediment chemistry and sediment biology. Details of
the decision-making process used to select a method for evaluating sediment toxicity as it relates
to biologica.i effects are. provided in Tetra Tech (1988a) and PTI (1989). As pan of the remedial
. investigation/feasibility study, sediment Quality objectives were required that could be used to:
.
Identify problem chemicals in sedimentS

Identify sources associated with problem chemicals

Esmblish spatial designation of problem areas, especially
biological testing results were not available.
in areas where site-5pecific
.
.
S~ver:ll loproaches to sediment quality objectives based on !:lbor:ltory. t'ield. lnd ~hecreri~~i
~~!:Hlonsnips were eV:1iu:1teo ['or .1Pplication co [he CB"~T 3ite. ,Aopro:ll.:hes ~V:liu:lCed :nc::.Ideu
~er"erence lreas. )creenin~ !evei ;oncentr:ltions. AfT. lnd .~auilibrium ~nrtitionjn~. ~hsed .)n
:onsloerauon or" management :mo tecnnicai ~riteri:l ;lno on reSUHS or" '1 ':erific:mon ~xerClse ..\"I[n
field-..:ollected data. the AET :J.pproach was selected lnd conr'irmed ;lS ~he prer'errea iTIetnod (or
deveiooin~ sediment quality 'I:liues in the CBiNT lrea. -\n AfT is the sediment concencr:ltion or'
1 ..::temic:li :leove which 5tatisticaHy si~nificant (P~O.OS) biolo~icai effects :lre 'llways ,)oserved 'n
.he 'lata set 'Jseo ~o genernte .-\ ET \!aJues. in ,>cher '.Vords. if :.lnv ..:hemic:ll ~xceeds cs -\ ET ;'or .:
;J:lrncuiar oioiogicai indicatOr. ~hen In Jdverse biological ~t'fect is;Jredictea ,'or chat : naic:ltOr.
-\lternatively. if '111 .;hemical ';oncenrr.1tions lre below :heir\ ET. rhen 10 :dverse ~!'fec:s ~:re
)reuicred. ~he :.. ET '1ooroac:t..::m ;,e :~sea :0' 'JrOV1(je ;nemtc~t-"oec:I'ic ."eL1im~nt .!U:.1I1(\' . ::tues
;'or che gre::1t"est i1umeer Jnd ..videst range of ..:hemicals 0[. .;oncern in Commencement (Jay 1na
throughout Puget Sound. AET can also be developed for a range of biological indicators. including
laboratory-controlled bioassays and in situ benthic infaunai analyses. An additional advantage of
using existing AET for the CB/NT site is that the [l'!mMi~1 investigation data constitute 3. relatively
large proportion of me ratal d:rtl set used to genernte AET values. The AET approach has also
been selected for applic:uion in other Puget Sound regulatory progrnms.
-------
v.
N
. -- - -- ...--.-
'-.._.-..-
o
- .1IgI." "11..111, ",oW8on SedImeo...
~::~ s..:........, ".100", ............ SedIo-
u
~ ".........~....... s..a.-..
INo clII1IInnkv 8ioIogIcAI 0... A.."'II18,
I I -, i, II II' I III III
"......... fir....... s.......... II, .klOrIc,,'
Oaaa 0nIw
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.
c'-*:. bc- 119"..... flea.
I"''''''''
"
~ HIL..a.
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"
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o
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- "........ A.u SItAIIad....... f.UlbIll,
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lILt .... .. f....... ~
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2000
4000
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.
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-------
-."".'--..
~u
-
'1/gh881 p......, ...~ ~.....
IIIIS'UIl PI Ot:/lance Shoreline
~*~ s-......,......... "'0"'" SedImenIe

~~ 1'................. s....-.
tHo Co,,,!,''',,,, 8IuiugIcaI 0... A........
POI""'" .......,.. s.c.-.. II, '1I8IMc4oI
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- IIU51UU
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COMMENCEMENT
BAY
- P",w.", A.... ........... ... r ......,
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.--. A.... Skde4...... ~I"""""'""
IlIA IlOl ... ,....., .....
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-------
The calculation of AET for each chemical and biological indicator is straightforward:
1.
Collect .matched" chemical and biological effectS data at many sampling stations,
incJudinl potentially impacted sites and reference areas.

Identify impacted and nonimpacted stations based on statistical comparisons with
reference station conditioDS.

Identify AET usinl onJy nonimpacted stations. For each chemical and biological
indicator. the AET is identified as the hipest detected concentration among
sediment samples that do not exhibit statistica11y sianificant effects.
2.
3.
A pictorial representation of the AET approach applied to a data set for two example
chemicals is presented ill Figure 13. For each chemical. the ranges of signific:int and nonsig-
nificant sediment toxicity. results are shown along a concentration gradient. For each chemical, the
AET is shown as the highest concentration where no significant toxicity was measured (i.e., the top
bar for each chemical). Above this concentration for each chemical, toxicity was always measured
(solid pan of lower bar).

Durinl the remedW investiaation. AET were generated for three biological effecu (amphipod
mortality, oyster larvae abnormality, and benthic infauna abundances) for a data set of 50-60
stations. FoUowin8 the remedW investisation, the AET data set was expanded considerably by the
addition of other synoptic data sets from various areas in Pu8et Sound. The AET data set used lA
the feasibility study to establish sediment cleanup goals consisted of 334 stations. and included data
from other areas of Puget Sound. A list of AET used to deilne the sediment quality objectives for
the CB/NT feasibility study is provided in Table S. These values represent the lowest AET for
the three biological effectS indicators.
The three biological effectS indicators used to define AET -derived sediment quality objectives
for the CB/NT feasibility StUdy were selected based on their sensitivity to sediment conrnmin~tion,
availability of standard protocols, and ecological relevance. The resultant AET are applicable to
a wide range of relevant biological effects, thereby providing protection against a wide range of
impacts. .
Benthic infauna are valuable indicators because they live in direct contact with the sedimentS.
they are relatively stationary, and they are important componentS of estuarine ecosystems. If
sediment-associated impactS are not present in the infauna, then it is unlikely that such impactS are
present in other biotic groups such as fishes or plankton.
The test species used in amphipod toxicity testS (Rhepoxynius abr01rius) resides in Puget Sound
lnd is a member of a crustace:ln group th:l[ forms an import:lnt part of the diet of many ~stuJrine
fishes. .-\mphipods are gener::llly pollution sensitive. Jnd species such ~ R. anrOll/u.\" ~:1.ve J high
.:''Jilu[:lm ~:tposure potemial Jec:luse ,hey Jurrow imo :he ~eaiment 1nd :'c~d on :eaimem :n:w~:"::i.
T.he ')vster larvae bioassay ~ses 1 ,est sDecies j CrtlJso.HreQ !.,'!!.!tlJ I that resides in Puget Sound Jna
:uppons commerciaj ana recreationai fisnenes. lhe iife ~[:lges tested lemDryo ana l:1n'al ~re "ery
3ensnive stages of the organism's life cycle. TI1e primary ~ndpoint is l :;uDierha1 ..:nange ;n
development that has a. high potential for effectin~ larvai recruitment.
- -
,-.;
."lITIGATING ~AC70RS
-.ssessment or' .:r:emic::i <':Ont:1ffimatlOn ::na :1iOlOgIC::i effects ~t :he ':J/,'\!T ~i[e :nalc:tea :ne
.Jresence 0[' .>lgmficant ~nv'ronmental
-------
LEAD
NO SEDIMENT TOXICITY
. I - . ... .
.- .-----. -...--..- .. - -. .
.. ... .. . . .
I
10
SEDIMENT TOXICm OBSERVED
I:~/.~/ i.; /./ ;'..~i//.'~=-,~/ I I I lI-
t t : t. I:
sP." sp.,. : ...." RSo"f
I I
I I
101 ...... UOI .....

'A~'!':: ~AX:M~M'F-

CONCENTRATION (mglKg DW) TOXICtTY OBSeRVeD
THRESHOLD LEVEL AT A
BIOlOGJCAl
STAT10N
I , I , , '.
,.
\
4-METHYLPHENOL
OH
$
NO SEDIMENT TOXICm
.
... ..-
.----... .
!
SEDIMENT TOXICITY OBSERVED
~ .
I
~S.'9
~S.t8
.,.,',1';,_.
t I:

SP.tS SI'.'.;
I
. Wi" .., ,
'81'- ..'
t:ao ~O.
I
, ,
.
. ..~.
I
.-
.
J10
:00
'000'
1
APPARENT
iOXIC1TY
;"HAESHOLD
'O~' :e~

MAXIMUM j
OBSERVED
\..E'JEL AT A
31OLOGiCAL
STATION
CONC::NTRATION (~g/Kg OW}
J. .:108Iect80 Cil celecllOn limn snown
Figure 13. The AET approadT applied to sediments tested for lead and 4-metnyfptrenot
concentrations and toxicity response during bioassays

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TABLE S. SEDIMENT QUALITY VALUES REPRESENTING
THE SEDIMENT CLEANUP OBJECI'IVES RELATED
TO ENVIRONMENTAL RISKS
. Chemical
Metals (ma/kg dry wei&ht; ppm)
Sediment
Cleanup Objective.
Antimony
Arsenic
Cadmium
Copper
Lead
Mercury
Nickel
Silver
Zinc
1508
57B
5.18
390L
4soB
0.S9L
>14()AJ1
6.1'"
410.
II
5,200L
2,lOOL
1,300"'-8
500L
S40L
I,SOOL
960L
670L
17.000L
2.500L
3.300L
1.600L
:.300L
3.6001.
[ .600L
1'iO"
::;01.
~:OL.
Ol'luic Compouads (~g/kg dry weight; ppb)
Low molecular weight P AH
Naphthalene
Acenaphthylene
AceDal)hthene
Fluorene
Phenanthrene
Anthracene
2-Methylnaphthalene

High molecular weight PAH
Fluoranthene
pyrene
Benz(:1)anthracene
Chrysene
Benzofluor:lnthenes
Benzoe:1 ipyrene
Indenoe 1.2.3-~.d)pyrene
Dibenzo( :1.b ):1nthracene
3enzoC g,h.iJperytene
Chlorinated or~:1nic compounds
[..:i - Qicnlorobenzene
t. .+-j)ichlorobenzene
1.::-DichJorobenzene
; ..:.~- t"richJorooenzene
..fexacnlorooenzene \ HCJ)
: -:- rJA.L.L3
; IOil
50i..J
5 i"\
""'\d
Total PCBs
1,0008..
. .
-------
.
TABLE S. Coatiaued
Chemica!
Phthalates
Sediment
Cleanup Objective-
Dimethyl phthalate
. Diethyl phthalate
Di-o-buyt! phthalate
Butyl benzyl phthalate
Bis(2 -ethylhexyl )phthalate
Di-n-octyl phthalate

Phenols
160L
2008
1.4QO'U
9()()'U
1.3008
6.2ooB
Phenol
2-Methylphenol
4- Methylphenol
2.4-Dimethylphenol
PenClChJorophenol

Miscellaneous extractables
420L
63A.L
670L
29L
360"
II
Benzyl alcohol
Benzoic acid
Dibenzofuran
Hexachlorobutadiene
N - nitrosodiphen ylamine
7JL
6S0u
540L
lJB
28B
Volatile organics
Tetrachloroethene
Ethylbenzene
Total xylenes
578
lOB
40B
Pesticides
p,p'-DDE
p,p' - ODD
D,P'-DDT
98
169
3..8
I ')ption 1 - L~west AET lmong lmpnipod, Jyster, lnd benthi~:

-\ - ~mpnipod mOrt:ljjry bio:lSsay
:.. - ')yster larvae :J.bnormaJiry bioassay
3 - Benthic infauna -
. - The 5edimenr quality IJbjectiye t'or- ~uman ne:lJth n:lS been ~st:lbJished It
! 50 QPO ,'or ?C3s :u the CB/NT site lccording ro .1 method ..:ombining
!Ouiiionum ;JOlrririoning '1nd iisk :.lssessmenr methods,
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7.3.1
Natural Recovery Process
Natural recovery of contaminated sediments is the process whereby the magnitude and extent
of sediment CODmmiMition in the upper sediment layers is reduced over a period of time following
significant reduction or elimination of contaminant sources that adversely impact sediment quality.
ReductioDS in surficial sediment cODr.:.mination are expected to result in corresponding reductions
in environmental and public 'health risks.
The overaJI process of natural recovery of sediments is dependent on several specific processes:
.
SedlmeDt 8CCWIIaJadoll aDd mbdDa: Once existing sources are redw:ed or eliminated,
cleaner sediment would tend to bury the more contaminated sedimentS. Biological
and physical processes would also tend to mix the recently deposited, cleaner
sedimentS with the contaminated sediments in the near-surface layers.

Blod.adadoa: Microbial assemblages in the sediments break down many
contaminants into less toxic forms.

Dlffusiye 1011: Conr.:.minants adsorbed onto sediment panicles may tend to dissolve
into interstitial water (i.e., water in the sedimentS) then diffuse into the overlying
water column.
.
.
These processes act at very different rates in reducing sediment contamination. The resultan~
recovery rates are also very site-specific, depending on factors such as sediment deposition rates, \
biological mixing activity, degrees of physical disturbance, biological productivity, and oxygenation
of the sedimentS.
7.3.2
ReJationship to Sediment Quality Objectives
In the feasibility study (Tetra Tech 1988a), natural recovery was evaluated as a potential
meaDS of achieving the sediment quality objective for the site. The advantages of natural recovery
include:
.
Long-term mitigation of environmental and health risks

A voidance of the potential adverse impacts of sediment cleanup operations (e.g.,
disturbance of existing benthic communities. redistribution of contaminants during
dredging operations)

Reduction in volumes requiring remediation with coincident incre:1Ses in the
fe:1Sibility of implementing sediment remedial activities

Reductions in cost.
.
.
:I
7he disadvantages of naturaJ recovery JS :1n ~Iement oi (he selected remedy inc!ude:
~
7he continued risk oi ~xposure during (he n:lturai recovery penod

Uncertainties regarding predictions of feasible levels of source control :md estimated
~ecovery rates

':Jncern ~1bout the possibility of disturoance to '.1 rel:ltiveiy ~hin :1atural ;:lD 't!,:;..
~everal incnes oi dean ':ieaimentl by pnyslcai ; e.~.. 3nip :)cour. 'Nave ~rosion) ~na/
)r jioio~jcai I e.~.. :)urrowing) ,.,rocesses.
w
~
A mathematicaJ model was deveJoped in the te:1Sibility study to quantit:ltively JSsess :1aturaJ
recovery in the CB/NT problem are:1S. The Sediment Contamination Assessment Model (SEDCAM)
is a mass balance equation that predicts the sediment concentration of cont:lmi~ants in relation to
source loadint. sed.imentation. rateS, sediment m.ix.in&. b~ 3Ad. conta.min~at loss at the
sediment-water interface. The model estimates the time required for sediment concentrations to
-------
decrease to levels considered acceptable (Le.. concentrations below chemical-specific sediment
quality. objectives). The model also allowed an evaluation of changes in areal extent of sediment
problem areas given estimated levels of source control over varying timeframes. A IO-year
timeframe for natara1 recovery was recommended in the feasibility study based on precedents in
environmental legislation; the balance of remediation-related impacts relative to continued
exposure, monitorial. and practic:a1ity; and requirements in the 1989 PSWQA plan (PSWQA 1988)
to consider natural recovery. cost, and feasibility in developing sediment remedial guidelines.

Given sufficient levels of source concrol. natural recovery was predicted in the feasibility
study (Tetra Tech 1988a) to reduce the volume of sediments requiring remediation at the CB/NT
site by up to 40 percent. Natural recovery was shown to be effective within a IO-year period
following source control in areas that were marginally contaminated above sediment quality
objectives. The advantages of incorporating namra1 recovery as an element of the remedy appeared
to outWeigh the disadvantages in such circumstances. For example, concern about the integrity of
the natural cap is offset by the relatively low impact of potential exposure to underlying sedimentS
in marginally contaminated areas. Natural recovery was therefore considered an important
mitigating factor in the feasibility study.
"
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8. DESCRIPTION OF ALTERNATIVES
The purpose of the CBINT feasibility study was to develop and evaluate the most appropriate
remediaJ str.ueaies for correctinl the human health and environmental impact! associated with
contaminated sediments in the CB/NT problem areas. The feasibility study described cleanup
objectives for the site and then presented a rule of alternatives that offered viable means of
achievinl those objectives.
Ten.candidate alternatives were identified in the CB/NT feasibility study:
1. No-action
2. Institutional controls
3. In situ capPinl
4. Removal/conf"med aquatic disposal
S. Removal/nearshore disposal
6. Removal/upland disposal
7. Removal/solidification/upland disposal
8. Removal/incineration/upland disposal
9. Removal/solvent extraction/upland disposal
10. Removal/land treatment.
\
Although the names of the alternatives reflect characteristics of the specific sediment remedial
action that they include. aU candidate alternatives except the no-action alternative also include one
or more of the following major elements:
.
Site use restrictions-Protect human health by limiting access to edible resources
prior to and during implementation of source and sediment remedial activities.

Source controls-Implemented to prevent recontamination of sediments. Source
control may be enhanced relative to existing progr:1ms. and consequently accelerate
sediment remediation schedules by providing additional resources to focus activities
on sources that contribute contaminants [0 sediments.

Natural recovery-Included as :10 optional (and preferred) remediation str:ltegy ;'or
:narginaUy ,;oncaminated sediments that Jre predic:ed :0 lchieve Jcceptabie ~edimem
quality through burial :.lOd mixing wi ch Ilaturail Y J.ccumulatJng dean :iedimen ts.
.
.
.
'seciiment. remeciiai action-Address .iedimems -:omainin~ ...:omaminauon ,nat :;i
~xpected to ;Jersist for unacceptable petloas t>c' .ime throu~n .;ont'inement ~nd
treatment options.

Source :lad sediment monitorin~-Kefine de:ll1UD volume ~st1mates. ,;haracterize :he
~r'fectiveness ;)f source .;ontrols. Jna ~nsure [hat ~he ~emeay is ~r'fect1ve.
.,.
-he '' av :n 'vhicn 11a.lOr ~Iements lre :nc:uaed :n ~acn :::ndid:lte .:itern:ltive :s :umm:lrized :n
-:"'::oie ".
The following section summarizes the project cle:lnup objective. The next section des<:ribes
the general characteristics of five major eJemencs of the candidate alternatives and their inter-
relationships. This is followed by a description of the general characteristics of the 10 candidate
-------
''''~UI,I:: 6. MAJOR ELEMENTS OF TilE 10 CANDIDATE ALTERNATIVES
~- . --..
        Element   
     lIse Source Natural Sedimenl Remedial Aclion 
Allernaliv~    I~~sukliun Control Recovery Confinement 1teatment Moniloring
   "- _._~.- _. ----        
I. No AlIl"lI   No Exisling programs" Yes No No No
2. ,lnslil!.!I" 111.11   Yes Enhanced Yes No No Yes
 Con.rub           
3. 1,1 Siw \ .Ippill~   Y~s Enhanced Preferredb Yes No Yes
4. Ren.."." \ :\llIllIIc\1   Yes Enhanced Preferred Yes No Yes
 Atju.Jlk Di:>IIII:..11          
5. Remll\'.aI:    Yes Enhanced Preferred Yes No Yes
0\ Near:.I"'I': 1)1:>1111:...1         
6. Remu\'."i    Yes Enhanced Preferred Yes No Y~s
 UplauJ 1)1:>111':>,11          
7. Remm.ll.'    Yes Enhanced Preferred Yes Yes Yes
 Solidill'.11 h 1111          
 UplallJ 1 )I:>PII:>.II          
8. Renul\ .11:    Y~s Enhanced Preferred Yes Yes Yes
 Indncl;.I"11I1          
 Uplallti fJblllb.11          
9. Remll,,;,"':)'lh ..:111   Yes Enhanced Preferred Yes Yes Yes
 Exlraui..lI!          
 UplallJ 11 I> PU:',I1           
10. Remm.oI:    Ye:. Enhanced Preferred Yes Yes Ycs
 Land '1,,:.11 III..: III          
   --- - - --.      
 -..---.-....          
" Nil prll1;I..... ,:........, CIII' III III I."... 111111,'1 ktleral Superfund.     
-------
alternatives and the sediment remedial action that distinguish them. A description of ARARs
and other factors to be considered (TBCs) concludes the description of alternatives.
8.1 SEDIMENT CLEANUP OBJECI'IVES AND EXTENT OF CONTAMINATION
The lonl-term sediment quality goal for Puget Sound. dermed by PSWQA (1988) as the
absence of acute or chronic adverse effects on biological resources or significant human health risk,
was translated into a set of sediment quality objectives for the CD/NT site. The sediment quality
objectives were dermed in discrete, measurable terms relative to specific human health risk
assessments and environmental effects tests and associated interpretive guidelines. As such,
sediment quaJ,ity objectives form the basis for both source control and sediment remedial actions.
The process for developinl these sediment quality objectives is described in greater detail in
Sections 7.1.4 and 7.2.4 of this Record of Decisjon. in the feasibility study (Tetra Tech 1988a), and
in the development of sediment cleanup goals (PTI 1988).

Sediment quality objectives were also translated into sediment remedial action levels and
source control levels. Sediment remedial action levels incorporate technical feasibility and cost
coDSideratioas by inc:orporatinl mitipting factors such as DaNra1 recovery. The sediment remedial
action level differentiates areas that exceed the sediment quality objective, but are predicted to
recover natura.Uy, from those that are more significantly CODmmimlte(1 and therefore require active
remediation to achieve the sediment quality objectives. If natural recovery is predicted to be
effective in achievinl the cleanup objective in a reasoaable timeframe (10 years), then no sedimezia
remediation would, be required.
For sources, the relationship to the sediment quality objectives identified for the CB/NT site
is less direct. Ecology's source control program will consider applicable state sediment standards
(currently under development) which are also based on the long-term sediment quality goal for
Puget Sound. Ecology's proposed source control requirementS incorporate technical feasibility and
cost considerations by requiring utilization of AKARTs and compliance with appropriate ARARs.
Sediment quality standards (or interim values) will not explicitly be used to derive effluent limitS,
but they will be considered in the selection of appropriate treatment technologies.
In the feasibility srudy, sediment remedial alternatives were developed for tWo options: I)
active remediation of aU sediments failing sediment quality objectives, and 2) active remediation
of sediments failing remedial action levels and n:lturnl recovery of marginaJly contaminated areas.
In both cases, the long-term overaJi project cleanup objective was to attain sediment quality
objectives. Therefore. the extent of cont:1min:1tion in each problem area W:LS estimated according
to chemical exceedance of on~ or more of the sediment quality objectives.
Problem chemic:lls :hat ~:
-------
time (Le., within 10 years following the identification and control of major Sources of contamina-
tion). Monitoring was described as most important in the early stages of remedial action [0 ensure
that sources would be adequately controlled and to provide a baseline for future assessment of
adequacy of source control, rate of sediment recovery, and permanence of sediment remedial
action.
U1
Site Use Restrictioas
Site use resttictions consist mainly of public warnings to reduce potential exposure to site
contamination, particularly ingestion of contaminated seafood. Local health advisories are an
integral part of the overall remedy because the ultimate cleanup objective was projected to be
achieved over a 10-15 year period.
8.2.2
SoQfte Control
Source conttol activities specified for the 10 candidate alternatives are characterized as either
existinl programs or enJumced programs (Table 6). The designation existinl progranu indicates
that no additional effort would be expended to accelerate implementation of these progranu and
subsequent sediment remedial action. EnJrtDfced source control requires that additional resources
be foc:used on identification of ua1cnowu sources, characterization of suspected sources, and control
of known sources that are conttibuting contaminanu to the high priority problem areas at ~e
CB/NT site. Existinl source control programs were focused on by the Commencement Bay UBA T
following the remedial investigation. Source control efforts have recently been enhanced through
a cooperative agreement between EPA and Ecology awarded 30 June 1989 (see Section 3.4). This
expanded effort will ensure that sediment remedial action takes place in a timely fashion. Source
conttol and remedial activities related to sources in Commencement Bay are broad-ranging in scope
and status of action. For many sources (e.g., shipyards), the implementation of best management
practices is the main form of remedial action. There is a variety of more traditional types of
remedial action that have been or will be implemented to mitigate contamination at sources. These
range from preliminary actions that address the most severe site contamination (e.g., site stabiliza-
tion, expedited response action) to more comprehensive remedial measures (Le., remedial design and
remedial action). In general, appropriate source control actions have been identified on the basis
of site-specific studies. Many of the ongoing source-related activities were initiated based on the
results of the CB/NT remedial investigation (Tetra Tech 1985) and focus on problem areas and
problem chemicals identified in the CB/NT remedial investigation. Source control actions for
additional significant sources that are identified during the ongoing studies will be integrated into
the overall remedy for each problem area.
fn general. E~ology will use consent orders. .:onsent decrees. :lnd Jdministr:ltive orders to jrive
source-related :lctivities. Orders :md decrees. which can be issued Jt any rime Juring rhe remedial
~roc~ss. may ,cecify ~ither J. singie :lction ')r' :1umerous Jcrions. One ')r :nore ;J~rmi[s .:re ':1;;0
rypically required to implement source .:ontrols. \1any of rhe major sources in the CBi;\iT .1rea lre
.uo.iect ,0 .\lPDES ,)r ~CRA permits. :n :..ddition. ~peci:l1 permHS ,nay '":e requirea :'or :ert:lIn
;emeaiai :lctivities (e.g.. J1r yuaJity permitS (or 3rounciwater strioping ,)r' \'olauie 'Jrgamc .;om-
~ouncis I. A summary of major permitS or regulatOry mechanisms relevant :0 source .;ontrol .1ctions
:s ;Jresented in Section .3.
A. .;ummary ~r' :he :;t:ltUs ,)1' :ource :dentific:uion. ..;naracteriz:uion. .lnd .;ontrOI <:!forts :n :he
~ight high priority 1reas lddressed in rhis Record of Decision is provided in Table i. Detaiis ;)r'
.1e ,jroccss ;'or determmIn~ '.he ::cceotJbJiity qt' ~:ource '.;ontrol '~!'fOrtS ~:re ll~~cnbea in .~~c:lOn n.
:mDlementauon ~cneaules ;or 
-------
   'fAilLE 7. STATlJS OF SOURCE CONTROL ACfMTIES  
 IN COI\II\IENCEI\U:NT RAY NEARStiORE/TIDEFLATS PROBLEM AREAS  
 "---.--- .        
     Sile Characlerizalion Site RemecUal Action 
    Orderl  Completion  Completion NPDES
 SilL   Decree Sialus" Dale Slatus" Date Permit
 - .-. -..----        
 Head uf lI}kl'IlS \\~Iclway        
 Kaiser AIIIIIIIIIIIIII .S; Chemicil CII.  1190 U 9/89 P 90 11/~<.I
 Pennwall (:I.cllli.:ill (:"11 p.  6~7, 3189 U 10189 U 91 8J9d
 General tdd.lls. JilL.  'd187 C 7189 u 12189 12~9
 3009 lllyl'll \VilY Illg Suning rah..l  6/1$7, 90 U 6/90 P 91 
 WJsscr Willld:> I\)g SlIniug \'.11'1..1  3187 U 89 P 12J90 
 . Louisiana b.:ifiL 1 og S\uling Yaul  6187 C 6189 P 10190 
 Cascade '1IIIIIIa lug Surting YiUJ #! 2190 P 90 P 93 
 B&L UJII.llili  2/89, 8/90 U 6/90 P  
0\ lacoma 1i1l.llhuilJillg Cu.  7189 C 1181 0  12189
~ Siorm dfOillD         91
 Addiliunal :>"UILC iJclllifi.:ali.w   0     
 Moulb of 11}'&.:bos WaAtclway        
 Ocddentill (:hclllk.al  11188 U 9189 P 91 3f)(f
 Storm dlillll:>         91
 Additional ~IJUfLC iJclllilit:allllli   0     
 Sitcum WaAt.:I\':ay        
 1bminal"J       0  
 Siorm DI.IIII SJII.!   C 7189 U 4190 
 Olher SIIIIIII ,....ill:>        91
 AdaJilioll..t .,"llilC i.kllllfkalhill   0     
 SI. P"dul W..I..I .vay        
 Simpson' 1;" 11111.. I" ..11  12/~5, 12/87    C . 9/88 12/2)1'
 Siorm aJ....,...    - -   91
 AaJaJiliulI." ." .UI. L hkllllli<:illh...   0     
-------
TARLE 7. t -llIllillW:il
."--.'-----0'"
~II.;
Order/
Decree
Si.e Characledzalion

Complellon
Dale
Sile Remedial Aclion
Completion
Dale
NPDES
Permit
Slalus41
Slalus41
---. ..-. ------ --
Middle \\~I';I way
Couks ~blllh; ~1'..:.;jiJlli~s
Marine I 11.1 11;,1 ri..::. NUllhw~:o1
S.orm lta .';u:.
AddiliulI.,1 ~dUIL': iJ":lIIificalhl1l
o
o
12189
12/S9
91
o
Head of Cil}' W..iI~lv.'ay
Americall j'!;llIlIg
Marainac ~lljJlbllilJjllg
Saurm DLIIIIS CS !.JI. CNH/, ca-..! \11
1hcuma ~I'II" :oilc
Olher Sh,lllI JliJill:'
Addiliun," ~IIUIL': i,kn-lifac;llh.1I
II/Sb. 9IH7. 10/89 5189 P 90
  o If)()
C 4,c;o U 
0   
   91
o   
0-
VI
Wbcclcr-O:,t)d,KJ 'Volle. way
Siorm DI,'III (:W-.!5~
Olher S'UIIil Jr;.;n:.
Addiliou;" ~,IUIL": iJ":lIlitlcaliull
C
4,c;o
u
91
o
Moutb 01- ':IIY \v.lla.:.way
D SUecl j'..lIlIklllll
Siorm d..IIII:,
Addi.iOl"11 :,oIUf~c IJC"linL,lIhlli
111S8. 91
u
12189
P
92
91
o
---.. ..- -. ---
II U - LJndcl-"..,.
P - PI all II. .1
C - COlIIl'kl':oI \'.1111 hillg-lell.1 1I1t/lIlIlllllIg fctluired
0- OnglHIIg .:1&':111.:111 (,f 11\....111 :O'''lIn: 1IIIIIrili ellllf!.

b NPDES p. 11,,11 I LII~ wid dOiIL
-------
.
8.2.3
Natural Recovery
In the CB/NT feasibility study, the advantages and disadvantages of including natur.1l recovery
were evaluated for all of the alternatives that include sediment remedial acrion. In the CB/NT
feasibility study. tWO options were analyzed for each candidate remedial alternative that considered
sediment remedial action: 1) remedial action alone achieves the sediment quality objective, and 2)
natUral recovery is considered acceptable for all portions of the problem area that are predicted to
reach the sediment quality objective within 10 years. and sedimentS that are not predicted to
achieve this objective are subject to remedial action. Natural recovery of some or a11 of a given
problem.area may occur through chemical degradation. diffusive losses of contaminants across the
sediment-water interface. and burial and mixing of contaminated surface sedimentS with recently
deposited, clean sedimentS.
Natural recovery is expected to be effective in marginally contaminated portions of each
problem area, but it is not intended to address severe levels of contamination. To determine the
cleanup level, a recovery factor was developed using the mathematical model SEDCAM (described
in Section 7.3.2). Recovery factors represent the ratio of the cleanup level to the sediment quality
objectives for different chemica.Ls. Recovery factors developed in the CB/NT feasibility study
ranged from 1.2 to 4.6 for different indicator chemica.Ls in the different problem areas. That is,
in some areas sedimentS contaminated at up to 4.6 times the sediment quality objective were
predicted to recover within 10 years following source control. The value of a recovery factor is
a function of the source loading rate. sedimentation rate, depth of the surface sediment mixed
layer, and chemical degradation. Recovery factors identified in the feasibility study were based
on limited data, and will be further developed as a result of continued source investigation and
monitoring. additional sediinent sampling conducted during remedial design, and emerging
information on other processes (e.g., sediment resuspension, new degradation rate data) that may
alter recovery rates and the feasibility stUdy (Tetra Tech 1988a).
8.2.4
Sedllll(lftt Remedial Action
Sediment remedial action is directed at sediments that exceed the sediment quality objective
or ar.e predicted to exceed the sediment quality objective within 10 years (if the natural recovery
option is included in the overall site remedy). Sediment remedial action falls into the general'
categories of confinement and treatment (Table 6). Confinement remedies isolate contaminated
sediments but do not decrease toxicity, mobility. or volume. Treatment alternatives include
technologies that destroy or entrap problem chemicals, effectively reducing toxicity, mobility. or
volume. Details of the sediment remedial action that characterizes the 10 candidate :llternatives
lre described in Section 8.3 :lnd the feasibility study (Tetra Tech 1988:1).
~.2.5
:vtonit()rin~
:'jurce :lnd ~ediment monitoring lre ,;:-itical for determining rhe success or" !ndividu:li ~emedi:.li
:ctlons :lnd ensurJn~ that :lil necessary remeciiai :lCrIons ilave oeen undert:H~en in :J. ;Jroolem ::re:l.
7he .)verail objective of source monHoring is to document (he level of source .;ontrol 'J.chi~ved :lnc
,he :J.ttainment of ~nvironmental quality goals. Sediment monitoring will include :J. ,:ombination or"
.;nemical :mci 0Dtional 'Jiological ,ests 1S summarIzed in SectIon .L 1. Further Je~:l1i ~eg:lrain~
;amplin~ .jesi~n 1nd :nonJtoring is orovidea in :he C3/NT ~'e:lSibiiity ;ruay : Tetra "!'"ec:1 . 9HS:l) .:nc
;n :he ~megrated :lcnon plan (PTI 1988)' ~:lmpiing '.md (est ~'/:l!uation ;JrotOcOIS "or:n\':ronme~t~1
~ffec:s. J.S 'vell JS the-\ ET jacab~se. :!re '0 r~main ..:onsistem.vich 1nv -:diustmems 1domed '~\' :he
?'l~e~ :;uund ::;tuarv ?ro~r::m. .-!ew -.:~tS ',-/Iii 'il1iv ::e ':onSluereu :r- ::le'.' ::re ',:uuoreu ;:; ',-'~)!;!':~-
menrs (or one ut" the three oioiogicai mdic:ltors oJescnbed in this Record uc' DecisIOn. .\"hen iJor!l .
biological and chemical test results are available for a particular sediment sampling station. the
results of a particular biological test will outweigh the AET predictions of that biologic;).! effect
. based on chemistry.
-------
.
Source monitoring data are collected as part of the source control programs discussed above
in Section 8.2.2. During sediment remedial design. monitoring of poorly characterized sources may
also be necessary to refine estimates of the importance of source control at those facilities. This
monitoring may be coordinated with reconnaissance surveys designed to. assess the relative
importance of ongomg and historical sources of contamination.

Monitoring of sediment contamination .is conducted before and after sediment remediation
and serves the fOllowing purposes:
.
BaseliDe sediment sampling during remedial design and again during remedial action
. establishes a recent basis for assessing the success of the remedial alternative

Monitoring is used to confirm predicted recovery of problem sediments within a
reasonable time period (10 years) when sediment remedial action is not required for
all or a ponion of the cleanup volume'

Post-remedial action monitoring enables assessment of the success of source control
efforts and provides a record indicating that the sediment problem has been
mitigated (e.g.. successful operation of a disposal facility).
.
.
Baseline monitoring requirements are satisfied by sampling conducted during remedial design
to refine the estimated cleanup volume and during sediment remedial action to serve as a baseline
for evaluating natural recovery processes. Additional monitoring may be advisable depending on
the time lapse before implementation of the sediment remedial alternative. II

The recommended frequency of sediment monitoring depends on the documented success Of
source control. Annual sampling for sediment chemistry and biological effectS is recommended for
the first several years foUowing implementation of sediment remedial action. If results confirm
that sources have been adequately controlled. then the frequency can be decreased. For well
controlled sources or in the absence of ongoing sources. sediment monitoring is used primarily to
determine the success of sediment remedial action. When only partial source control is possible.
more frequent sediment monitoring may be necessary to determine the need. for subsequent
sediment remedial action.
8.3 CANDIDATE ALTERNATIVES
Each candidate alternative represents a combination of the major elements described above.
Implicit in each of the identified alternatives (except no-action) is the aggressive pursuit of source
control measures under all existing environmental authorities to reduce contamin:lDt inputs to
sediments to the maximum extent possible using AKARTs. The level of source control was
:onsidered in ~valuating alternatives to assess long-term effectiveness and the potential t"or natural
recovery. Details of these candidate alternatives lre presented in the feasibility study! T cua T e'.;h
:983:).).
,i.:J.l
Alternative 1: ~o-/"\ctiun
7he 1o-:iction alternative ~ucplies a baseline :lgainst which uther 3ediment remediai .llterna-
:ives ~an be '.:omcared. iJnder ,he no-action alternative (he site would be let't lar~eiy :.mcnangea.
'vith :to remeaiation or ~eaiment contamination. :ithougn some \legree or' naturai rt!coverv 'nav ')e
~vident in :lCe:lS imcacted by historic:l1 sources. This alternative does nothin~ ~o mitigate the pubiic
:e:llth ::nd \~nvironmentai iisKs ~ssoc::ltea '.vith (he ::ite. :)Ut its ~'!:l1uat1on :s ~~aUlreu )V 'i1t! '.JC~.
:...osence Jr' lny Jaditional iesources ,'or ;.;ource .;onrrOI ;hrougn :oln :?A, ECOlOgy ..;ooper~t1ve
agreement under Superfund is an implicit element of this alternative. Potential impacts ot the
no-action alternative include the following:
-------
o
.
Continued potential for human health effects associated with consumption of
contaminated fish and shellfish

Continued high incidence of fish disease (e.g., liver lesions)

Continued bioaccumulation of problem chemicals in the aquatic food chain

Continued depressions of the benthic communities (reducing the value of contami-
nated areas as habitat for iuhery resources)

Continued :u:ute and chronic tOxicicy for marine ors~ni'l"" associated with sedimentS.
.
.
.
.
8.3.2
Alternative 2: Institutional Controls
Institutional controls include access restrictions, limitations on recreational use of nearshore
areas. issuance of public health advisories. monitOring to evaluate cJJanges in sediment characteris-
tics. and most importaD~ enhanced regulatory cona-ol of contaminant sources specifically oriented
toward mitigation of sediment conmmination. Limitations on access and recreation (e.g., fishing,
diving) reduce human exposure and risk to public health. but do nothing to mitigate the existing
environmental impact mentioned under the no-action alternative. Some degree of long-term
mitigation is expecu,d as a result of reduction in soun:e Jl-fin... Sediment monitoring is included
in this alternative to permit identification of contaminant migration patterns and assess sediment
recovery associated with source control. Monitoring would be designed to enable assessment 0{
changes in risks to public health and the environment before impacts are realized. \
8.3.3
Alternative 3: In Situ Capping
In situ capping involves containment and isolation of contaminated sediments through
placement of clean material on top of existing substtate. The capping material may be clean,
dredged materia! or fiU (e.g.. sand). In additiOD. it may be feasible to include additives (e.g.,
bentonite) to reduce the hydraulic permeability of the cap or sorbentS to inhibit contaminant
migration. Both mechanical and hydraulic dredging equipment can be used for in SilU capping
oper.1tions. Cohesive, mechanically dredged material would be placed by using a split-hulled barge.
Hydr.1ulically dredged material would be placed by using a downpipe and diffuser. Depending on
site topogr.1phy, diking may be necessary along a margin of the capped sediments to provide I:uern.l
cap support.
For the purposes of evaluating the capping alternative and estim:lting costs, it was assumed
that cle:1J1. dredged materia! from the Puya!lup River would be used to constrJlct the C:1p. Although
in SilU capping has been successfully conducted with hydrnulic dredging eQuipment. for costing
purposes it was :lSsumed that the c:1pping material would be dredged using 1 -:Iamshell Jre.jge w
.-r1aintain cohesiveness. trnnsported to the problem lre::1S. :md deposited hydrn.ulic:1lly ~o ...:re:J.re 1 "'::lD
'lith :J. :ninimum :hic~mess Ji j ;'eet, E'::l!u:ltlOn Juring jesign may dic~te pjac~:nent .)C' ..(J~i:lOnai
:::lDping material to prevent failure due to erosion or ,jiffusion I)f mobile contaminants,
~.3.4
.-\Jtemative.$: RemovaJ/Confined, Aquatic: DiSVQSai
Severn1 .;oniined lQuatic disposal .)ptions were described :n ,he C'a/NT r'easibiiiev ;tUG\',
7hese)ptions inclUde waterway confined lQuatic Jisposai. :mailow- water ,:onfineci :lQu:mc disDOS::ll,
1pen-water ,;onfined acuatic disposal. lnd o"en-w;uer mounded .:onfined :lGuatic discos:!. ~he~e
'Dtionsliffer ~'rom ,)ne ::nOther jaseG ':m~ely)n :oc:ltion. leeth. md Jhys\(,;ai ...::i::lr:c:e:-IStlC: .['
the disposai SHe. DesIgn features oi ln in-w:lterway ..:oniined lQuatic disposal site lre iilustr:ltea
in Figure 14. Mechanical dredging followed by split-hulled barge placement techniQues can be
used to implement this alternative. The thickness of the <::1P required for confined aQuatic dispoS4lJ
options r.1Dges from 3 to 6 feet, depending on wave and tidal energies and water depth at the
d~ site. Onsite confined aquatic diS1'QS3J could be ill!t'lemetateG within a desi8nated shipping
uea. This approach would entail dredging an uea well below the 'zone of contamination.
-------
r
UPLAND
. .
HIGH TIDE
WATER
SURFACE
. .. ..n...........
..
LOW TIDE
..
SOLUBLE'
DIFFUSION"
CONVECTION'
,',
,
to. .

r
...
. .
.. .
..
...
..
.. n.
. .
..
..
. .
...., .
...
...
. ..
..
....
. ..
.. "
'...' . DtFFUSION{
". CONVECTJON{{
..
. ....
. .....
.. .
.. ..
... .'
..
...
...
...
n. .
..
.. .
. ....
..
.. .
. .
...
. .
. . . . .
r\
Figure 14.
fn-waterway confined aquatic disposaJ of contaminated dredged material
I
-------
depositing contaminated dredged material in the excavated pit, and capping it with a thicK layer
of clean, dredged material if future navigational dredging were anticipated.
Use of an offsite open-water confined aquatic disposal site was assumed in the CB/NT
feasibility study. for costing purposes because a deep-water site of sufficient capacity for a large
volume of material had been identified as potentially viable. A clamshell dredge would be used
to maintain nearly in situ densities. Also, by mwmizing water entrainment, a clamshell dredge
would result in easier transport and fewer or less severe water quality impactS during dredging and
disposal operaUoas. Dredged materials would be transported to the disposal site and placed directly
using a split-hulled barge to limit bu1JciDg and water column impacts. Capping materials would
subsequently be placed in the disposal site using a submerged diffuser system to minimi7'e water
column turbidity and facilitate more accurate placement of materials. Use of the diffuser system
would elimin!lt811 upper water column impacts by rad.i.a11y dispersing the material parallel to and just
above the bottom at low velocity (Phillips et a1. 1985). .
8.3.5
A1temadYe 5: Remom/Nearshore Disposal
Dredging fonowed by coDimed disposal in the nearshore environment is another alternative
for V!di~t remediation u the CBINT site. Generally, nearshore sites must be diked before they
can receive dredged material. There are essentially no limitations in the selection of dredging and
transport equipmen~ although hydraulic dredging followed by pipeline transport to the disposat
facility is considered optimal (Phillips et al. 1985). All variations considered for the removal/
nearshore disposal option use industry standard equipment and methods that are generally available.
Hydraulic dredging conimes dredged material to a pipeline during transport, thereby minimizing
exposure potential and handling requirementS. Systems for management and treatment of dredge
water caD be readily incorporated into the facility design; The disrances between several of the
problem areas and a tentatively identified Blair Waterway nearshore disposal site are great. Material
dredging with a clamsheU system would be used for implementing this alternative in problem areas
more than 2 miles from the disposal site. For problem areas within 2 miles, a hydraulic dredging
system would be possible. Logistical problems may be encountered, however. in areas with heavy
marine traffic.
A schematic drawing depicting general features of a nearshore confined disposal facility is
presented in Figure 15. To accommodate a dredge water control system using chemical floccula-
tion, the secondary settling basin would resemble that illustrated in Figure 16. Other assumed
design features include fill depth of 30 feet and a minimum cap thickness of 3 feet. Additional
capping material may be required to facilitate subsequent construction over the confinement
facility. The facility was assumed [0 be unlined.
For the purpose of evaluating this alternative in the feasibility study. it was assumed. mat :he
nearshore disposal faciqty in Blair Waterway would be used. For the Record 0f Dc-::sion. :his
'litern:ltive was ~"::1iuated md ';OStS were 'Je'!~ioped assumIng Jisposal was incorporated :nro ::-iannec
:onstrucrion pro jecrs.
~.3.6
.-\1temative ti: Removal/Upland Disposal
Dred~in~ ~'oi1owed by uDland ,jisposai would ;nvolve [he rrnnsr"er ')f Jredged m:ltemll :0 :1
.anQ-;)ased conr"inement c.acliity 'lnd wouid iJe implemented [ollowmg )ourc~ ..;onrrol. ':::~lliment
:ouid ~e dred~ed ~ither mechanically 0r !wdrnulicaJlv 'lnd trnnsferred :0 rhe disDosal site ;'V :ruck.
::l1i. .Ir ")!Deline. \5:n he;::.se 'J[' ,1e:1rSnOre 'JiSDosal. :he ::aernatlve..:::.n :)e :rnclementeu ~S1ng
5tanOarQ <.lredgIng mQ :rnnsport equipment ,nat is genernUy useQ t"or slmiiar operntlons. ~rovlsions
would be required for the management of dredge water and leachate generated during the
dewatering process. Disposal site design features would include a liner and cap. The liner system
would include an underdrainage system for dewatering the fill material and for conuollin& l~rMrp
over the long term. The underdrainage system would be designed to operate as eith~r a passive
. collection system or a vacuum-assisted dewatering system.
-------
,., . ~ ' , ,
VOLA TlUZA TlON
II
INF1LTRA TlON

DREDGED
MATERIAL..
HIGH TIDE

DIFFUSION
....:~AGE..
- CONVECTION
VIA TIDAL
PUMPING
. .
. .. .
- EXIS IrfG.---.-. -. _...-
::<~: J ::/.:--: :-::
-; SOTre"::;::,:>
... .
SEE?AGE:.
~
I
i1
I
!
-------
POL YMIR FUD
SYSTIM
-
DRIDGI
PtPe
PRIMARY
CONTAlNM8NT
ARIA
seCONDARY
CONTAINMENT
AReA
-:"
V
?
------
---------
------------
---------------
-------------------
----------------------
------------.-------------
------------------------
-------------------------
------------------------
-------------------------
------------------------
------------------------
------------------------
weJR
IOXU
\ \
.....
-
;:;.f.r.nca: ~"lliics at al. . . ':=:';
t
"'l1lI
Figure 16.
Dredge water chemical darification facility
I
-------
A schematic drawing of an upland confinement facility is presented in Figure 17. Dredge
Water clarification (e.g., using the secondary settling basin and chemical clarification design shown
in Figure 16) wouJd be an essendal feature of !he facility. I' was 3SSUmed thaI the disposal facility
would be construCted to contain conmminated dredged material to a depth of 15 feet. A dual
synthetic liner and passive underdrainage system would be included to permit removal of
perCOlating dredge water and aLlow for long-term leachate coUection. Dredged material would
settle, and ponded dredge waler wnuld be remnved. Passive collection of percolating waler would
coatinue Wltil!he fill coosolidates la an e.teal !hal allows capping operatioos to commea100"00 :ceo,
lre cnara"erized by 'lgoilioan, me,:us cooramlDatioo. which ;, 00' mi.igated by iocioerarioo.
Second, marine sedimentS are charaCterized by very low aru COotenl, maleing incioera.ioo eXtremely
energy-in'eosive and less cosl-effec.ive. As for 'he o.her alleroa'ives, implemeo!:lIion of 'ource
control measures was assumed.
-------
a)
UPLAND DISPOSAL
J
VOLAT1UZATtON, J
DIFFUSION, J
CAPtLLARY, 1
MOVEMENT I. 1
1 I
1 I
I
I I
I 1
1 1
1 1
I I
J
I
\
\
~
b)
CROSS-SECTION
INJIlUEHT

>
PONDING
OEPTH ~
AREA FOR SEDIMEHTAT10N '" 1-

, .
- ~EEBOARD
;'
/
COARSIE-GAAINED I
JREDGCD MATeRIAL
~.w~
::>
~UENT
" -'REA FOR FtNE~AINED
JREDGED MATaiIAL STORAGE
~
,
Figure t7. Confined uptand disposat (a) and COt1lpui1~ at a typical diked upland
disposat site (b)
-------
For this alternative, sediments were assumed to be me~hanically dredged, using a watertight
clamshell bucket to minimize water content of the dredged material, minimize water column
Partitioning of contaminants. and maintain in situ sediment densities. The dredged material would
be transported to shore by barge and then to an upland site for incineration. It is possible that an
incineratOr could be located adjacent to the problem area and transport by truck could be avoided.
Analysis of the iDc:inerated residue may. reveal that the material. no longer requires special handling
and conf"lDement. Open-water disposal may be a feasible option for disposal of incinerated
contaminated dredged material, but for this alternative, disposal in a minimum security landiill was
assumed for evaluation.
8.3.9
Alternative 9: Removal/Solvent Extrac:tJon;Upland Disposal
For sediments containing primarily organic conrnmin~ntS, solvent extraction followed by
incineration of the organic: concentrate would be 'a feasible alternative. This approach to sediment
remediation would result in permanent removal and destruction of organic compounds. It was
assumed that contaminated sediments woald be dredged using a clamshell, transported via barge,
and offloaded using a clamshell to an onshore treatment facility. The contaminated dredged
material would be treated, dried, and transported to an upland disposal facility. Because the
process effectively dewaten the solids, stabilization was considered unnecessary.

For the purpose of evaluating this alternative, use of the BEST8 technology marketed by
Resources Conservation Company (BeUevue, Washington) was assumed. Effluents from the proc~
would include wastewater and treated solids, and a concentrated organic waste that might require
additional treatment. Solids retain a low residual concentration of extracting solvent, and depending
on metals content, may be returned to the removal site for unconf'med disposal, placed in a PSDDA
open-water disposal site, or landfilled in a secure facility. The latter was assumed for estimating
costs. The extracting solvent. typically triethylamine, is not a listed hazardous waste constituent,
which simplifies waste solids and wastewater disposal.
8.3.10 Alternative 10: RemovaifLaad Treatment
For sediments contaminated with biodegradable organic compounds, a land treatment option
was considered. Land treatment involves the incorporation of waste into the surf3ce zone of soil.
followed by management of the treatment area to optimize degr3d3tion by natur:ll soil micro-
organisms. Chemical and physiC:lI char:lcteristics of the waste need to be evaluated to determine
the Jrnount that C:l11 safely be loaded onto the soil without 3dversely impacting groundwater. Soils
possess substantial c3tion exchange c:lpacity, which C:ln effectively immobilize metals. Therefore.
wastes containing metals C3n be 13nd-treated. but careful consider:ltion of the JSsimilative capacity
'Jr" :he soil for metals is ~SSenti3J.
;=')r ~":lluating thi.s :llternative. ;c WJS ;lSsumed chat ~ourc~ ,,:ontroi would Je implemented lna
:n:lt ~ediments would be removed using a cl3msheU dred~e co minimize water .;oncenc ,)C' .ne
irea~ea materi3L .'~fter ~r:lnSPOrt hy barge :.lDa ,rUCK :0 {he land cre:ltment i'ac:iicv. ~he :-:eaimem
:naterial would ,e distributea anci ciilea into ~he upper i5-jO ,;m vr" joiL The !ana :re:lCment
f3Cility design would prevent stonnwater run-on and aHow coilection :lDd management vf runoff.
L.. ::simeters and monitOrinq 'Neils would be installed ;:nci Qerioaic:lily s3mcied ,0 :lid in ,he ;JetecCion
)I' ouosurr'ace ~ontaminant :nigrntion.
. .
:.....
...PP!..~c....nLZ :)R 'lliLZVANT \NO .;.P!>!10P!tlATE :~EQUIREMENTS
Remedial actions implemented under CERCLA must meet legally applic:lble or releV3nt 3nd
appropriate requirementS (ARARs). ARARs include promulgated environmental requirements.
criteria. standards, and other limitations. Other factors to be considered (TBCs) in remedy selection
may include nonpromulgated standards. criteria. advisories. and guidance. but are not evaLuated
pUrnJanr to the fomral process required for ARARs. ARARs of federal. state. and trib31 govern-
-------
ments must be complied with during CERCLA response actions. Loca.I ordinances with promul-
gated criteria or standards are not considered ARARs but may represent important TBCs. Major
chemical-specific. location-specific. and action-specific ARARs and TBCs are presented in
Tables 8. 9, and 10.
\
\
-------
-----.
M~,Jj;1
SUICacc W.tlcr
ARARs"
Clean \\~lh:1 . \LI
-..I
-..I
Wdshingll'lI \\,11<:1
Qualily SI,II"I.ulh
Puyallup '1& II,.:
Weiter QII,oIil)
Program
Weilcr Pull.,I,,'1I
Conllnl :\. I ,.utl
Wdlcr R~:,...I"'::'
ACI
TUesb
Pugcl SOIlIl,I \V,II':I
QualilY "\1111..'111\
MiJlliJg~III' III 1'1.111
TAULE K. MAJOR CIIEMICAL-SPECIFIC
AI~AI~s I.'OR REMEDIAL ALTERNATIVES
1'lIiJlinn
Prere41uisiles for Applicability
Requirement
. - ~ ---.
.H 1I.S I . S.:nilill 1151
Ck.1I1 \\',11':1 AI:I Scuiun 3U1(b)
.B liS (' S.:~I iOlt 1251
.W CI'H 1!).1~1I-125.124
Iii I TI< ~ ~7.~~
l'k;all \\,11':1 ,kl SC~linn 4tH
Jj liS.'.. SLni1i1l 1251
-10 U:I< 1 ~I
«(J S U' \ 1'.1;)11 )
W. ",J. 1-' ~ ~III
1'11),011111' '11I1o;a1 ('lIlIlIcil
1<.::..11111""1 Nil. 1512H~C
I... \\. ~JII. I;) ,11111 IH..:W ~II,54
I'~ \\ 
-------
'fAilLE H. (CuutilollCtll
.---...
MediOi
Crilical 'iii,,, II}'
Vcllues A,hl".lh'::>
(rcferenn; .I. ..'::>,
carcinugellk I"IILII.)'
faclors)
Groundwaler
ARARs
Clean \\'011. 1 .\':1
-I
CoO
Resuun:e I ..11:.':1','.1
lion illld I..,. ,,\'el)'
ACI (I{CI, ',j
Safe Drilll,III!!
W..lcr ALl
Nalional 1'11111,11 y
Drinking \''',11<1
Slallllanb
t '11&.. iOIl
Prerequisites for ApplicabililY
Requirement
.---.- -----
IlIle!~I.II.:,1 I{hk Illformalioll Syslem,
[I'A t Ilike of Ilcalah and Envi-
I' HIIII': 111011 Assessmcnl
I kitllh LlleLl:. As:.c:.smcnls, Ilcallh
i..hl 1:11\ iit III mCIll 01 I EfI'ct:1S
f)dl:II,IIII'lIb. alltl ha:alah atlvi-
~lIlie:> 11l11i1 Ihe EPA Ollin: of
({..::..:.II da OIliti De\'clopmCnl and
Ola'il'" 1Ia' \VOIIC!'
Jj t I ::>,t', Set'lion 1251
-411 (1'1{ 1\&
(I L::> 1:1',\ I')~(I)
-III t, S,I', I.'JIII
-III Cn{~I.IIIII.211-4,1211. 2115.11U-
2.;) I 'I'
.411 'I-I{ !id')1I-2h4,IUI, 265.~)-
211),"1
-t2 I J.S I', Sed illll 111()f cl ~'c//-
.HI ,'1.1< 1.11 '
-to I 1,1{. IH
Thxicology indices used for esli-
maling heallh risks
Ambienl water quality criteria for
prolecling aqualic organisms and
human heallh
Closure and POSI-ciosure perform-
ance slandards
Groundwaler prolection standards
(maximum conlaminant levels
(MCLs» musl be mel
MCLs for maximum allowable
levels of conlaminanls in public
drinking waler
Sccolldary MCLs fur aeslhelic
qualilies ul' public drinking waler
Fur use in conducling risk assess-
menls; applies 10 bOlh sourt:cs and
sediment
Groundwater on the site; applies to
both sources and sediment (different
standards may apply to dilkrcnl
aquifer zones)
RCRA facilily closure; applia:s hi
sources only
RCRA facilily; applies 10 sa:dimcnl
(upland disposal)
Groundwaler used as publit: drink-
ing waler; applies 10 sedimenl
(upland disposal)
Groundwater used as puhlic Iii ink-
ing waler; applies to sedimClI1
-------
TAUI.E H.
(CIIIIII.IIIC,II
Media
l'ilalilln
Prerequisiles for Applicabilily
-. - - - ---
W.ncr 1'11111111.111
Control ,\d ;11Il1
W.ncr Hl::>IIIII'L::>
ACI
Air
J\RARs
Clean Ail
'..1
TPCs
- ~
-0
Pugel SlIlIlId .-\il
PUIiUliulI ""1111,,1
Agency ,glll.k hilL:.
SaliIqCDI. Suils, ,111.1 5111..1 Wd:>IC
ARARs
Thxic Sui. .I.II,.l::>
Contrul ,\, I
RCI~A
TPCs
Pugel 50111,.1
Dredged I.. j,'I:>,,1
Analy:.is (1'..1)1).\1
.--.- ..--
Requiremenl
l{l:W ~'II II') ;11 III I{CW ~"54
.I.! II S.J' Sl:'" h III 7..j1l1 c:1 st'tJ.
-hi': I-'I{ 1',111 )11
I'II~..I ~dllll,1 ..\i.. 1'lllIuliun CunlJol
. \gl.'lh \ gllhldilll:S fur an:eplable
,1111101<111 k\'ds (AAL)
D II S I ~.,III d !h~t/.
.hI l j'l, lid
.U II.S.I' 1.'/111
.111 .: 1-'1, -~. d~.I
I'~,j ,1)\ (1'/;;;-; I
Requires use of .AK.AR'B for con-
Irolling discharges 10 groundwaler
Ambient air qualily siandards for
chemicals and paniculales .
Sources muSI meel AAL guidelines
Soil cleanup level for PCBs
EP loxidlY lesl for conlaminanl
leaching Iriggers handling and
disposal requiremenls
Chemical and biological crileria for
dredged malerial disposal in Pugel
Sound
All direcl discharges; applies 10
sources only
Air quallay presenlly onsite or
during Irealmenl; applies tu SOllfceS
and sedimenl
Aclion will produce air emissions;
applies 10 sources and sedimenl
PCB conlaminaled soils; applies to
sources only (soils)
Conlaminaled soils and sediments
requiring land-based dispusal
Disposal of dredged malerial suil-
able for open waler, unconfined
siles in Pugcl Sound; applies hi sed-
imcnl only
-------
. 'rAlitE H. (C..u.i"lIclll
... -.-......
Mcdia
-------..
Puge. SUlllhl W.III:I
Qualily Milll.I!!':IIILIlI
Plan (PS\Vq \ 1~1l)";1
Diulngi(4t1 R~OUI,''''
c.o
o
TBCs
Fnnd and Illug
Adminisil ill h 'II
t'ilalion
Prerequisites lor Applicabilily
Requirement
I'S \\I}:\ l'lilll (1')1)/) Elemcnt P-2
I'~ \\"1'\ 1'1,111 (I ')1)1) Elemcnl P-3
I'S \\'11:\ 1'1,111 (I %~) Elemcnt S-4
I'~\\'.n 1'1;111 (1%1) Elemcnt S-7
oj') l H{ ItH'J~.III.N2
Sediment quality standards lor
~ntaminaled sediments
Criteria for sediment impact wnes
aud dilu.ion zones
Regulations for disposal 01 dredged
material exceeding Element P-2
s.andards
Guidclines for sediment cleanup
dedsiuns
Maximum concentrations 01
contaminanls in fish tissue
Actions involving sedimen.s having
adverse biological effects or human
heallh risk; applies to 5Cdiment
WdSlewaler discharges wilh dilution
:wnes; applies 10 sources and
sediment
Dredged material requiring confined
disposal; applies to sediment only
Applies to sedimenl exceeding
Element P-2 slandards
Inlerslate commerce 01 fish; appli..:s
10 sources and sedimenl
-"--.-. .
" Applkable or Id.... ilill illlJ ilIlIIlOIIlI'II': I "'I"II':lIIcnts.
b Other factors hi I.e LlllI:.j,ILI.:J.
-------
TAULE 9. MAJOR LOCATION-SPECIFIC
AltAlts FOR REMEUIAL ALTERNATIVES
LOl;a I it) II
-....- --------
( 'llal iun
Prerequisites for Applicahilily
AnA~.a
Wjlhin 1II().)'~.oi 11.1",1
plain
Wilhin lloolll'l.oi..
WCllanli
CoO
Occ:ans or W;lh .-. 01
Ihe: Unilcd SI..,,"
CommencclII':lIl 1i.I)i
Paayallup Ri\"':1 '-'-'.IILI-
sh~d
Wilhin :.Ial~ 1.1 ,''-.dl

IIlgII11I hOlIOllol, ,.. w..- t,
:.ilc
Requiremenl
"II l :Ht 2111.1;-)(11)
L.\~d'"'.: ().-.Ia II~~~
"II (1,1< I' .-\pp~ndix A
L.',,:lIlh-.: I )ld~1 II~~II
10 l I ;1< II . \1'1'~lItJix A
('kMI \\'.1..:1 Ad Scclions '-11"
;IIIJ .1111
"II CF!( 12)
HI':.:!) 0111,1 11011 hurs Apprupriaiions
,:',d s,;,lillll IU
I'u} .llIul' 'It Illc III' li.dians Sculc-
111.111 :\d of I~X~. PL-WI-41.
Illi ~,I.\T ni (21 Junc I~X~)
!\ J. . ,I, I I" I.:, I <1111101 AU (III i I i-
.111'.. '/.I.II"'I,"'I.! (IH'\"'). Llws
,II j'o,,'/
Hu;ilily muSI be consarucled, main-
lairi~, and operaled 10 prevenl
washoul
Aclion 10 avoid adverse effecls,
minimize polenlial harm, res lore
and preserve nalural and beneficia~
values
AClion 10 avoid adverse effecls,
minimize polenlial harm, res lore
and preserve nalur~1 and beneficial
values
AClion 10 dispose of dredged and
fill malerial requires a permit
Aclions which obsaruci or aller a
navigable walerway require a permil
Observe &ribal environmenlal slan-
dards. and slandards and require-
menls for cull ural and religious
preservalion
Enhance fisheries resources
Imposcs suhslanlive cleanup siand-
artl:.
::
RCRA hazardous wasle uealnu:nl.
slorage. and disposal; applies 10
sources and sedimenl
Aclion will occur in lowlands and
flal areas adjoining inland and
coaslal walers
. AClion will deslroy. modil'y. or
develop wellands; applies III sources
and sedimenl
AClions in oceans and walers of Ihe
Uniled Stales; applies 10 sedimenl
only
Obsaruclion or alteralion of a
navigable walerway; applies In
sedimenl only
AClivities affecling envirunmcnlal
quality including fisheries, hahilal,
surface waler, and groundwaler;
applies 10 sources and sedimenl
AClions which impaci fishclics
resources; applies 10 sedimclIl only
Source cOnlrol aCliuns lakclI ill :.lalC
-------
TA8L1~ 9. (Ccu..illuctll
--.---.
l.m:a I itlll
. ._n' . ".-.. -.
CQnlaminalcd 1'lllllLll)'
Wilhin 2()() k. I ..I
shurclinc
'1'110.'
W&:lland
( 'ilitliun
Prerequisites for Applicability
11.li,lululI:> W;ISle Managcmcnl Act,
UlolplCI '/11111) (WAC 173-303-420)
~llIlIdilic ~Iitn;agcmcnl ACI, RCW
~II 5~
1:1'.\ "'dl,ln,1s AClion Plan, EPA
0111<': III Waici anl.! WClland Pro-
ILd hili .l.lnllary I ~~~)
.__-0"_"_'--
Requirement
Presence of hazardous wastes
Subslanlive permit requirement
No net 1055 of remaining wetlands
base
Source control actions al areas of
contamination
Actions impacting within 2UO feCI of
shoreline
Dredge and disposal of dredged
material in wellands
U Applicable OJ"
" Olher "actors
(;0
t.)
I.. I.; n'II..hILIL".
III, \,1111 0111,1 ,lppUIIIII,IIC I <.:l1"IlCmcllls.
-------
TAIU.E 10. MAJOR ACfION-SPECIFIC
AItAlts FOR REMEDIAL ALTERNATIVES
( "ilal iun
Prerequisites for Applicabilily
AClinll
. ....----------
--_._- ._- ._-
AI~Atb41
LJI)land dispu~.d \ d..:.
un:) u" I~CH.\ 1..11.11,1
nus waSI~
Upland displl:...1 \,1111'
tainment) HI I, I f< ,\
hitzarduus \\';I~I.;
"'"
~
UI)land disl"",..1 11".:.1
dusurc) .
UI)land displl:.oI ..I
snlid waSI~ (II d.lllg';'
ous waSI~
.111 d.I': .~I..I.II, 2h.t221). 20.t25M,
~ii I HII
)1 n:l{ ~1I2
~II t 1.1': ~1".2211. 204.221, 204.301,
21,1 .\tH, .!!I.LUl4. 204.31U.
21". HI. 211X
~..llp;'11 I)
-II I t I I, -' II. 1
W. ".1 II) 1111
W. \1 I J I III ~ 1170-1111
\\' ,I U \ III ~.I-H
w.
Iii ill I 11111; .f!lI; (,1111;
idllt,1I1
Requlremenl
Removal of all contaminated
matcrial
Construction of new landfill onsite;
design, maintenance. and operation
requirements
Monitoring requirements
Functional standards for solid waste
handling
Designation of material as danger-
ous waste
'Itealmenl, storage. and disposal of
dangcrou,s waste
Provisions for facility design,
maintcnance. and closure
RCRA hazardous waSle placed at
site, or movement of waSIC "rom
one area 10 another; applics to
sources only
RCRA hazardous waste placed in
new landfill; applies to sources only
RCRA hazardous w~ste; applies It)
sources only
Material classified as solid wastc;
applies to sources and sediments
Material classified as dangerous
waste; applies to sources and
scdiment
Material classified as dangerous
waste; applies to sources and
sediment
Snils and sediments classilicd as
dangerous waste requiring land-
-------
'fAULt: 10.
CIIIII i lIue.1
Al:l ill II
Dredging and dl:.l'0:...1
of dredged llloIlLaial
0llcn-walCr ill..1 11':,11'
shure
Any aCliun illl..:.liug III':
mitrine CIl\'ill'hl..':1I1
c.o
~
Upland disl'"...1
(groundwalel 1,..jICL'
lion)
Incineraliun 01 dlcJgul
mUlerial
Dircci disd..11 ,', "I

!realmeUI S}',I, 'il
dnuclII
I'ilillion
. 0_- -----
tk..u \\,'ILI '\.:1 Sel:liun 41H
,III l:(-'I{ 12)
Ck:tu \\~IILr ALl Se':liun 4111
.11) d'H' I~:\
l{l:\V 7) !II,IIN)
W \1: ~~II.IIII
l'u},..lIul' 'liil,&: 0'- Indians Scttle-
111,'111 ..\d III I')X~. PL-atll-4I, 103
~r\L <), I!I JUlie I~~~)
l'u}.IlIul' Irill..1 Cuuncil Rcsululion
t'~iI j) I !;);)l ,
.111 I 'H< !C,.P.lI).2tl'UOI, 205.~O-
211),'11
,III I II, ,~hl..\1O.2o-l.~Jt). 265.270-
.!Ij). -~' 1'1
1'lIgd ~111I11l1 Air Polluliun Cunlrol
AgclI' Y 1'<.:111111 issuance
III . 1'1, I ').I.~ \(h), 12:\.122,
I!) I ' \pl II I I, illIll 12:).12-1
Requirement

Dredging in waters 01 the United
Slates requires a permit; action to
dispose 01 dredged material
requires a permit
Dredging or aquatic disposal 01
dredged material requires stale
waler qua lily certificalion
Requirement lor a hydraulics
permit
Ensure substantial restoralion and
enhancement of fISheries resources
Interim aribal waler quality Stan-
dards adopting Washington water
quality siandards
Groundwater monitoring at RCRA
disposal' facilities and general pro-
teclion requirements
Requirements for incineration 01
RCRA hazardous waste
Requirements lor incinerators to
achieve local standards, new source
requirements
Re1luircments and criteria including
compliance with fcderal waler
(Iualily nilcria and ~eSI available
Icdlllillogy (BAT); NPDES permil
le1Iu;'-";nls
Prerequisites lor Applicabilily

W.uers 01 the United Siales; applies
to sediment only
Applies to sedhnent only
Inlerference with natural waler now
01 Washington Stale walcrs; applies
to sediment only
Activity musl impact fisheries re-
sources; applies to sources and sedi-
ments
Surlace waters 01 the stale of
Wdshington (conventional waler
quality parameters only); applies 10
sources and sediment
RCRA hazardous waste; al)plies 10
sources and sediment
RCRA hazardous waste; applies 10
sources and sediment
Applies to sources and sedimenl
Direcl discharge 10 walers 111' Ihc
Uniled Siales; applies 10 sourccs
-------
TAUI.I!: 10.
11111 il.llc.1
Al:l iOIl
t'lIilllllli
. '
Discharge 10 'I jlubll.:!}'
owned Ircalll"-lil \\"11 I.:.
( POTWs)
Land lrealm~"1
Oaher Irealllh 1.1
'ffio..b
00
v.
Upland disl'lI:>.,1 "..
solid waSle UI .1.lIlg~I'
O&Ui wasle
Dredging .UIIJ .11.pu~.11
of dredged 111.11<:1 iil'
-- -.-
- --_. _. -..-
~II U.H .111\.5
~u CH< .!III.7I, 2h~,72
~(J CH< .!II,I.D'. 2h.t273, 264.276,
21iq7~, 2Id,~/)'. 2b.t2H2.
2.', I,~~; i
~2 lJ,S,(', iIlOI(d)(.1), 3UU.t(e)(3),
l,~12-!1,III,i). h'J2~(e)(3)
:'&11 rl~ ,111/211
.40 (I :.~ 2111
,Ill CH~ 2,,/), W.2MUJ
'lihlJlllil"'I~I'l'~ ('Ollilly lieallh
D..p,IIIIII~1I1 I<~gtllaliuns fur Sani-
lal}' . allJlllb (pending)
"ugd ~I'"II,I I )Iedg~d Disposal
A lIi"j "i:. II ');-;~ I
':1', \ W':lbwh Al:lilill P'an, EPA
011....- ,II \\'aln aud Weiland Pro-
1':1.11"11 I blltlill ~' . ~I)I)
Requiremenl

Requiremenas for discharges to
POTWs
Design, monitoring, and treatment
re
-------
9. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
CERCLA guidance (U.S. EPA 1988) requires that each remedial alternative be evaluated
according to specific criteria. The purpose of the evaluation is to identify the advantages and
disadvantages of each alternative, and thereby guide selection of the remedy offering the most
effective md feasible means of achieving the stated cleanup objective. While the nine CERCLA
evaluation criteria are all important, they are weighted differently in the decision-making process
depending on whether they describe a required level of performance (threshold criteria), technical
advantages and disadvantages (primary balancing criteria), or review and evaluation by other
entities (modifyina criteria). The 10 CB/NT candidate alternatives described in Section 8 were
evaluated under CERCLA according to the fOllowing criteria:
.
Threshold criteria
Overall protection of human health and the environment
Compliance with ARAR.!
Primary balancing criteria
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
Modifying criteria
State and tribal acceptance
Community acceptance.
\
\
.
.
Alternatives are discussed in the relative order in which they best meet the criteria (e.g.. those
alternatives that most closely meet the criteria are discussed first). Following is :J. description of
the evaluation criteria and the comparative evaluation of each candidate remedial altern:ltive.
9.1 THRESHOLD CRITERIA
The remedial :J.lternatives were first ~valu:lted in relation to the rhreshold.:riteri:1: uV~,:l!l
Jrotecrion or human he:1lth :lnd the ~nvironment :lnd .,;omoii:lnce '.\lith :~RA.Rs. 7)lC :tH::~~holi.i
';r;cerlJ. must 0e met by' the ~:lndid:lce Jitern:lcives i'Ur ;'urtl1er ~onslderJ.C1on :IS iemetii~:) ,'ur :ne
':(ecord ,)t' !)ecision.'
1).1.1
OvernH ?mtection of Human. Health :lnd the' Environment
)veraH orotec::ion of i,uman ne:uth :lnd the ~nvlronment ~eauires ~'!alu:ltion dr" ~10W 'veil -11e
:emedy :Iiminates. :eauces. or ..;oncrois :iSKS :rom ::lcn :xposure pathway: wnecher :11~re .1re
'macc~otable :~hort-:erm \Jr ';:'Qss-media imoacrs:lna ',vhecher ~~oosure :~'!eIS ,"or ;:rcinogens .:re
'jrou~nt ":l[l1in :ne ~:~~cot:lDie :':SII: ":m~e.
All alternatives except the no-action and institutional controls alternatives provide over:lll
protection of human health and the environment. The no-action :11temative fails to meet the stated
cleanup objective throughout all problem areal be<::WSe the existing threau to human health and
the environment are unaltered. The institutional control alternative does not meet the threshold
-------
criteria for protection of human health and the environment in large portions of most problem
areas because the exposure pathway to contaminants via ingestion of contaminated food species
remains unmitigated, and adverse biological effects continue to occur for an unacceptable period
of time. Bec:ause the no-action and institutional controls alternatives fail to meet threshold criteria.
they were no 10lller considered as feasible remedial alternatives.
9.1.2
Q)mpl1ance with AppUcable or Relevant and Appropriate Requirements
Compliance with ARARs requires evaluation of the remedy for compliance with chemic:a1-,
location-, .and action-specific ARARs (or justification for a waiver); and whether the remedy
adequately considers other criteria, advisories, and guidelines.
All alternatives except the no-action and institutional controls alternatives are able to comply
with ARARs at the site. All alternatives that require dredging may require variances as authorized
by the Clean Water Act allowing for temporary contaminant and turbidity levels that may occur
during dredging. Such waivers may be justified on the basis that long-term site cleanup will be . .
attained. Because the no-action and institUtional controls alternatives fail to meet the intent of
CERCLA and the NCP, they were no longer considered feasible remedial alternatives.
9.2 PRIMARY BALANCING CRITERIA
\
Once an alternative satisfies the threshold criteria, five primary balancing criteria are used td
evaluate other aspects of the potential remedies. Each alternative is evaluated by each of the
balancing criteria. One alternative will not necessarily receive the highest evaluation for every
balancing criterion. The balancing criteria evaluation are used in refining the selection of
candidate alternatives for the site. The five primary balancing criteria are: long-term effective-
ness and permanence; reduction of toxicity, mobility, or volume through treatmen~ short-term
effectiveness; implementability; and cost. Each criterion is further explained in the fOllowing
sections.
9.2.1
Long- Term Effectiveness and Permanence
In evaluating long-term effectiveness and permanence, the magnitude of residual risks :1S well
:1S the adequacy and reliability of controls must be ex:unined. The three removal/treatment/upland
disposal alternatives that utilize solidific:ltion. solvent extr.lction. and incineration have the highest
degree of long-term effectiveness and permanence because they reduce the potential for future
contaminant migration through destruction or immobiliz:ltion of contaminants. Confined :lQuatic
disposal :lnd ill lieu capping also provide a high lev~1 of long-term dfectiv~ness :lnd p~rmanence"
CJntaminated ,jredged material placed 'Jr covered in 1 5ubaQuatic ~nvironment would iso!::.re
,;oDClminancs i"rom the sensitive marine ~cosystem. The ~otenrill (or .;ontlminant migr:lCion '.\"OUIQ
:1150 be very low bec:1use these two alternatives would maintain the same anysicoc!1emicli ..:onai-
"Ions ;-05 :he originat materi:u. 'jpiand ::.na nearsnore LlisDOS:U ..ll1a IJna treatment ..re ..:ornDaraUVetv
:ess ~tTective and permanent than che alternatives :lamea lDove. Nhiie engineering -;onrrOtS maKe
uDland disposal more secure than nearshore disposal or land treatment. :lU three of these llterna-
:ivp.s :1:1Ve- the- potentia! for :ncre:1Sed .;ontaminant'migr.ltion due (0 physicochemical ,.;nanges ;n :he
iredqed material Jurin~ Jnd liter ~emediation.
'':':
1eriuc[.iun of -:'uxidty, _"'1()i)iiity~ "r "Illume .hn)U~h :"rc:umem
Evaluation of alternatives based on the reduction of toxicity, mobility, or volume through
treatment requires analysis of the fOllowing factors: the treatment process used. the toxicity and
nature of the material treated, the amount of ha:mrdous material destroyed or treated, the
irreversibility of the treatment. the tyge and. quantity of tre:1tment residue, and the statutory
prefel ellce far tre3~rtt ~ :I I'rirtcipaJ efement.
-------
The remedies that offer the greatest reduction of toxicity, mobility, or volume through
treatment are the three removal/treatment/upland disposaJ alternatives. The solvent extraction
alternative reduces the mobility and volume of organic contaminana by removing them from the
dredged material The solidification alternative reduces the mobility of COD~min~na but increases
the total volume of material. Incineration of con~mina.ted dredged material eliminates organic
contamination, but sediments with significant levels of inorganic contamination may be relatively
unaffected by incineration. Land treatment of dredged material reduces the toxicity of organic
chemicals, but the aerobic sOil conditions required for this alternative may increase the mobility
of metals.
While ;11 situ capping and confined aquatic disposal are Dot tteatment alternatives and
therefore do not reduce ,the ,volume, toxicity, or mobility of contaminants within the sediment
matrix itself, these alternatives isolate the material from the environment. Nearshore and upland
disposal alternatives also do not reduce the volume, toxicity, or mobility of contaminated sediments
and may a.c:tua11y increase the mobility of compounds in untreated dredged material due to changes
in physico-chemical conditions (e.g., redox potential).
9.2.3
Short. Term Effectiveness
Evaluation of alternatives based on short-term effe:ctivene5S requires an evaluation of th~
effectiveness of protection for the community and worken during remedial actions, environmental
impactS during implementation, and the amount of time required for remedial action objectives to
.be achieved.
The remedy having the highest degree of short-term effectiveness is in SilU capping, which
results in minimal exposure to workers and the public and no resuspension of sediment. In
addition, i1l situ capping caD be implemented very quicldy. The three removal/disposal alterna-
tives are the next most effective in the short term, resulting in minimal community exposure, low
worker exposure, and minimal resuspension of contaminated sediments. Confined aquatic disposal
is the most timely of the three removal/disposal options because it can be implemented Quickly,
whereas nearshore and upland disposal options involve siting and construction delays. The three
removal/treatment/upland disposal alternatives have still lower short-term effectiveness, resulting
in moderate community and worker exposure and some resuspension of contamin:lted sediment.
Further, these remedies would require 2-3 years for bench and pilot scale testing or facility
installation. The land treatment alternative is the least effective of all remedies in the short term.
resulting in moderate community and worker e~posure and requiring a long tre:ltment period co
attain remedial action objectives.
lJ ':.4
Implementability
The implementability criterion has three factors requiring evaluation: technical r'easibility.
.:dministrative' :'easibility, lna :he :J.vaiiabiiity 1)1' ;ervices :mci :n:lteriais. Tecnnical i'~:lsibiii[y
~eQuires :lQ ~vaiuation of the ability to ~onstruct and operate the technolo~y. ~he reliabiiity J[' :ht:
:echnolo~y. the ~ase of undertaki[1g ldditionaJ remedial action (if n~essary), :1Od monitoring
:onsider:ltions. The :lbility ro coordinate 'lctions with IJther J~encies is ,he unly ;':lctOr '.or
~vajuatJn~ 'ldmlnisuative t'easibiiitv. The waiiabiii[v qf ~en'ices :lnd materiais :-eauires evaluation
)t: :he "ollowln'J "~ctOrs: lvaiiaoiiitv ,)1' :re:ltment. ;tora~e ;apacity. ~mQ Jisoos:11 services:
'lvailabiiity of !'1ecessary eauioment Jnd specialists: :lOa availability of prospective :echnologies.
III SllU capping is the most ~asily implemented remedial alternative in situations where
navigational requirements do not impose depth restrictions. This option is a demonstrated
technology, and equipment and methods for implementation are readily available. Further,
sediment monitoring is easily impleme.n~ operation and maintenance requirements are minimal.
and multi-agency approval is feasible. Confined aquatic: disposal is die next most easily imple-
mented remedial alternative, having aU of the benefits of in SilU c::1pping except chat removal and
-------
subsequent confinement is less easily implemented. The confined aquatic disposal alternative can
be implemented onsite in a manner that allows continued navigation within the waterway. The
nearshore and upland disposal alternatives must address more contaminant migration pathways than
the confined aquatic disposal and in SilU capping alternatives. However. there is also more
oPPOrtunity to enaineer adequate control mechanisms and monitoring programs relative to the
open-water alternatives. The nearshore and upland alternatives can be implemented at onsite
locations (described in the feasibility study); however, because none of these locations have been
specifically identified as available and approved for disposal of contaminated dredged material.
they rank slightly lower.

The land treatment alternative is rated reiativeiy low for implemencability. This alternative
requires extensive bench and pilot scale testing, monitoring during active treatment, and agency
review for treatment facility siting and operation. Further. site availabil~ty for treatment is
uncertain. The three removal/treatment/upland disposal options, which are only in the develop-
mental or conceptual stages. are least easily implemented among all the remedial a(ternatives.
System maintenance for these alternatives is intensive during remediation. In addition. approvals
depend on pilot testing, and equipment for solidification and solvent extraction pt'oc:esses is either
in developmenw stages or unavailable. The incineration alternative is more feasible than the
solvent extraetion or solidification alternatives due to the current availability of incineration
equipment.
9.2.5
Cost
I,
In evaluating project costs, an estimation of capital costs, operation and maintenance costs,
and present worth costS are required. The cost analysis that was conducted for each alternative in
the feasibility study had several errors that resulted in underestimates of capital and monitoring
costS. Major errors included underestimation of unit costS for dredging and failure to consider
the excess volume of material requiring disposal due to the swelling of sedimentS during the
disturbance of dredging operations. Revised cost estimates were developed in the Record of
Decision for the four confinement options represented by the preferred alternative. In the
following discussion, cost estimates developed for the feasibility study are used to compare costS
among major categories of alternatives. The revised cost estimates developed for the Record of
Decision are used to compare costS among confinement alternatives.
In the feasibility study, remediation costS for each problem area were developed for selected
subsetS of the 10 candidate alternatives. The subset of the 10 candidate alternatives considered
to be applicable to a given problem area was determined on the basis of waste characteristics (e.g.,
solvent extraction was determined to be appropriate in areas where organic contamination was the
major form of contamination) and problem area characteristics (e.g.. ill SilU capping was not
.:onsidered for waterways with active shipping traificJ. Custs were developed t'or :wo options:
! i 1ctive remediation or all sediments exceeding the long-term cle:lnup objective. Jnd :) Jc:ive
~~mediation or' sedime~1ts not ;Jreaic:ed :0 recover :0 :he :ong-rerm ,,;!e:lnup ob.iec:lvevithin 1
~easonabie ;imeframe I i.e.. [0 years!. Candidate alternative .,;osts developed in :he t'easibiiitv sruav
:nat 1re :lSsoclated with Option': ',ue aresentea r'or (ne ~i~nt n.roolem ::.reas Jddressean :l1is
~ecord of Decision in Table 11. Although (he t'easibiiity study Jnd proposea pian recommenaed
:J. performance-based Record or Decision th:lt could utilize various sediment remedial aiternatives.
Jreierred aiternatjves were' identified tor ~:lch CB/NT oroblem 'lrea. :Specific 'liternatlves ',vere
~ecommended based on a combination on' aroblem area charac:eristics. 5cheduie I)r' :iource ,;ontroi.
:na :entative oiisposal ~i[e Jvaiiaoiiity. The :ota! estImated ";OSt 'Jr' :ne ;Jreferrea llternatIVes .'or :ne
~i~ht aroblem areas described in this Record or' Decision was approximately S i '7.500.000.
?~asibility 5tUay ";OSts lssoci:lted 'Nt[h incmeratIon ',vere ,he 3re:ltest. ,lOa ~xceeaea ,;osts
associated with all of the confinement options by a factor of 10. Solvent extraction was the next
most costly, exceeding costS associated with the confinement alternatives by a factor of 5.
Solidification was the third most costly alternative. typicaJly exceeding the confinement options
costS by a. fadar of 2.. The com ~t~ with. land treatment were comparable to the costS
associated with upland disposal, the most costly of the confinement options.
-------
   'li\UI,1! II. COSTS ASSOCIATIID Willi CANDIDAm ALTERNA11VE$'>"  
     (1110USANDS OF DOlLARS)    
  ----.-_6-_-..        
       Salldlft- Solvenl Ineiner- 
    Confined   callool Exaracllool allool 
   III Sltll Aqualk Nearshore Upland Upland Upland Upland land
 Problem Area l:appwg Disposal Disposal Disposal Disposal Disposal Disposal 'fiealmcnl
  -- ...... ------.-        
 llead 01 Hylcbu:;         
 Capilal   1,731 5,338 9,503  45,880 104,275 
 O&MC   376 421 572  551 551 
 lbl..1   2,107 5,15~ 10,075  46,431 104,826 
 Moulb 01 Hylcl>l ...         
 Capilal   1,773 5,597 10,013  48,568 110,461 
 O&M   2H9 336 475  453 453 
 lbUal   2,062" 5,933 10,488  49,021 110,914 
\D          
0          
 SilL"'.         
 Capilal   544 1,612 2,887 4,400   
 O&M   125 139 185 178   
 lbUd   669 1,75111 3,072 4,578   
 SI. r-..ul         
 Capilal  117!. 1,3"1 4,234 7,568  36,742 83,566 6,154
 O&,M  I.!o~ 21H 231 352  335 335 222
 lbliAl  I.IJ)-J.I 1,559 4,465 7,920  37,077 83,901 6,376
 Middk:         
 Capilal   461 1,409 2,481 3,791   
 O&M   179 165 205 199   
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TAttLE II. «('"... illllt:.I,
-,- .. n___-
-~--_.. .-
        SoUditi- Solvent Inclner - 
     ('nnl"inetl   cationl Extractionl ationl 
   /11 SI/II Aqualic Nearshore Upland Upland Upland Upland Lantl
Pmblem Area   l :;Ipplllg Disposal Disposal Disposal Disposal Disposal Dis~1 1h:almcni
 ..------        
II~ 01 Cily           
C~pilal     3,372 10,454 18,658 28,260   
Q&M     485 572 869 828   
1hlal     3,857.1 11,026 19,527 29,088   
Wbeelcr -Osgood          
Capilal    1-1-1 139 321 504  2,377 5,337 (1)6
O&M    .!)! }I 31 39  38 38 86
l"lal    Jill! nod 352 543  2,415 5,375 692
~ Mm..b 01 Cilyl,.          
u.pilal     233 682 1,174  5,726 12,992 
O&M     53 51 70  67 67 
'R.lal     286 733 1,244  5,793 13,059 
 .-. -.------ ".'--       
"Reference: '1i:11.1 'k.:!1 t l~ol$..),        
b 10 year natul..1 1..:~nn:I)' illduJ..:J III illh:lllilli\'c.       
&: O"M = 0P":',""III illIJ 1II.lillh:..,..".,,:,        
.I Pr~lerretl allclII..lin::. III l :UiNT k.l:>iIIl1i1r slIhly.       
~ In:ililuJional l:UI'I...h: ~;Ijiilal ~.I:,I II, (JJ.: 1\,1 ]-15, Inial 351.
>-
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Revised costS assoc:iated with the four major confinement options were developed for this
Record of Decision and are summarized in Table 12. The rationale for revisions to the costS
developed in the feasibility study are provided in Section 10.4. As described in Section "11.3, the
commed aquatic disposa1 option is most likely to be implemented on aD areawide buis due to site
availability considerations. Therefore, it is the onJy option for which areawide costS are presented
in Table 13. The revised areawide cost estimate for sediment remediation associated with each of
the eight problem areas addressed in this Record of DecisiQn is approximately $32,300,000,
assuming the use of in situ capping at the St. Paul Waterway and commed aquatic disposal in the
rem~ining seven problem areas. The costs of the other commement options are presented as a
factor of the commed aquatic disposal costs (i.e., alternative cast/commed aquatic disposal cost).
The upland disposal alternative, as noted in the evaluation of feasibility study costs, is the most
costly of the confinement alternatives. However, the tOtal range in costs estimated for all four
commement options is never greater than a factor of 7. and is more typically a. factor of 4 for the
different problem areas. Costs associated with in situ. capping and nearshore disposal are the
lowest. The low costs assoc:iated with nearshore disposal are explained in Section 10.4 as a
component of planned construction projects that reqwre fill materiat.
9.3 MODIFYING CRITERIA
The modifying criteria are used in the final evaluation of remedial alternatives. The tWo \
modifying criteria are state and tribal acceptance and communiry acceptance. For both of these \
elementS, the factors considered in the evaluation are the elements of the alternative which are
supported, the elementS of the alternative which are not supported, and the elementS of the
alternative that have strong opposition. Under CERCLA, tribes are provided substantially the
same opportunities for project oversight and implementation as those afforded to stateS. At present,
the opportunity for CERCLA oversight by tribes is often limited by environmental program
capability and experience relative to state programs. In the case of the CB/NT project, the state
is afforded co-lead statUS with EPA, whereas the Puya.ilup Tribe is currently afforded status as a
supporting agency, as described in Sections 3.4 aDd 5.1.
9.3.1
State and Tribal Acceptance
State and tribal acceptance is addressed in the Record of Decision r.lther than in the CB/NT
fe2Sibilitystudy because of their changing roles in the oroject during the public comment period.

As indicated previously, Ecology was the lead management agency for the CB/NT project
under a cooperative agreement with EPA throughout the study phase. including the remedial
:nvestig:ltion. f~asibility study. :lnd public comment period. State :lcceptance Juring that ;Jeriod
was based on their role as lead management Jgency. Ecology was instrumental in develooing the
r":v~ key :Iements ,)f the 5"elected remedy. ?!:lnnin~ 3'::1edules for integ~teC1 oroj~ct lmplemenrJ-
:ion were jointly prepared by E~olo~y :md EPA. During rhe public -:omment period. ecology
,-eouestea :hat C:P A JSsume :he !eaa t"or ,1eveloping :ne :\.ecord \)[ Decision I..lue :0 ~esource
.;onstraintS. However. Ecology has conunueo (0 play :J. key rOle in che development or' cne i~.ecora
at Decision.
::~)Qtinued ~tate ::lcceotance O[ :he :jetected remedy :s based :)n (Wo '-actors. First. :he selectea
~emeay :s .lesi~nea :0 'Je lS ;onsistenr ".lS ;Jossible ',virh ~mer~ing .;t:1te regul:ltions ~e~aroin~ :ne
:i1ana~ement of contaminated sediments. Second. Ecology has been <:!Smblished JS the lead .)versi~ht
:~enc': 'or ')oeraDle ";nl[ )5 ,Source '.:~mtrol), "t1e :"irst:na :nost.;ntic~1 ~;reo in .)vp.r~lIl')rol~C:
.mplemenrauon. :Juring :lecord 'Jt :Jecision le'leiopment :ne 'jtate ~rresseQ :he !1eed :0 ;';::J.ru'y
severa! project implementation issues. For example, the process by which EPA and Ecology will
determine the levels of source control which trigger the initiation of sediment remedi:1l design and
sediment remedial ac~ion in each problem area was raised as an important issue. Discussions
prompted clarification and adjustments to the over:111 projel:t !Cbedule State acceptance of the
selected remedy is evidenced by a letter of concurrence in Appendix A. '
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      TAIILE 12. ESTIMATED COSTS    
      FOR TilE FOUR CONFINEMENT OPTIONS.   
      (THOUSANDS OF DOLLARS)    
 . -.., . -- ..- ---- . -. --..-        
        Waterway    
    I kild uf Mouth of.    Head of Wheeler- Mouth of
 Alternative   , 'ylc:hus Hylebos Sitcum St. Paul Middle City Osgood Cityb
 - ......._---------         
 Volume (yd')   217,OlJO 231,000 66,000 174,000 57,000 426,000 11 ,GOO 
 In-W,..erway CIII,I illcd ,-\I~uil&ic J).:'~J(.s,,1        
 Containmt:11I ,:dst   ~ .tHlJ 3,300 1,950  2,670 5,110 967 
 Monitoring ...:,J:,( ('''11111411)  '))') 162 93  76 144 12 11.1
 Total costC   t).I.jO 5,710 3,360  4,150 1,630 1,360 101
 Cost nornlillilCd III LlJufillcJ         
 aquatic Lli:'I" IS.. 1'1    1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0
\0           
w            
 III Situ Capping           
 Containmelll ,-,1St       1,200    
 Monitoring ':\I,.t (iIlIlIlIill)      27    
 Total costC       1,820    
 Cost norm..liLcd to conJ'ined         
 . J' IJ   lI.tI 1 0.56 0.58 0.45 0.49 0.50 0.66 1.0
 aquauc 1:.1 idsa  
 Nearshore Dislw:...,1           
 Cost normallLcd td LLJuJ'illcJ         
 aquatic di:'1 H;:;iaJ.1   11.71 OJn 0.19 0.83 0.64 0.92 1.3 1.0
 1I1)land DislHtsal           
 Cost normidi...,1 III ,:ulilillcJ         
 . . r 1"   II) 2,7. 1.5 2.8 1.8 3.2 1.6 I.()
 aquatic l I:.", ,:,il  
        "    
 TOTAL AltEA\\'II,I:: t'lJS~; J'!, Hill'         
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TABLE 12. (Cu..liuul:ll,
_n .... -~----'--'- - ..,.
" AU alternativl.::' ilicolJJolill~ llilllll.ll h;wvery. See Sections .10.4 and 11.3 for further explanations and assumptions.
b Costs for MOIII!. lit" l :ilY Waten',',,)' I~p..esent monitoring costs only.
C Contingency - ~1J';c'
Adapinistratioll - 8,}~
Discount rate - "I %
Includes monilll,iug II\'~"
IU )'eaL;.
( indicated alternative )
confined aquatic disposal
e Combines ill ~iltl l:appillg Lost hh ~L Palll with in-waterway.confined aquatic disposal for remaining seven problem areas. .
d Preljented as il Lidul uf Lunfillc,! iHlllillk: Jispusill costs
\0
A
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Acceptance by the Puyallup Tribe has also changed over the duration of the project. Through
most of the remedial investigation and feasibility study the tribe provided comments on the, project
as a member of the Technical Oversight Committee. The tribe's commentS on draft documents and
their feedback in meetings were primarily concerned with the need to adequately address chronic
effects in the marine environment and to ensure protection of flSheries resources. As a supporting
agency for continued project management, the tribe has continued to express concern about the
permanence and effectiveness of the selected remedy. Many tribal members rely on subsistence
fishing in Commencement Bay and conrnminants such as PCBs and dioxins are of particular concern
because of their toxicity, persistence, and tendency to bioaccumulate in the marine environment.
Although the tribe has expressed concern about the impact of hazardous substances on fisheries
resources and human health, the Puyallup Environmental Commission regards the selected remedy
as an important means of mitigating and preventing those impacts. Tribal acceptance of the
selected remedy is evidenced by a letter of concurrence (Appendix A) which expresses both support.
for the remedy and concerns that it may be difficult to implement in a manner that will be fully
protective. The Puyallup Tribe's concerns may be addressed through continued participation in the
enforcement activities outlined in Section 3.
9.3.2
COIIIIIIUDity Acceptance
The agencies have carefully considered all commentS submitted during the public comment
period and have taken them into account during the selection of the remedy for the CB/NT project
as described in this Record of Decision. Based on the comments received during the public
comment period, members of the community are supportive of the overall approach that combines
source control, natural recovery, and sediment remediation (if necessary). Most commenters agreed
that there are demonstrable adverse environmental impactS in the CB/NT sedimentS, that the area
should support a multiplicity of uses (e.g., commercial, recreational), and that source control should
be a high priority.
Commenters expressed numerous divergent opinions on several key issues. These included the
environmental and human health risks posed by the site, the proposed cleanup goals, the feasibility
of and timeframe for source control, and the protectiveness and proposed role of natural recovery
as a component of the remedy. For example, some commenters said that there is no significant
human health risk, while others argued that the human tiealth risk is far greater than the feasiuility
study estimate. These various divergent comments have been considered in the selection of the
remedy and responded to in the Responsiveness Summary (see Appendix B).
Some commenters offered new information which led the agencies to modify the selected
remedy from the proposed plan. The Puyallup Tribe of rndians Jnd the NJtional OceJnic Jnd
,~tmospheric Administration raised 5ignificant habitat preservation :lnd fisheries ~nhanc~m~!H issues
:hJt ~~sulted in the :lgencies giving these issues JdditionaJ we:~ht in the remedy, \Iost :Jmme!He~~
:;e!ie':ed :hat the es!in:t:ltes for t"e:lsible source ~ontrol :lnd [he time nece:;sary :0 :1C:1 ie'''~ ;vU;':':::
:ontrol '.vere overly oDtimistic. These estimates have ~een revised. RemediJI;osts :1nd I,,'oiume
::-sumates ''vere '.;haHen~ed. ~1Dd ~JDon ,eVI~W, me '.t!~encies !lave ~evisea ,hese -=stimates dDWara.
.~SARCO provided new information about the sediments Jiong the Ruston-Pt. Defiance Shoreline
which resulted in that problem Jrea being separ:;1ted into J. new operable unit.
').4 OVERALL ~KING
:-ile cont'inement ::ltematives I J" ...:." 5. .lna ..,) ;"CDreSem q1e most .:! r'ec~i\'e ::no '~::sIi)k ::1e~ns
'Jf Jchieving overaU protection of human health :lnd the environm~nt :lt the eEl NT site. This
high overall ranking for confinement alternatives is a reflection of the general characteristics of
problem sediments at the eight CB/NT problem are:lS addressed here. CB/NT sediments Jre
characterized by relatively low concentrations of contaminantS which often have a high affinity for
sediment particle~ and the total. volume of sediments requirins active remediation. is ta.rge (i.e.,
greater than I million cubic yards as estimated in the feasibility study). Confinement of CB/NT
-------
o
sediments therefore offers the most appropriate and cost-effective means of achieving the cleanup
objectives for this site.
All commement alternatives can be implemented at the CB/NT site, minimizing the costs and
risks of transporting conr::tmip3ted sediments to distant locations. Qnsite disposal is also more
acceptable under Superfund policy and guidance than the offsite disposal of untreated waste
materials. In addition, performance monitoring for all confinement options uses well established
sampling and analytical methods. Given appropriate siting conditions, the in situ capping
alternative can be most readily implemented, and because it does not involve dredging of contami-
nated sediments, eliminates potential problems associated with conmminant redistribution during
sediment resuspension. Both in situ capping and in-waterway commed disposal alternatives have
the added advantage of preserving the original physicochemical conditions, which limits the
potential for contaminant mobilization associated with the transition from anaerobic to aerobic
conditions. However, in environments with a high potential for ship scour, currents, and wave
action, these two alternatives are more susceptible to disruption of the cap, and added protective
measures need to be incorporated into the design characteristics to ensure permanence. For
example, in navigable waterways the confined aquatic disposal alternative must be implemented so
that the top of the cap neither impedes shipping traffic, nor is susceptible to ship scour. Qver-
dredging to such a depth may require the placement of a significant amount of clean dredged
material out of the waterway to accommodate some bulking of contaminated sediments at the
disposal site.
In contrast, implementability of nearshore and upland disposal is much more dependent on
the availability of limited disposal sites. Potential loss of intertidal and wetland habitat is an
important consideration in both cases. However, nearshore disposal can proceed rapidly and be
cost-effective when the disposal facility is developed in conjunction with authorized shoreline
development projectS (e.g., fill operations). Habitat mitigation will be a key component of such
projects as required by Section 404 of the Clean Water Act. Upland disposal is also a viable option
that can be incorporated into property development projects or implemented on some of the
remaining vacant land in the study area.
Aerobic conditions at nearshore and upland facilities may enhance contaminant mobility;
however, a greater degree of control in the design, construction. and maintenance of the confine-
ment system is possible. While contamination of groundwater is more .likely in the event of failure
at an upland disposal facility, adequate engineering and monitoring can be developed to control
contaminant migration. Transport of contaminated sediment to the upland facility would also pose
additional worker and public exposure hazard in the event of a spill. Loss of intertidal habitat is
an important disadvantage associated with nearshore disposal. .
[n general. :111 of the treatment alternatives are more effective than the confinement alterna-
tives at reducing the toxicity. mobility. and volume oi ..:ontamination: however. in must ';Jses
'IVailable tre:ument technologies are not appropriate co [he ..:hemicaJ mi.uures (i.e.. mixed me(~is
lna Jr~:lnic ;;:Jmpounds.j that ;;haracterize ..:ontaminated sediments Jt the C3t :'-JT me. 7;le ;:;:'::'(~:
?ermanence of the treatment alternatives relative to the :.:onfinement Jlternatives does not .;usw""
~he !ncreasea cost 0" [reatinq sediments ::u [he C3/NT ~ite. CD/NT proolem ~eaimenrs .:re
reiativeiy low concentration/ high volume waste~ for which treatment is nor considerea JppropriJ[e
tJr cost-~ffective under Superfund.. [0 addition. these alternatives ::ue nor :lS readilv implemented
1S :he confinement :J.iterna[ives. in ,orne '.:ases reauiring :- 3 ;,Iears ot Qilot rests. :1nd ~herer"ore
)iferin~ :ess ;;~n:a.tnty :n cerms ')t :ong-rerm orOtection :md !ess <.:apaoiiiev \)( mieigatin~ ;u~nlfic::m
:hreats :0 11uman ,le::llth :.lnd rhe ::nvironmenc ;n ,he ~nort-{erm.
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10. SELECI'ED REMEDY
Based upon consideration of the requirements of CERCLAand the NCP, the detailed analysis
of the alternatives, and public comments, EPA, the state of Washington, and the Puyallup Tribe
have determined that Source Control/Natura! Recovery/Sediment Confinement is the most
appropn.te remedy for achieving the CD/NT cleanup objectives. The selected remedy represents
a generalized form of Candidate Alternatives 3, 4, S, and 6 by incorporating all four options for
confinement of contaminated sediments: in-place capping, confined aquatic disposal, nearshore
disposal, and upland disposal. The selected remedy is also represented by a specific combination
of the key elements described in Section 8.2: site us& restrictions, source control, natural recovery,
sediment remedial action, and monitoring. It is expected that the selected remedy will be protective
of public health and the environment, and will meet federal, state, and tribal ARARs. The project
objectives are to be achieved in a 15-20 year period by implementing these key elements in an
interdependent, integrated fashion. In general, however, because of differences regarding location,
environmental characteristics, and status of source control betWeen problem areas, the selected
remedy will be implemented independently in each of the eight CB/NT problem areas.
A remedy utilizing a generalized sediment remediation element was selected because all four
confinement options provide an effective means of protecting human health and the environmeht
. . at the CB/NT site. They are also comparable in terms of overall feasibility and cost-effectiveness.
By allowing the flexibility to utilize anyone or combinations of the four confinement options in
each problem ~ the selected remedy maintains the greatest degree of consistency with the intent
of the 1989 PSWQA plan (PSWQA 1988; Element S-4, Sediment Disposal Standards). It also offers
the best opportunity to implement the remedy in a timely manner while integrating the following
factors when appropriate:
.
Construction or development projects within the waterways
New information gained during the remedial design phase
Newly available disposal sites.
.
.
10.1 CLEAl'lUP OBJECTIVES
The objective of the selected remedy is to achieve accepcble sediment quality in a re:LSonable
timefrnme. This objective has been defined in terms of biological and chemical tests. :IS described
in Section 7 and summarized in S~ction 3.1. As described in Section 3.':. sampling and test
~val uation protocols for ~n vironmen ral ~ffects. as well :1S the .-\ ET database. :lre ro i'emJin
;ansis.em '.vith .lny adjustmentS .1dopted by :ne ?\lger Sound Escuary P:-ogram. 8ec~use :ne
)bjec:ive of the selected remedy is ro .1chieve rhe sediment 'Juality ~oaj in J reasonable :imeframe.
,~:ltUrn1 .-ecovery :s integrated into rhe overnil remedy. ,'-I:uurni recovery .;onsldernuons :.lre Ilsea :-J
identify :)ediment remedial Jction !eveLs that delineate sedimentS that :.lre JUowed :0 ,ecover
naturaHy from ~hose that reQuire Jctive sediment c1eanuo. The sediment quality objective .1lso
:.lcpties :0 30urce control reQuirements.\1oniroring of sources :md 3ediments will i)eJsed -0
letermine :he ~ffectiveness or :;ource controls. Habitat t'unction ::lnd ~nnancement 'J[' :'ishenes
resources ',viii ::lJSO be incorcorated JS part of che ()veraJI pro jeet ,..::e::1nup I)bjecrives. For example.
~he Jhvsical characterisrics ::tnd ofacement of material used t'or ::accin~ contammated :;ediments in
:rte :1anne ~nvlronment '.vIii :)e -eauired .,0 )rovlde ',;,;uJ(Joie;uosrr:lte :na :1~DirJr '.or ~CU:ltJC
organisms :hat may uriiize ~nat environment.
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10.2 KEY ELEMENTS OF THE SELECTED REMEDY
The selected remedy includes the following major elements:
.
Sice use restrictioDS
Source control
Natural recovery
Sediment remedial action (Le., confinement and habitat restoration)
Monitoring.
.
.
.
.
10.2.1 Site Use Restrictions
Site use restrictions consist mainly of public warnings and educational programs intended to
reduce potential exposure to site con~mination, particularly ingestion of contaminated seafood.
Local health advisories are an integral part of the overall remedy because the ultimate objective
will be achieved over a 15-20 year period.
10.2.2 Source Control
The general characteristics of source control at the CB/NT site are described in Section 8.2~2.
Implementation schedules for source control activities in the eight high priority problem areas
addressed in this Record of Decision are summarized in Appendix C.
The success of source control is evaluated using monitoring data, typically collected as part
of permit requirements. In addition to existing source control programs, Ecology is developing
several source-related regulatioDS and requirements to be implemented statewide. Ecology
requirements that are specific to Puget Sound, and which may be integrated into source control
activities, include the following:
.
Standards for identifying and designating 'sediments that have acute or chronic
adverse effects on biological resources or that pose a significant health risk to
humans

Definitions of acceptable source control technologies (i.e., AKARTs) for various
types of sources (e.g., pulp mills. sewage tre:ltment plants. shipyards. storm drains)

Administrative rules for establishing receiving water and sediment dilution zones in
the vicinity of wastewater discharges (the sediment dilution zone :s -:ommoniy
referred to :lS :l sediment impact zone. :l spe::ific Jrea Jdjacent ro J municioal or
!ndustrial .jischarge where sediment sr::md:lrds.lre rel:lxed oy ;Jermit; ~ediment
:moact zones may be established when rechnical :~:lSibility. rime. or cost iimits :he
:,:oiiity of J. uiscnarger m ~ompiv with ~ediment standarasl

Administrative rules for establishing sediment recovery zones in rhe vicinity 0f
'N'astewater discharges (a sediment recovery zone is :l variance r"or cleanuo Jctions
:0 '.lilow consideration Qr' rime. cost. :lnd technical ~"e:lSibiiity in :neering seaimenr
;;randards I
.
.
a
2
Guidelines for .jeterminin~ when the .:oncentrarion or !oadin~ r:lre f)[" .;hemical
;ontamlOants 'Iiscn:lr~ea (rom:.: ."ource '.:ouid ,~:':.cced 'ieaimem .:t:mU:lras
.
Chemical-specific concentrations or loading limits for source permits based on
AKARTs.
As the regulations and requirements are being developed. Ecology's Sediment Management
Unit staff have periodicaJIy outlined how they will be implemented. Effluent limitations will be
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derived for those contaminants remaining in an effluent stream after applying AKARTs. Pennit
requirementS will be used initially to address effluent and treatment system analyses when sediment
quality is - determined to violate interim sediment quality values, or final sediment quality standards.
when adopted. Sediment quality standards (or interim values) will not explicitly be used to derive
effluent limits, but they will be considered in the selection of appropriate treatment technologies.
A sediment impact and/or. recovery zone, which may be based initially on standardized size
constraints, may be established when treatment technology is inadequate. Results from monitoring
effluent and sediments will be used as feedback to technology requirements during permit renewals
and modifications. If monitoring reveals problems in meeting receiving water quality standards,
sediment quality standards, or permit requirements, then the adequacy of AKAR Ts will be
re-evaluated, technology more stringent then AKARTs may be considered, beyond-pipe main-
tenance may be required, or the sediment impact zone and/or recovery zone size may be altered.
10.2.3 Natural Recovery
Natural recovery of some or all of a given problem area may occur through chemical
degradation, diffusive losses across the sediment-water interface, and burial and mixing of
contaminated surface sediments with recently deposited clean sediments. Areas that are expected
to recover naturally within 10 years of sediment remedial action (based on modeling results
confirmed by monitoring data) are initially exempt from sediment remedial action (Le., confined
disposal). However, monitoring to confirm the long-term effectiveness of the recovery will be
required as part of the overall CB/NT selected remedy. Should subsequent monitoring data indicate
that natural recovery is not viable in a reasonable timeframe, the need for active sediment
remediation may be reconsidered. Areas that are predicted to recover naturally are detmed by the
following performance criteria for priority problem chemicals particular to each problem area, as
described in the feasibility study:
.
MIDi mum Chemical CODceDtratloD: Surface sediment concentrations exceed the
long-term cleanup objective (illustrated for indicator chemicals in Table 13)

Maximum Chemical CODceDtratloD: Surface sediment concentration are less than
sediment remedial action cleanup levels (illustrated for indicator chemicals in
Table 13).
.
The recovery factor is derived from a mathematic:1l model. SEDCAM. that relates recovery rate to
source loading, sedimentation rate, surface sediment mixing due to bioturbation and physical
disturbance. and existing levels of contamination (Tetra Tech 1988a). Recovery factors developed
in the feasibility study for selected indicator chemicals are summarized in Table 13. These
recovery factors will be modified on the basis of source loading and sediment data collected during
remedial design.
l().;,z.~ Sediment Remedial Action
The ~stimated surface :lreas :lnd sediment '/olumes in the CB/NT problem :lreas :hat :lre
subject to sediment remedial action are summarized in Table 14. These J.reas J.nd volumes J.re
,educed :rom the :ueas and volumes that ~xceed sediment QuaJity objectives on rhe basis -)(
,ecovery factors aeveloped Juring the feasibility studv. These :lreas :lnd volumes 'Viii De ~evisea
m ,he ~asis)[" sediment :amDling juring remedial Ijesi~n. T~ntative imolementation ~chedules :"or
5eaiment remediai action :lre summarized in Appendix C. These schedules are nighiy dependent
~oon [he :;uccessr'ui imOlementarion I)t" ;ource .;onrroi -lcrions.
ResultS of sediment sampling during the remediaj design phase will be used (0 refine ~stjmares
of the areal extent and depth of contamination to be addressed by the sediment remedial alterna-
tive. These data will also be used to identify tempor:1i changes in problem chemic:1l concentrations
resulting from sedimentation and from source control actiODS that occurred after the remedial
investigation/feasibility study sampling phase. Documented changes then will be used (0 refine
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TABLE 13. INDICATOR CHEMICALS AND RECOVERY FACTORS
Problem Area .
Head of Hylebos
Mouth of Hylebos
Sitcum
St. Paul
Middle
Head of City
Wheeler-Osgood
Mouth of City
 Sediment 10-year Remedial
Indicator Quality Recovery Action
Chemical Objective. Factorb Level'"
PCBs 150 1.6 240
Arsenic 57 1.7 97
HPAH 17,000 1.9 32,000
PCBs 150 2.0 300
Hexachlorobenzene 22 4.6 100
Copper 390 2.9 1,100
Arsenic 57 2.9 160
4- Methylphenol 670 1.9 1,300
Mercury 0.59 1.2 0.71
Copper 390 1.2 470
HPAH 17,000 1.3 22,000
Cadmium 5.1 1.3 6.6
Lead 450 1.3 580
Mercury 0.59 1.3 0.77
HPAH .7,000 1.2 20,000
Zinc 0.59 1.2 490
HPAH 17,000 1.5 25,000 .
Mercury 0.59 1.5 0.89
3 Concentration, expressed as Jo'8/kg dry weight for organics and mg/kg dry weight for
metals.

b Maximum enrichment ratio (i.e., observed concentr:uion/cleanup objective) in surface
sediment [hat will recover (i.e.. return [0 1.0) in 10 yeJrs.
; Target cleanup levels will .;hange based on source monitoring Jnd sediment remeJi:li
,.;esign jata.
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TABLE 14. ESTIMATED SURFACE AREAS AND
VOLUMES OF SEDIMENTS SUBJECf
TO SEDIMENT REMEDIAL ACrIO~
Waterway Area Volume
Head of Hylebos 217 217
Mouth of Hylebos !IS 230
Sitcum 6611 6611
St. Paul 87 174
Middle 114 57
Head of City 171 426
Wheeler-Osgood 22 11
Mouth of City. O' 0
TOTAL 792 1,181
a Areas are reported in units of 1,000 square yards. Volumes are
reponed in units of 1,000 cubic yards. .

b Includes sediment for which biological effects were observed for
nonindicator compounds.
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predictions of the rate of problem area recovery (Le., to develop refined recovery factors) and to
re-evaluate the need to implement sediment remedial action. In addition, sediment sampling
conducted during remedial design will provide a baseline assessment for subsequent monitoring to
determine the success of remedial action. Guidelines for developing source monitoring and
sediment remedial design sampling programs are provided in the integrated action plan (m 1988).
Habitat mitigation and ilsheries enhancement projects will also be incorporated into sediment
remedial actions. The scope and focus of these activities will be determined on a site specific
basis during remedial design. For example, the habitat restoration protocols being developed by
EPA's Region 10 Wetlands Program and Puget Sound Estuarine Program will be incorporated into
the evaluation and design process. -
In the following sections, the general characteristics of the four confinement options that
constitute the sediment remedial action element of the selected remedy are described in terms of
the factors that may influence their selection for all or a portion of the problem area. The choice
of conf'mement option ultimately applied to a site will depend on the results of the remedial design
phase, the status of available remedial technologies evaluated during remedial design, and
availability of disposal sites. These confinement options are described in greater detail in
Section 8.3 and in the feasibility study. The ultimate selection of a specific confinement option
or combination of confinement options for a particular problem area will also be affected by
economic and development considerations.
In-Place Capping-In situ capping involves contain~ent and isolation of contaminat~d
sediments through placement of clean material on top of existing substrate. In-place capping is
inappropriate for environments with a high potential for ship scour, current action, or wave action
because these disturbances. can lead to cap erosion. Currents in the CB/NT problem areas are
primarily tidal in origin and result in generally quiescent flow conditions. Maintenance dredging
precludes the use of capping in areas maintained for shipping navigation. Capping of sediment
with high concentrations of unstable organic matter may result in methane formation which can
produce bubbles and may potentially disrupt the cap as they float to the surface. The effect of this
process on cap integrity and contaminant migration should be evaluated in pilot studies. The
primary environmental impacts associated with implementation of this alternative is loss of existing
benthic and intertidal habitat at the site. Because of the high value placed on intertidal -habitat,
any loss of intertidal habitat would require corresponding habitat mitigation.
In-place capping may be determined appropriate during remedial design for those portions of
a problem area that are not subject to shipping traffic, or where shipping traffic could be
restricted. This alternative could also be included as a partial site remedy if remedial design resultS
suggest that it is appropriate to consolidate sediments :md restrict navigation in a portion of the
waterway.
rn-lJlaC2 ';:1Cping . has been selected as .he ..:onfinement ootion JPproori:ue to St. PJul 'V:lter',\i:lY-
.-\S described in Section 6.4. the Simpson Tacoma K.raft Company, in -:ooperation with E~ology,
1esignea ::md impiemented :he -.;appin~ uperation :hat :)e~an :n Decemoer ~ 987md ~:1aeu ;:1
'september 1988. The c:lppin~ project was coordinated with related ~emediai Jctions. inciuding
uredging for outfall aJi~nment. placement of material dredged from the outfall. Jredging llong .he
-:hio :Jnioadin~ (jock lnd ,he new ..:hip unloadin~ t'acility. :md in~ertidal habitat ~nhancement.
:=-utUre ;:;PA enforcement actions will expand response Jctions fe.g.,;ediment '11oni(Qrin~lc~IVl[ies)
~t :his problem area.
C.mlined Aquatic Dispusai--":unt'ined :lquatic aisposai invoives ,he 3uoaquatlcl.li:;posal ~na
capping of contaminated sedimentS. The hydraulic energy associated with the quiescent waterways
in the CB/NT problem areas is lower than in other shallow-water environmentS exposed to more
direct wave action. However, propeller wash and ship scour would be expected to significantly
increase subsurface energy in the ~w-waIer environment. 1£ sited ia. shallow water. the disposal
site should be located in an area that would not be dredged. :md where shipping traffic could be
-------
restricted. If sited in an active shipping area where future dredging is expected. the contaminated
dredged material and cap must be placed deep enough to preclude cap disruption associated with
prop wash and dredging activities. Details of in-waterway confined aquatic disposal are described
in the feasibility study (Tetra Tech 1988a) and Phillips et al. (1985).
Nearshore Disposal-Nearshore disposal involves dredging of contaminated sediments followed
by COni111ed disposal in the nearshore environment. The primary environmental impact associated
with implementation of this alternative is los5 of existing benthic and intertidal habitat at both the
dredge and disposal sites. Because of the intertidal location of the disposal site and the high value
placed on intertidal habitat, this alternative would require a habitat mitigation component. As a
general policy for the CB/NT sit!,. EP A would prefer that the nearshore disposal option only be
utilized in conjunction with projects that would otherwise be permitted commercial development.
The intent Qf this policy is to minimize unnecessary impact to nearshore habitat. consistent with
the provisions of Clean Water Act Section 404. Also. the influence of tides and groundwater on
con~min~nt transport would be much greater for nearshore conf"mement than for confined aquatic
disposal or upland disposal. In adclition, altered redox conclitions may increase the mobility of
metals, depending upon the level of placement within the disposal site. To the maximum extent
practical, sediments containing predominantly inorganic con~min~nts would be placed below the
water table level in the coni111ement facility to minimi7,! contaminant mobility. Nearshore
coni111ement may be determined appropriate during remeclial design for a problem area if it can
effectively be integrated into an ongoing construction and fm project.
'.
Upland Disposal-Dredging followed by upland disposal onsite would involve the transfer of
COD~min~ted dredged material to a conf"mement facility that is not tidally influenced. The primary
environmental impact of this remedial alternative would be destruction of the existing benthic and
intertidal habitat at the dredging site. As with all alternative! that involve dredging, resuspension
of contaminated sediment would also be a concern. Destruction of habitat at the upland disposal
site is likely to be less significant than at a nearshore site. However, implementation of this
alternative would involve risks to area groundwater resources in the event of contaminant leakage
from the containment facility. Transport of contaminated dredged material to the upland facility
would also pose additional worker and public exposure hazards in the event. of system failure or
spill. Disposal in an upland facility would result in significant physicochemical changes in dredged
material that could increase mobility of metal and organic contaminantS.
10.2.5 Monitoring
Source monitoring and sediment remedial design sampling and monitoring play a k~y role in
the refinement of the remedial altern:uive. bec:lUse for many problem areas the data ::lDalyzed in
rhe remedial investigation and feasibility stUdy were not adequate to I) fuily determine the
~r'fcc:iveness of source controls implemented ,0 date. or :~ Jet"ine the volume ut" 5edimem ~xc~~Lijng
,he c!eanup objective with J. high degree of confidence. Furthermore. severai source control .11.::ions
:i:J.ve been :mpiememeci since the source loaciing :.:naiysis '.vas i.:onciuctea. uata g:J.ps :.lSsoci:ltea Wltn
~ources ''viiI be J.adressed by the :;ource .;ontroi programs chat are directed oy Ecology. Source
monitoring data will be developed to characterize the discharge or release. the receiving body of
',Vater. 'lnd JSsociated sedimentS. :lccording to both chemica! :lnd biological parameters. Source
:oaciing data i i.e.. :neasurementS of the :J.mount of contaminant discharged ~o the various orobtem
.:.reasJ ;Jrovicie :ne :nOSt :mponam :niorm:uion l'or -ietermimng ,he ~t'fectiveness Jr' ~ource <.:ontrOls.
:he :elative contributions of problem chemicals oy ongomg sources. :lnd the neea i'or J.aditlonai
.-.Jurcc ';ontrOis.
Monitoring during sediment remedial design can be used to assess CB/NT feasibility study
predictions of the rate of natural recovery of a problem area and the estimated cleanup volume.
For example, if a problem area was predicted to have a very slow rate of natural recovery. but
results of the remedial design sampling (ndiQt~ that. the voWm.e. of ~rliment exceeding cleanup
gOals had decreased significantly since the CB/NT feasibility study and remedial investigation
-------
..
sampling, the decision to implement sediment remedial action may be re-evaluated. Similarly, if
a significantly slower rate of rec"overy is documented in areas predicted to recover naturally within
a reasonable time, sediment remediation may be required, rather than reliance on natural recovery.
Additional moniroriq may be advisable depending on the time lapse before implementation of the
sediment remedW alternative. Sediment monitoring will be required during sediment remedial
" action to establish a baseline from which to evaluate the effect of source control and natural
recovery in areas where natural recOvery is predicted to be a viable means of achieving the project
cleanup objectives.

Monitoring within problem areas, at d.isposal sites, and at habitat mitigation/restoration areas
developed as part of the sediment remedial action within CD/NT problem areas will be conducted
to evaluate the effectiveness of the remedy in achieving the sediment quality objectives and in
relation to habitat function, especially relative to fisheries resources. Sediment monitoring will be
used to develop data for priority problem chemicals within each problem area as described in the
feasibility study and other chemicals that may become of concern to EPA through source
monitoring or other related studies. Biological effects data may also be developed at the option of
the PRPs or the agencies to confirm problem area characteristics relative to the sediment quality
objectives. Habitat evaluation will be conducted in accordance with habitat restoration protocols
that are currently being developed by EPA's Region 10 Wetlands Program and Puget Sound Estuary
Program. These protocols will be incorporated into habitat evaluation in the CD/NT problem areas
before and after sediment remedial action at both dredging and disposal sites. These protocols are
being designed to quantitatively assess the characteristics of an area that contribute to habitat
function (i.e., feeding, refuge, and reproduction).
10.3 IMPLEMENTATION
Source identification, characterization. and control activities are underway in all eight problem
areas. In general, the remedial alternatives selected for the different problem areas will be
implemented independently of one another. For the SL Paul Waterway. source control and sediment
remedial action implemented under a state consent decree" were completed in September 1988. The
success of these actions is being evaluated through a monitoring program, which is to be expanded
by EPA to ensure consistency with this Record of Decision and long-term protectiveness of the
action. In the remaining seven problem areas. key elements of the selected alternative will be
conducted together or in sequence over a 15-20 year period. [mplementation schedules for source
control and sediment remedial activities for all eight problem areas have been developed for
planning purposes, and are provided in Appendix C. The timing of source control actions is highly
dependent on the avaifability of agency staff and fim:mcial resources, the success of negotiations
with PRPs, and the results of source investigation and control actions.
The successful implementation of the selected remedy requires that the key ~lementS of this
Re~ord of Decision" be carried out in Jn integrated. interdependent fJShion within ~ach probt~m
.Hea. Rei:ltionships JmQng the key decision points :lnd key ~Iements or" the :::eiec::eu ~emedy Jr~
iilustr:lted in Figure 18.
After signature or the Record 0[' Decision. ecology wiil continue to identify CD/NT sources
Jnd enrorce appropriate source control measures. Jnd enrorce those measures. Source monitoring
"viii be required by Ecology to evaluate the :dfectiveness ,)f ")Durce ..:onrrol ~neasures. Ecoiogy and
E?A '.viil evaluate the ~ource monicoring data cO Jetermine when source .;ontrol :s sufficient ~o
:;eqin the remediai Jesign phase t'or ~ediment ~emedj::u action in each problem :lre:l. Se'ler.l1 :"JCtOrs
will he considered in this evaluation. including the possibility of unidentified major sources within
one Irobiem :lre:l. :he :;t:ltUs ,)I" ;ource ~Ontrol" :"or ::nown major ':ourccs.~nd ":he ')ossicle ":umUl:lt1\'e
;r"fec:s '-rom other C3/ NT ~ources.
For each problem area, the remedial design phase will begin with sediment sampling to refine
the volume estimate of contaminated sediments exceeding the sediment quality objective and the
prPdi~ted aatu.ta1 recovery rate... ~ -~ia8 data will be used by EPA to dererm.iDe whether the
problem area, or portions thereof, will achieve sediment Quality objectives through natural recovery
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SOURCE
ACTIONS
- -- ..---..
- -- - .--- --- _. ~-_.-
SUUI ce
IduntiliLatioli.
Culilrol. and
Munitoring
...
[-
-~
No
------
. --------------
Yes
------------------
-------~-----
o
VI
SEDtMENT
ACTIONS
ROO blLilieli
~'"
---..-.-----.. ..-.-
Remedial
Design
. RBfine Recovety
Rale Estimate

. RBfine Spatial Extent
of ProblBm Are.

. SBIBct Confinement
Option
~
Key Decision Point
Source Control
and MonJIoring
No
Natural
Recovery
Yes
Remedial
Action
. ImplBment
Confinement
Option
. &gin '0- Year
RBCOV8f)' Period
~
Key Decision Point
TIME
~
Source
Monitoring.
Recovery
MonJIoring
Disposal Site
and Remedlated
Area UonMoring
I U. I~.;y uuci~iull pOIIlI:J and associated activities
- - - - -...-
-------
in a reasonable timeframe (Le., 10 years), or whether sediment remedial action is necessary in all
or a portion of the problem area. This information will also be used to suppan the selection of the
appropriate confinement option or combination of confinement options if remedial action is
determined to be necessary for a Particular problem area. '

New information on previously unidentified contaminants will also be evaluated during the
remedial design phase and integrated into the remedial design sampling and analysis strategy. For
example, recent sampling conducted by EPA as a part of a national bioaccumulation study has
indicated that dioxin may be present in shellfish in the CB/NT site at levels that pose a potential
threat to human health (Appendix B, Section 2.1.6). Preliminary evaluation of this data suggests
that further development of source- and sediment-related dioxin data in the Hylebos and St. Paul
Waterways is warranted.
FoUowing remedial design, source control and mOnitoring will continue until Ecology and. EP A
determine that all major sources have been controlled to the extent that sediment recontamination
is not prediCted to occur or the source is in compliance with AKARTs. Sediment remedial actions
wi1J then be implemented, including sediment monitoring to establish a baseline from which the
IO-year recovery period will be evaluated for all areas predicted to recover naturally.

There may be facilities or storm drains which, after implementation of AKARTs, still
contribute conmminllnts at levels that will exceed sediment cleanup objectives in the vicinity of the
SOurce. For these facilities, a waiver may be incorporated into applicable permits to allow a
temporary sediment impact zone. However, this will not delay or alter implementation of the,
selected remedy, and sediments within a permitted impact zone will be subject to the same remedy'
seleCted in this Record of Decision (i.e., recovery or conimement). Source monitoring will- continue
under Ecology's source control program. Post-remedial action SOurce monitoring will also ensure
that Source controls remain effective and that new contaminants are not being introduced.
As pan ,of the sediment cleanup action, EP A will develop and implement monitoring programs
for areas that are predicted to recover naturally, areas that have undergone sediment remediation,
and for disposal sites. Sediment monitoring wi1J conium that the selected remedy is effective by
I) tracking the progress of natural recovery, 2) managing permitted sediment impact zones, 3)
confirming the effectiveness and integrity of sediment confinement oPtions, and 4) ensuring that
Source controls remain effective and that new contaminants are not being introduced.
10.4 COSTS
Costs associated with source control activities are not included in this Record of Decision. but
may be developed as part of the individual Source control actions enforced by Ecology, Because
source-relatea Jcrivities Jre being ~nforced largely Jccording to ~xisting ~nvironmenral progr:lms
Jr the feder.ll. 5tare. and local levels. :lnd because the scope of these Jcriviries typically go~s beyona
:he :denrificJrion Jnd ~onrrol .Jf ~onrJmin:lnt iOJdin~ to .he mJrine ~rtvironmenr. ir :s ,~jt':-;I.:~lr :0
determine what proportio~ of total source-related COSt can be J[[ributed to mirigation of ~onr:lmi-
latea ~eaimentS. It is even more difficuit to Jetermine (he :ncrementaJ I.:OSt ur' :;ource :omrol ::l:lt
is airectly lttributable ro JChieving CB/NT project objectives. rei:ltive (Olchieving;omoliance
with non-CERCLA Source control requirements.
~stimated .;osts :lSSociated with sediment-related :lctions :lre summarized :0 TJble i:. :\evisea
;onc'inea <.1isoos3J;OSt lSsumotions were deveiooea e'or chis Kecord or" Decision. :;ummanzea)elOw.
Jnd detailed in Aopendix D. Costs Jre modified t'rom the estimates orovided in (he CB/NT
"~aslbiiitv ~CUdv 'iJSea ')0 'Iew ;ilr'ormation rcceivea 'Iurjn~ ',na ::r'ter :he ')uoiic ,:ommenr )er:oa
lna laairionaJ aiscusslOns With 'Jreaging '/enaors. CJStS ;lSsociatea with '.:onr'inea :.lqU:ltlc ..lispos:lJ
are dependent on the sediment volume estimates developed from available sediment data and rhe
natural recovery factors that were incorporated into sediment remedial action cleanup levels to
achieve sediment quality objectives within 10 years. Sediment cleanup volume estimates will be
efined during the remedial design phase and costs are anticipated to change accordingly.
-------
Costs are also affected by engineering considerations that cannot be fully evaluated until
remedial design is completed. The cost estimates presented in Table 12 are based on volume
estimates for sediments that are not predicted to recover to the sediment Quality objectives in a
reasonable time frame (Le., 10 years). Other assumptions are:
.
The sediment. volume to be dredged is composed of a whole number of 4-foot
dredging lifts. . This assumption incorporates an overdredging allowance.

Dredged material swells by 75 percent as a result of water entrainment. Upon
redeposition, compaction will reduce the volume to an amount only 20 percent
greater than the initial volume.

Excess volume generated by swelling of overdredged sediments at in-waterway
confined aquatic disposal sites is disposed of at the PSDDA site. This material is
assumed to be clean, as it originates from below the contaminated sediments.

Sufficient Puyallup River sediment is available to carry out habitat mitigation for
the nearshore disposal alternative.

As a general policy for the CB/NT site, EPA would prefer that the nearshore
disposal option only be utilized in conjunction with projects that would otherwise
be permitted commercial development. Site preparation costs are to be assumed by
the developer and are not included in these estimates. For the purpose of estimating
transportation costs, the Blair Waterway slips, which are centrally located, are
assumed to be available and of sufficient capacity for at least some projects.
.
.
.
.
A different assumption regarding the implementation of the confined aquatic disposal option
was also incol1'orated into the revised cost estimates. Implementation of the confined aquatic
disposal option was assumed to be onsite, rather than at the offsite location described in the
feasibility study. The offsite location was determined to be problematic due to' technical considera-
.. tions (e.g., the depth was 100-200 feet) and because transport of untreated sediments to the facility
would be in conflict with the Superfund offsite policy.
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11. STATUTORY DETERMINATION
Under CERCLA, EPA's primary responsibility is to undertake remedial actions that assure
adequate protection of human health and the environment. In addition, Section 121 of CERCLA
established several other statutory requirements and preferences for cleanup. These specify that
when complete, the selected remedial action for the site must comply with applicable or relevant
and appropriate environmental standards established under federal, state, or tribal environmental
laws unless a statutory waiver is justified. The selected remedy must also be cost-effective and
utilize permanent solutions and alternative treatment technologies or resource recovery technologies
to the maximum extent practicable. Finally, the statute includes a. preference for remedies that
employ treatment that permanently and significantly reduces the volume, toxicity, or mobility of
hazardous wastes as a principal element. The following sections discuss how the selected remedy
meets these statutory requirements.
11.1 PR.OTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy protects human health and the environment through source control
measures that eliminate major sources of contaminants to the marine environment, especially in\
relation to bottom sediments in each of the eight CB/NT problem areas addressed in this Record
of Decision. The remedy also provides for sediment conf'mement measures that isolate contami-
nated sediments from sensitive and edible marine resources. Sediment conimement options include
in SilU capping, confined aquatic disposal, nearshore disposal, and upland disposal.
In the CB/NT area, the current risks to public health are associated primarily with consump-
tion of seafood organisms that have accumulated PCBs from conrnminated sediments. For baseline
conditions evaluated during the remedial investigation, the estimated lifetime risks associated with
consumption of 1 pound/month (15 grams/day) of Commencement Bay fish were about 2xlO~.
Remediation of sediments containing over ISO ~g/kg PCBs should result in fish tissue concentra-
tions similar to those in fish from Carr Inlet, a relatively uncontaminated reference area in Puget
Sound. Sediment remediation at this level would reduce the excess lifetime risks associated with
PCBs contamination in Commencement Bay fish to about 4x 10.5 for a seafood consumption rate of
12.3 grams/day, which has recently been identified as an average fish consumption rate for the
Puget Sound area. Those individuals who are consuming seafood from the CB/NT site at a greater
or lesser rate would experience, respectively, greater or lesser :lSsociated risks. This :lverage post-
remediation risk level is within the acceptable range of risks (10.7 to 104) for Superfund siees.
Contamination of CB/NT sedimentS by 1 wide variety of org:1Dic and inorganic -:hemic:lls has
Jeen shown :0 result in substaneial :J.dverse dfecrs :0 biological resources. Effects :-tave ::een
demonstrated using :J. preponderance-of-~vidence :J.pproach [hat incorporated multioie bioiogic:l1
::1aic:ltors O[ seaiment toxicity (sublethai :lnci ;etnal) :,md Jirect effectS on ~enthic iniauna ::.na ,'isn
'.;ommunieies. 3ecause ot" the documented impactS m biological resources :lnci poeentiai impacts ,0
human health that are evident in the CBI NT problem :lreas, ehere is a presumption of harm andl
1r 111 imminent threat posed. by contaminantS in these areas. [n 'Jrder to ;je protective 1)[ :Jotn :he
?uolic ;leath Jnd ,he ~nvironment. a :;ediment IJuaJity 00 jective has been ~staoiisnea ~'or ,hese J.reas
:n 'vnich 1 :10 1averse ,:ifectS !evei was :neasurea ;)y :he ,hree iJiotogical ;naic:ltors '.lna :1Uman
~ealth assessment methods descrIbed in this Record of Decision. These biological effectS indicators
:.'p.re ':iso 'lsea :0 develoo '~mOJriC:ll ::edimem Juaiiev "alUes ~E; :hat ~c!:1[eneasurea "iOlog!C:l!
:Ifects :O;:)Dc~ntratlons ;)i .;hemic:ll ;omamlnants. ..,r:l1idaeion seuaies ;0 ?uget ";ouna ,lave
demonstrated that AfT have a high reliability (86-96 percent) in predicting the presence or absence
of adverse biological effectS. Therefore, remediation of Commencement Bay sediments to
contaminant levels based on AET should ensure that biological conditions would improve to levels
characteristic of Puget Sound reference areas, the function of hi&h quality habitat would. be
restored, and fisheries would be enhanced.
-------
11.2 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIRE-
MENTS '
The selected remedy of Source control, natural recovery, and sediment confinement (i.e.,
in situ capping and/or onsite dispOsal) will comply witl1 all action-, ChemiCal-, and location-
specific ARAR.!. The ARARs are presente~ below.
11.2.1 Action-Specllic ARARs
Sediment remedial activities (i.e., capping, dredging, and/or disposal of contaminated
sediments) will meet the following action-specific ARARs:
.
RequirementS for upland disposal of RCRA hazardous waste as established in
40 CFR 246, 264, 265, 268 Subpart D, and 52 CFR 8712

Washington state Hazardous Waste Management Act (RCW 70.105) requirements for
upland disposal of solid waste, dangerous waste, and extremely hazardous waste as
codified in WAC 173-303-081 and WAC 173-303-650

Substantive requirements and guidelines of Clean Water Act Section 404 (40 CFR
125) as implemented by the Corps and EPA (e.g., for dredging and dredged materials
management, including designation of disposal sites)

Requirements of the state Water quality certification process pursuant to Clean
Water Act Section 401 (40 CFR 125) (i.e'., actions must not result in a violation of
water quality standards or other state policies, requirements, and laws that pertain
to tl1e aquatic environment and beneficial use protection)

Substantive requirements of the Washington Department of Fisheries and Washington
Department of Wildlife hydraulics permit (e.g., design and performance constraints
and timing of action)

Requirements of Washington Model Taxies Control Act (Initiative 97) for managing
hazardous waste site cleanups, Chapter 2, Laws of 1989

Washington Shoreline Management Act requirements for activities conducted within
200 feet of shorelines of statewide significance (RCW 90,58. WAC 173-14)

Washington state requirements for interference with the natural flow of srate Waters
as set forth in RCW 75-20.100 and WAC 220-110

The Puyallup Tribe of rndians Settlement Act of 1989 (public law 101-41. : I June
1989) requiring substantial restor:ltion and enhancement of the fisheries reSOurce in
the Commencemenr Bay lrea
, \
.
.
.
.
.
.
.
.
J
Puyallup Tribe Water Quality Program (Puya1fuo Tribal Cuuncil R~sOluti()n ""',
i 1238) aOopting \Vasl1lngton .vater Quality Standards Jnd protecring fishing ;'lg!1tS.
i;aoitJt '!aiues. ~urfa::;e Water. ~~nd ';roundwater.
Source .;ontroL activities will meet the following action-specific .-\RARs:
~
"J
.
Washington scate Hazardous Waste \1ana~ement ACt {RC'.V 70.105) iequiremencs ,'or
'jpiand .Jisposai oc" ':olid WaSte. .jan~erous Waste. ::nd extremeiy :Iazaraous 'V:1sre ::s
,;oaified in WAC 173-303-1)81 :lnd WAC 173-j03-Q50
,~eaujremencs "c' . "'asn jn~con'..loael :-()xi~:: ,-'0ncroi ,'.c.;t 'I nai;lti \'e 17',",)r :~:111:1~!:: \!
;1:lZaraous Waste SHe "':leanups. Chaprer :, Laws or" j 989

Requirements for discharges [0 publicly Owned treatment works as established in 40
CFR 403.5, 264.71, and 264.72
-------
.
Conditions stated in the pertinent NPDES penn its governing direct discharges
including storm drain outfall to Commencement Bay waters (40 CFR 125.122,
125.123, 125.124)

ConditionS stated in the pertinent pretreatment permits governing direct discharges
to city of Tacoma sanitary sewers

Puyallup Tribe Water Quality Program (Puyallup Tribal Council Resolution No.
71288) adopting Washington Water Quality Standards and protecting fishing rights,
habitat values, surface water, and groundwater

Washington Water Pollution Control Act (RCW 90.48) requirements governing
discharges of any pollutant to waters of the state

Washington Shoreline Management Act requirements for activities conducted within
200 feet of shorelines of statewide significance (RCW 90.58, WAC 173-14)

The Puyallup Tribe of Indians Settlement Act of 1989 (public law 101-41, 21 June
1989) requiring substantial restoration and enhancement of the fisheries resource in
the Commencement Bay area.
.
.
.
.
.
11.2.2 Chemical-Specllic: ARARs
Sediment remedial activities may be required to meet the following chemical-specific ARARs
depending on the activity in question (e.g., dredging, dredged material disposal): \
.
Limiting permissible concentrations established by 40 CFR 125.120-125.124; 227.22,
and ambient water quality criteria for protecting human health and aquatic organisms
established by 40 CFR 131

Groundwater protection requirements for .RCRA facilities as established by 40 CFR
264 and 265

Federal requirements for groundwater used as drinking water as set forth in 40 CFR
141 and 143

Federal regulations (implemented by 40 CFR 261.24) requiring an extraction
procedure toxicity test for contaminant leaching trigger handling and disposal
requirements

Washington water quality standards for surface waters (WAC 173-201)

Water Pollution Control Act (RCW 90.48) and Water Resources Act (RCW 90.54)
require the use of -AKARTs for controlling disch:uges to surface water ::md
groundwater.
.
.
.
.
.
The J.bove standards may be exceeded on 1 short-rerm. ioc:llized basis .jurin~ dredging 'lr,eJin~~:-::
,iisposai 'Jperations Jue [0 resuspension of -;untamin:Heu .eliiment.
':;uurce control :lctivities wiii meet the l'oHowing ...:nemica!-specific ,.:..RARs:
]I
Water Pollution Control Act (RCW 90.48) :lnd Water Resources Act I RCW qO.5~)
,eQuire ,he use ot' ,-\KARTs for ...:ontrolling .jischarges to mrt'ace water ~md
~rounawater

Tecnnoiogy- basea $t:lndards establisned in Cican Water Act S~ctiun 301 (b,
11
']
:":rnitIn~)erml~Sli)ie_oncenrr~ul()ns ; ()rjiscn:lr~es . :HO ,l1anne 'vaters )urSU~1H .j
~O CFR i:5.1:0- i:S.!:.+; ::7.::
.
Ambient water quality criteria for the protection of aquatic life :lnd human he::llth
established by 40 CFR 131

WashingtOrt water qualicy sr:mdards for surface water:tS eSCtblished by WAC (13-
201.
.
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11.2.3 Location-Specific ARARs
Sediment remedial activities will meet the following location-specific ARARs:
.
Clean Water Act Sections 404 and 401 (40 CFR 125) substantive requirements for
dredged material evaluation and impacts assessment (including wetlan4s protection)

Rivers and Harbors Appropriations Act Section 10 substantive requirements for
protecting navigable waterways

Puyallup Tribe Land Claim Settlement requirements for actions that impact fisheries
resources in the Puyallup River delta

Executive Orders 11990 and 11988 (40 CFR 6 Appendix A) to avoid adverse effects,
minimize potential harm, and restore and preserve natural and beneficial uses of
wetlands and floodplains.
.
.
.
Source control remedial activities will meet the following location-specific ARARs:
.
Washington Shoreline Management Act requirements for activities conducted within
200 feet of shorelines of statewide significance (RCW 90.58, WAC 173-14)

Washington state Hazardous Waste Management Act (RCW 70.105) requirements for
upland disposal of solid waste, dangerous waste, and extremely hazardous waste as
codified in WAC 173-303-081 and WAC 173-303-650 .

Requirements of Washington Model Taxies Control Act (Initiative 97) for managing
hazardous waste site cleanups, Chapter 2. Laws of 1989.
.
.
11.2.4 Other Factors To Be Considered
Sediment remedial action will consider the following:
.
Requirements and guidelines for evaluating dredged material. disposal site
management. disposal site monitoring, and data management established by PSDDA
(1988)
.
Critical toxicity values (acceptable daily intake levels, carcinogenic potency factor)
and U.S. Food and Drug Administration action levels (for concentrations of mercury
and PCBs in edible seafood cissue)

Pending TPCHD regulati~ns for sanicary landfills

Substantive land use reQuir~mencs tHO lhe Tacom:.1 Shoreline \Iasrer Progr:1m
.
]I
'1
£P..J. Wet/and .~c!i(JIl Plan iC.S. EPA :989) describing 'iational \\'<:,~l::lnd Poii,;:: .1nu
;oa1 of no net lOSS

:989 PSWQA plan IPSWQA 1988) Elements ?-l. :.lna ?-~ '-or -:edimenc .1u:.1li[\,
.>randards and sediment impact zones
1
:::I.
[989 PSWQA plan (PSWQA ! 988) ElementS S-..t S- i, :.md $-;) t'or;oniined disposal.
:ieanuD decisions. :md (nvestigations Jna dean ups 1)[- -:ol1t:lmil1area seuimenr.
Source ,;onrrol Jctions will -:onsider [he foilowing:
J
.:..K.:..ir;- _~ul(.ie:il1es :l!1U :~)g<) i)S\\'QA :)1:.111 (PSWQA ,;)88) a~:nenrs j'--) .alU'-- .0[-
the development at' AKART guidelines and effluenc limits for toxicants and
particulates

1989 PSWQA plan (PSWQA 1988) Element P-3 for the development of criteria for
defining ~ediment impact mnes relative to ~harge:L
.,
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11.3 COST EFFECI'lVENESS
The cost of the selected remedy is described in terms of sediment-related activities only,
because source controls are being enforced largely according to non-CERCLA environmental
authorities and pro8J'8Dl5. The net present worth value represented by in situ capping for St. Paul
Waterway js estimated to be $1,820,000 (actual costs for capping nQt provided by Simpson Tacoma
Kraft Company for thjs Record of Decision). The cost of implementing the selected remedy in the
remaining seven problem areas will vary according to the types of confinement options actually
utilized. Because the confined aquatic disposal option can be implemented within each problem
area. site availability js less of a limiting factor. It is therefore the most likely option to be
implemented on an areawide basis and is the only option for which areawide costs are presented.
The net present worth value for implementing confined aquatic disposal in the remaining seven
problem areas js estimated to be $30,500,000.
The total estimated cost of sediment-related activities in all eight CB/NT problem areas
addressed in this Record of Decision is therefore $32,300,000. Costs associated with in situ capping
are approximated a factor of 0.5 less, costs associated with nearshore disposal are approximately a
factor of 0.8 less, and costs associated with upland disposal are approximately a factor of 2 greater
than those associated with confined aquatic disposal. It is expected that the remedy implemented
at these problem areas will represent a combination of these commement options, which would be
reflected in actual costs. Revisions in estimates to the cleanup volume based on the results of
remedial design sampling are expected to have a maj()r impact on these cost estimates. However,
the selected remedy js cost-effective because it has been determined to provide overall effective-
ness relative to costs of the other remedies evaluated for sediment remedial action.
Because natural recovery is included as a key' element of the overall alternative, the estimated
costs of the remedy are approximately one-half of what they would be if the remedy did not
incorporate natural recovery over a 10-year time period. The estimated costs of the selected
remedy are at least one-tenth of the costs associated with incineration, and at least one-quarter of
the costS associated with treatment of sedimentS by solvent extraction, and at least one-half the
costs associated with solidification. These comparisons to treatment costS are derived from
feasibility study cost estimates, which are assumed to be valid for comparison purposes.
By providing for flexibility in the disposal site option, the selected remedy provides a cost-
effective means of achieving the project objective: acceptable sediment quality in a reasonable
timeframe. Nearshore disposal can be integrated into planned construction projectS that require
fill. Similarly, disposal location siting can take into consideration the unique use requirements of
each of the remaining seven problem areas to minimize economic impactS associated with
implementation of the selected remedy (e.g., shipping traffic disruption), or associated with
projected uses of the waterways.
~lA UTILIZATION OF PE-rL'\1ANENT SOLUTIONS AND ALTElL'\fATIVE T:lZ.\7~,IE:'IT/
TECHNOLOGIES
.sPA :.lod ~he state of Washington have determined that the ::ieiected remeay reoresents ,:ne
maximum extent to which permanent solutions :lnd treatment technoiogies can be utilized in 1
:ost-effecrive manner Jt the CB/NT site. Of those alternatives that lre ;Jrorective of human heath
~nd rhe ~nvironment :md ;omoiy with ARARs. EPA lnd the state have determinea cnat :he
~e!ecred ~emedy :Jrovides (he ~est ;)alanCe or' cr:1deorTs in :erms ,jf ;ong-~erm crTectlveness:na
permanence: reduction in toxicity, mobiliry or volume achieved through treatment: shorr- term
"! fecriveness: :molememaDiiitv; ',na ';ost.7"he ':eiecrca'emedy :.:iso ,)t'fers:he ,1i~nest.l~~re~ 'f'
,)ver:l1i :.:cc~ptance 'vy ,he ::;t:1re. trice. lnd Jlfecrea .;ommuQlcy.
While the selected remedy does not include treatment (i.e., solvent extraction, solidification,
incineration) as a principal element in sediment remedial actions, it will significantly reduce the
inherent hazards posed by the contaminated sedimentS through isolation and source control. The
-------
principal threat posed by contaminated sediments is through exposure of resident benthic communi-
ties living at or near the sediment-water interface, fish that feed on benthic organisms or live in
close ~sociation with surface sediments, and humans who consume organisms that have been
exposed to the sediments and have accumulated contaminants. Burial of the contaminated
sediments, either through natural accumulation of clean sediments, or through confined aquatic
disposal, eliminates the potential.rates of exposure. Source control ensures that this very sensitive
interface will not be recontaminated,. and monitoring verifies that source controls and sediment
remedial actions have been effective.
11.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
This decision to confine sediment either in-place or in onsite disposal facilities is consistent
with program expectations, which focus treatment technologies on more highly toxic, concentrated
wastes~ In general, sediment contamination at the CB/NT site is characterized by very large
volumes of low concentration material. Because contaminant releases to the marine environment
have often been slightly dispersed in the water column as they settle, and are further mixed with
clean, naturally occurring particles as they accumulate on the bottom, they tend to be relatively
dilute as compared to more concentrated waste materials. Furthermore, contaminants that have
accumulated in the sediments typically have a sttong afimity for particles. Thus, once in place,
most sediment contaminants are relatively stationary unless the particles with which they are
associated are disturbed and remobilized. The potential for remobilization of particles within a
conimed disposal facility is relatively remote if the facility is properly designed and engineered.
. .
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, .
12. DOCUMENTATION OF SIGNIFICANT CHANGES
The proposed plan for the CD/NT site was released for public comment in February 1989.
The proposed plan described the preferred alternatives identified in the feasibility study for the
nine problem areas then included in the investigation, and identified a more general performance-
based alternative as the preferred alternative. Since that time, the fOllowing changes have been
made: "
1.
Project Scope: The problem area designated Ruston-Pt. Defiance Shoreline has been
established as a separate operable unit for the site: Operable Unit 06 (ASARCO
Sediments) (described in greater detail in Section 5.1.6), reducing the number of problem
areas addressed in this Record of Decision to eight.
" .
Source Control: Source control has been established as an operable unit for the site
which will be managed according to the objectives described in this Record of Decision.

Habitat ObJectbes: The importance of habitat restoration and iJ.sheries enhancement
has been clarified as a component of the CD/NT cleanup objective.

Selected Remedy: A limited range of four conf'mement options was selected to represent,
the sediment remedial action element of the selected alternative. '

Cost Estimates: Adjustments to cost estimates were made.

TImelrame (or ImplementatioD Schedules: Planning schedules for overall project
implementation were adjusted.
2.
3.
4.
5.
6.
These changes are logical outgrowths of the proposed plan, and are based on new information
. provided during the public comment period.
12.1 PROJEcr SCOPE
The Ruston-pt. Defiance Shoreline problem area described in the feasibility study has been
designated as a separate operable unit. This reduces the number of problem areas addressed in
this Record of Decision to eight. "
This change in project scope was made beQuse the agencies received a remedial investigation
for the ASARCO Tacoma smelter and off-shore sediments as a comment to the CB;NT t"easibilicy
srudy during the public comment period. This report included detailed new informacion :lCOUt
!:.~aracteriscics. areal extent. Jnd volume of ~ontaminaced sediments Jlong the Rusron- Pt. Der':anc~
Siioreiine. The agencies have reviewed this informatjon lnd beli~ve chat further Jeraii~d .In:l!ysis
'J(: ;emedial alternatives fO'r this problem area :s needed. The !'Iew information submitted Juring
:11~ comment periOd indicates that sediment toxicity problems ::ssoci:ued wuit ~oarse-'5rained slag
::nutic:les unique to the Ruston-pt. Defiance Shoreline may be less severe chan predicted in ,he
CliNT feasibiHcy study. Therefore. significant changes regarding the estimated volume 'Jr"
.;ontaminated sediments. the preferred sediment remedial :lJrernative. :lDd the ';OSt I)f this .emedv
;:m ;Je :1nticioared. The :nformatjon is specific ,0 the ~uston-Pt. Defiance Shoreline :eaimenrs.
.mtI. 'Joes not Jlter the ~electIon ()f .emeay ~"or me OCher ~igitt problem :lreas.
')ncc "he ~genc:~s :1:lVe ;"ully :'!aiuarea :he ..e:lsible -~me(ii:lI ~1Cerna[J\'es .or ":1is ;ro()le~
~. EPA and Ecology win issue :l new proposed plan for :l 30-..i:1y public ~ommenr period. "-\fcer
consideration of public comments. the agencies will select a remedy for the operable unit and issue
another Record of Decision specific to the CB/NT Ruston-pt. Defiance Shoreline problem area.
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12.2 SOURCE CONTROL
Source control has been described previously as the most challenging and critical first step in
the overall response strategy for the CB/NT site (Section 5.1). Ecology's Commencement Bay
UBA T was esublished in response to that challenge and is currently undergoing an expansion as
a result of additional resources made available through a Superfund cooperative agreement. To
more effectively manage that cooperative agreement and source control as a key element in the
selected remedy, Operable Unit 05 (Source Control) was established in the spring of 1989. Public
comment received on the CB/NT feasibility study indicated a very broad-based consensus that
enhanced source control measures were important to overall project success.
12.3 HABITAT OBJECI'IVES
The role of habit3t function as an important component of the overall project objectives was
expanded and clarified in response to three related issues presented during the public comment
period. First. 'concerns were raised that dredging activities could compromise important habitat,
particularly in intertidal environments. Second, various comments were received indicating that
impacts affecting habitat function should be evaluated in relation to impactS associated with
conmmin_tion problems. Thir~ the Puyal1up Tribe of Indians Settlement Act of 1989 was
promulgated, requiring substantive protection and enhancement of fisheries resources in the
Commencement Bay area. The habitat restoration protocols being developed by EPA's Region 10
Wetlands Program and Puget Sound Estuary Program will be incorporated into habitat evaluation
in the .CB/NT problem areas before and after sediment remedial action at both dredging and.
disposal sites. These protocols are being designed to quantitatively assess those characteristics of
an area that contribute to habitat function (i.e., feeding, refuge, and reproduction). Habitat
function has been included conceptually as a remedial objective that will be addressed in sediment
remedial design.
l2.4 SELEerED REMEDY
In the proposed plan for the feasibility study, the agencies recommended that a performance-
based remedy that could incorporate multiple sediment remedial options would be preferable to one
that limited remedial action to a single specific technology. The recommendation was based on
evaluations in the feasibility study indicating that :111 four confinement options offered similarly
feasible and cost-effective means of achieving the project cleanup objectives.
However, in the CB/NT feasibility study, a preferred remedy was idencified for each problem
area which included a specific confinement option (e,g.. nearshore disposal was preferred Cor the
Head or Hylebos Waterway). The decision to derine a generalized cont'inement element ['or
,ediment remediation instead at' the specific confinement options identified in the teasibiiity 3tUdy
:)r :l ~eriormance-b:lsed remedy 15 recommendea in the i'c:asibiiity study was based 'In ,;ommenrs
received during the public .:omment period. lnd :.ldditional technical lnd ldministrative revi~w
:onauctea by EPA. ami :::cology. "This decision :.u'fects oniy ,he :.;eciiment remeaial ~ctlon ~Iement
Jr' ,he remedy. Source .;ontroi and natura! recovery remain ~~ey ~!ementS of each qroblem :lrea
remedy.
7he preierred :liternative identified in ~he C3/NT :'easibiiity stUdv :lna ~he;electea :emeav
lescribed in Sec.ion ~O :.lre 3ummanzea in Table 15. The remedy :;elec.ea r'or :he Sr. :-'lUI
Waterway problem lre:l represents one of che four ..:onfinement options: III wu caopmg. For the
'.1outn .\[' :-fylebos. ,eaa .)r" ::::ty. ~:nci 'Vheeler-.)sgood ')roblem ::reas. )Den-water ~:)nr"inea ::au:ltIc
.jisposaJ '.vas identIr'iea :.IS .ne prer errea :.lJternatJve in me ieaslbiiity stuay, .\!earsnore \'Jlsposal.V~
identified in the feasibility study as the preferred. alternative for Head of Hylebos, Sjtcum and
Middle problem areas. Institutional control (including natural recovery) was selected as the
preferred alternative for the Mouth of City Waterway problem area.
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TABLE 15. SEDIMENT REMEDIES SELECTED IN THE FEAsmILITY STUDY
AND RECORD OF DECISION
Problem Area Feasibility Study Record of Decision
Head of Hylebos Nearshore disposal Confined disposal-
Mouth of Hylebos Confined aquatic disposal Confined disposal.
Si tcum . ~earshore disposal Confined disposala
St. Paul  In situ capping In situ capping
Middle  Nearshore disposal Confined disposal.
Head of City Conimed aquatic disposal Confined disposal.
Wheeler-Osgood Conimed aquatic disposal Confined disposal-
   \
Mouth of Cityb Institutional controls Confined disposal-
a In situ capping. confined aquatic disposal. nearshore disposal. upland disposal.
b Predicted to recover following source controls.
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After consideration of public comment, a limited range of confinement options was deter-
mined to offer the most appropriate means of achieving the project cleanup objectives in a timely
manner. The four different confinement options provide comparable protection of human health
and the environment, and they are similarly comparable when evaluated by the balancing criteria.
Variations in long- and short-term effectiveness and permanence are reJatively minor and are given
less weight than if the waste were higher in con~minant concentration. This added flexibility also
addresses cost concerns. For example, it is recognized that the added costs associated with upland
disposal may be justified for selected areas where in situ capping, nearshore disposal, or confined
aquatic disposal could interfere with commercial and navigational activities. In addition, new
information collec:ted during remedial design sediment sampling could greatly influence the selection
of the specific confinement option. It is anticipated that the spatial extent of contamination
exceeding sediment quality objectives and the areal extent of sediment predicted to recover
naturally could change significantly based on more detailed information on the distribution of
contamination concentrations, site-specific biological test results, refined sedimentation rates,
improved information on source loading rates, and new information on chemical degradation and
loss rates. Changes in waste volume will significantly impact the capacity requirementS of disposal
sites and consequently influence the overall disposal site design.
12.5 COST ESTIMATES
Comments received during the public comment period suggested that costS associated with
candidate alternatives were underestimated. Subsequent review of the costing procedures indicated
that unit dredging costs were underestimated by approximately a factor of 2, and that bulkiDg
factors due to incorporation of water during dredging were not included. The costs developed in
the CB/NT feasibility study were used to analyze the costs of the treatment alternatives relative
to the costs of confinement alternatives. New costs were developed for the four confinement
options using more realistic estimates for unit dredging costs and bulking during dredging. Other
cost refinementS were also developed on the basis of revisions to the preferred alternatives and
changes in assumptions regarding the factors that would influence their implementation. For
example, nearshore disposal cost estimates do not include site development because it has been
determined that this alternative will only be implemented when integrated into nearshore construc-
tion projectS. The cost estimates developed for the Record of Decision for confined aquatic
disposal assume that overdredging techniques will be used.
12.6 IMPLEMENTATION SCHEDULES
The implementation schedules for both source control and sediment remediation :lS described
in the CB/NT integrated action plan (PTI 1988) have been revised in response to public comment.
Yfany comments indicated that the estimated schedules appeared to be b:lSed on unre:llistic:lily shorr
timefr.tmes for source control. The schedules have been re-evaluated by EP.-\ :md E;;ology t"or ~:lch
,)(' ,he C3/NT problem ~reas, In 'Senera!. .he '5cheduies were revised co inciude i -3 more ::c:lrS ,)["
source '.:ontrol ~ctivities. The schedule revisions have been ~djusted to reflect :ldditional time
leeaea ~o investigate :.lnd :.ladress C3/NT :"ources. !ocluaing ~tOrm drains. :ha[ '''ere not :':lc:ored
into .ne ~ntegrateci action pian scneciules. The overaH rimeframe ,'or the action cleanuo phase .)f
the project has therefore been adjusted from ~ ye:us to :J. [otal of 3 years, as reflected in the
;Jlannin~ schedules in Appendix C.
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REFERENCES
Crecelius. E.A.. M.H. Bother, and R. Carpenter. 1975. Geochemistry of arsenic, antimony,
mercury and related elements in sediments of Puget Sound.' Environ. Sei. Technol. 9:325-333.
Gabler, A.R., 1.M. Cummin~, 1.N. Blazevich. R.H. Rieck. R.L. Alp, C.E. Gangmark, S. Y.M. Pope,
and S. Filip. 1982. Chemical contaminants in edible, non-salmonid fish and crabs from Com-
mencement Bay, Washington. EPA-910/9-82-093. U.S. Environmental Protection Agency Region
10, Seattle, WA. 118 pp. .
Hart Crowser. 1984. Soil and groundwater quality evaluation, SR-705 Tacoma Spur, Tacoma,
Washington. Prepared for ABAM Engineers, Washington State Department of Transportation, and
Washington Department of Ecology. No. 1-1210-09. Hart Crowser & Associates, Seattle, W A.
Malins, D.C., B.B. McCain, D.W. Brown, A.K. Sparks, and H.O. Hodgins. 1980. Chemical
contaminants and biological abnormalities in central and southern Puget Sound. NOAA Technical
Memorandum OMPA-2. National Oceanic and Atmospheric Admini'ltration, Boulder, CO. 295 pp.
MaJins, D.C.. B.B. McCain, D.W. Brown, A.K. Sparks, and H.O. Hodgins. 1982. Chemical
contaminants and abnormalities in fish and invertebrates from Puget Sound. NOAA Technical
Memorandum OMPA-19. National Oceanic and Atmospheric Administration, Boulder, CO.
168 pp.
Norton, D., and A. Johnson. 1985. Assessment of log sort yards as metals sources to
.Commencement Bay waterways, November 1983-June 1984. Completion report for WQIS Project I
for the Commencement Bay nearshore/tideflacs remedial investigation. Washington Department
of Ecology. Olympia, W A.
Parametrix. 1987. Sc. Paul Waterway remedial action and habitat restoration project: project
overview, SEPA environmental checklist, technical appendices. Prepared for Simpson Tacoma
Kraft Company. Parametrix, Inc., Bellevue, W A.
Phillips, K.E., J.F. Malek, and W.B. Hamner. 1985. Evaluation of alternative dredging methods
and equipment, disposal methods and sites, and site control and treatment practices for con-
taminated sediments. U.S. Army Corps of Engineers, Seattle, W A.
Pierce, D., A. Comstock, and R. Young. 1987. Marine resource protection program seventh
progress report. Prepared for the Tacoma City Council. T::lcoma-Pierce County He::llth Dep:ut-
mente Environmental Health Division. Waste and Water S~ction. Tacoma. W A.
?SDDA. 1988. Evaluation procedures technical appendix - Phase [ ('central Puget Sound), Public
:\.e'liew Drait. ?recared by the Evaluation ?roceaures WorK Group :'or ?uget Sauna Oreageu
:>isposal Analysis. U.S. Army Corps oi Engineers. S~attle. W A.
?SWQA. 1988. ! 989 Pu~et Sound water quaiity management plan. Puget Sound Water I)uaiity
A.uthority, Seattle. 'V A. 276 pp.
PTI. 1988. Commencement Bay ne:usnorel tider"lats inte~rated action pian. Public Review Drar'r.
"'~eDareu ,'or -etr~ -"'cch. ~nc.. ..:na "he .V~snint;(Qn uecarunent .)t' :::-:olO~Y. ;':1 :::r:\"lronmenral
';;~rvlcez. 3e!levue. 'j A.
PTI. 1989. Commencement Bay nearshore/tideflacs feasibility study: development of sediment
cleanup goals. Public Review Draft. Prepared for Tetra Tech, Inc., Washington Department of
Ecology, and me U.S. Errvmmmental Protection Agency. PTI Environmental Services, BeIIevue,
WA.
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,9
Riley, R.G., E.A. Crecelius, and D.C. Mann. 1980. Quantitation of pollutantS in suspended matter
and water from Puget Sound. NOAA Technic:!.l MemQrandum ERL MESA-49. National Oce:!.nic
and Atmospheric Administration, Boulder, CO. 99 pp.
Riley, R.G., E.A. Crecelius, and M.L. O'Malley. 1981. Organic pollutants in waterways adjacent
to Commencement Bay (Puget Sound). NOAA Technical Memorandum OMPA-12. National
Oceanic and Atmospheric Administration, Boulder, CO. 90 pp.

Rogers, T., E. Howard, and R. Young. 1983. Commencement Bay nearshore/tide flats drainage
system investigation. Washington Department of Ecology, Olympia, WA.
Stinson, M., D. Norton, and A. Johnson. 1987. An ,investigation into potential sources of PCB
contamination in Hylebos Water:way. Washington Department of Ecology, Olympia. W A.

Tetra Tech. 1985. Commencement Bay nearshore/tideflats remedial investigation. Vols. I and 2.
Final Report. EPA-910/9-8S-134b. Prepared for Washington Department of Ecology and U.S.
Environmental Protection Agency. Tetra Tech, Inc., Bellevue, W A.
Tetra Tech. 1988a. Commencement Bay nearshore/tideflats feasibility study. Public Review
Draft. Prepared for the Washington Department of Ecology. Tetra Tech, Inc. Bellevue, W A.
Tetra Tech. 1988b. Health risk assessment of chemical contaminants in Puget Sound seafood.
Prepared for U.S. Environmental Protection Agency Region 10, Office of Puget Sound, Seattle,
W A. Tetra Tech, Inc., Bellevue, W A. 102 pp. + appendices.
U.S. EPA. 1986. Quality criteria for water. U.S. Environmental Protection Agency, Office of
Water Regulations and Standards, Washington, DC.
U.S. EPA. 1988. Guidance for conducting remedial investigations and feasibility studies under
CERCLA. Interim Final Report. OSWER Directive 9355-23.01. U.S. Environmental Protection
Agency, Office of 'Emergency and Remedial Response and Office of Solid Waste and Emergency
Response, Washington, DC.
U.S. EPA. 1989. EPA wetland action plan (January 1989). U.S. Environmental Protection .-\gency.
Office of Water and Wetland Protection, Washington, DC.
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APPENDIX A
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-.
CHRISTINE O. GRECOIRE
Director
STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY.
Mail Stop PV-11 . Olympia. Washingron 98504-8711 . (206) 459-6000
September 2it 1989
Mr. Robie Russell
R~gional Administrator
EPA Region 10
1200 Sixth Avenue'
Seattle, Washington 98101
. -....
. .
. I "
",'.... .
Dear Mr. Russell:
The Washington Department of Ecology has completed its review of the
Record of Decision (ROD) for the Commencement Bay Nearshore/Tideflats
project. Based on this review, the State concurs with the selected
remedy.
I am glad the ROD includes a range of options for sediment disposal.
EPA's willingness to work with Ecology and the Puyallup Tribe in
refining a list of Applicable or Relevant and Appropriate Requirements
(ARAR's) is an excellent step in ensuring that the cleanup will meet
the requirements of federal, state, and tribal laws. Also, we look
forward to further clarifying the process for determining when sources
have been controlled sufficiently to allow sediment cleanup to
proceed.
I appreciate the long hours both. EPA and Ecology staff have
contributed to complete the ROD on schedule. We look forward to
working with EPA, the Tribe, the environmental cormnunity, and
Commencement Bay responsible parties in the upcoming phases of source
control and sediment remediation.
Sincerel?,
';;lrist:ine i). Gcegoire
Jirector
~':OG; kInk
-- .
:1ike Gallagher
':.:;.roi ?~esl'es
~ic~ ::ibcara
Terry Husseman
Bill Sullivan-Puyallup
Mike Wilson-SWRO
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--........-.. '-',-,
- -.. _. .-
-.....-... -~
THE au BEY LAW FIRM
SE' 2 9 1!89
31 10 BANK OF C"'L.IFORNIA CENTER
900 FOURTH AVENUE
SEA TTL.E. WASHINGTON 98164.1002
SUPERFUND BRANCH
RICHARD A. Ou BEY
SCOTT tot. MISSAL.L.
GRANT O. PARKER
September 29, 1989
TEL.EPHONE
(2061621-7034.
FACSIMIL.E
(2061621.7110
Mr. Robie G. Russell
Regional Administrator
u.S. Environmental Protection
Region X
1200 Sixth Avenue
Seattle, Washington 98101
HAND-DELIVERED
A.gency
RE:
Tribal Concurrence
Decision
on
Commencement
Bay
Final
Record
of
Dear Mr. Russell:

This letter is written on .behalf of the Puyallup Tribe of'
Indians with regard to the letter you received from Chairman Henry
John regarding the above-referenced matter on September 26, 1989.
Based upon subsequent conversations among Tribal and EPA represen-
tatives, the issue arose concerning the status of the Tribe's
"conditional concurrence" as set forth in Chairman John's ~etter
of September 26, 1989. Please be advised that the Puyallup Tribe
of Indians has concurred with the selection of remedy as set forth
in the final draft record of decision ("ROD") for the Commencement
Bay Superfund site.
Please be further advised that the Tribe reserves the right
to fully participate in selection of the alternative to be
implemented by EPA on a site specific basis. The Tribe also agrees
wi th EPA that there is indeed a need for further testing and
analysis to fully determine the .remedy to be implemented in a
manner consistent with the Superfund law. .
It is understood bet~een the Tribe and EPA that t~e list of
c=ncerns and conditions set forth in C~ai=man John's Sep~em~er :5t~
let~er continue to be concerns of the Tribe with regard ~o ':he
:..mplemen-ca-cion phase of the 3elec~ed remedy. .;ccordingl y I -:~e
:'r:.be ...,ishes to fully participa~e '.vith E..PA and the State :.Ji
Washington as one of the three sovereign governments implementing
.3.nd enforcing the selec-ced remedy at the Commencement 3ay/Hearsnor:
-:':.deflats Superfund Site. 3uch 3.ct:.ons on 3. 9a~ oi -:he:'=:.::Je
~ould include ?ar-cicipa~ion in =emedial design, 30urce con~=Ql, and
~~ose studies 3nd activities ~elevant ~o ~~e ~ro~ac~~an ~i ~isher!
:1~bita~ 1nd :i::.ner'} ::csourcas "J! -:he ?11ya.l2.u;> .1i~'er 3asin ~.:mr.le!1ca-
:nen~ Bay area.
It has been the consistent and vigorous position of the
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Mr. Robie G. Russell
September 29, 1989
Page 2
protected and that measures be taken to implement the ROD consis-
tent with the need to protect such treaty protected fishery
resources. The Puyallup Tribe appreciates EPA's acknowledgement
of the settlement leqislation, 'settlement agreement and technical
appendices as component parts of the clean up standards or ARARs,
and looks forward to working with EPA in the implementation phase
of the remedial. action.
As previously discussed with the Superfund site Manager and
EPA Office of Regional Counsel, it is cri tical:. that EPA make
additional resources available to the Tribe so that the Tribe may
meaningfully participate in the remedial design and remedy
implementation stages of the clean up. Our Superfund agreement may
serve as a foundation upon which to base a fuller measure of
federal support for the Tribe's participation and we look forward
to initiating discussions with you in this reqard.

On behalf of the Tribal Council, I again want to express
appreciation for the hard work of the EPA Region X staff, and we
look forward to a continuing government-to-government relationship
directed to protection of the fishery and treaty resources of the
Puyallup Tribe and the people of the State of Washington.
Sincerely,
THE Du BEY LAW FIRM
RICHARD A. Du BEY
Special Environmenta Counsel
Puyallup T~ibe of Indians
?J:..D: :-::
~=: ~enry John, Chairman, Tribal Council
~olleen ~argrove, gice-~hair. ~ribal Counc~l
Gabe Landry, Councilmember
Nan~! Shippentower, Councilmember
~errnan Dillon, Jr., Councilmember
3i1l Sullivant Qirector, ~nvironmen~al ?rograms
;ohn 3e1l, ~eser'a~ion At~orney
~. ~andall ~arrison, 0f~ice ~f ~eser!ation ~t~or~ev
!ike 3toner. :PA. Juper~~na site .!anager
rtllan Bakalian, EPA, Assistan~ Regional Counsel
File No. 8834.1
-------
Mr. Robie G. Russell
Regional Administrator
u.s. Environmental Protection
Reg ion 1.0
1200 Sixth Avenue
Seattle, WA 98101
AECEIVED
SEP 2 8 1!89
Agency
SUPERFUND BRANCH
Re: Commencement Bay Final Draft Record of Decision
Dear Mr. Russell:
The Puyallup Tribe ot Indians has reviewed the final draft
Record of Decision for the Commencement Bay Nearshore/Tideflats.,
This document is critically important to the health and well-
being of members of the Puyallup Tribe. We appreciate very much
the work that has gone into the document and as well as your
recognition that the Tribe has a critical role in the process of
directing the cleanup of Commencement Bay.

The Puyallup Tribal Council, governing body of the Tribe,
has instructed me to communicate to you the Tribe's position on
the final draft ROD. Although EPA has responded to many of the
issues raised in the Tribe's earlier comments, we are still not
convinced that the selected remedy will fully protect, among
other things, human health and the fisheries habitat. We do .
agree, however, with the general purposes and goals stated in the
ROD, and with many aspects of the selected remedy. The Tribe
therefore gives its conditional concurrence to the selection of
remedy in the ROD.
The Tribe's concurrence is conditioned on several factors
~hich : ~ill sp~ll out. If any ~t chose conditions are no~ ~e~
'~r 5a~isfac~orily accomplished within reasonable time limi~s in
~he ~lanning.or implementa~ion of the remediation process, then
the Tribe's response should be changed to reflect chat the Tribe
does not concur in the final draft ROD.
Ano~her reason the Tribe makes its concurrence conditional
is that many parts of the analysis and the proposed remedy are
3'::ill undefined.. Thus, if additional data is generated during
~he 9rocess, the Tribe reserves che eight to add to and elacor~~e
upon the conditions of its concurrence.
The Tribe agrees with the remedy selected in the ROD as long
as certain conditions are met. Those conditions consist of the
2002 East 28th Street
.
Tacoma. Washington 98404
.
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.
Mr. Robie G. Russell
September 26, 1989
Page 2
items identified in the Tribe's letter of June 24, 1989
(addressed to Mr. Michael stoner of EPA and Mr. Richard Hibbard
of the Washington Department of Ecology), commenting on the draft
feasibility study that led to this ROD. (A copy of the June 24
letter is attached to this letter.) Although some of the
problems identified by the Tribe's comments have been
satisfactorily addressed in the. ROD, others have not. Even in
cases where the ROD has been modified to address the Tribe's
concerns, there are some situations where we do not know whether
the remedy selected will be satisfactory until more information
is available. or until we see the results of the remedial action.
The Tribe therefore conditions its concurrence on compliance with
all of the elements listed in the Tribe's prior comments.

The following list is a summary of the general concerns that
remain, and the cateqories into which the conditions on the ,
Tribe's concurrence fall. This is not an exhaustive list of the'
conditions on the Tribe's concurrence; see the Tribe's letter of
June 24, 1989, for a more complete and detailed list.
1. The selected remedy must protect human health and
the environment.
2. The cumulative health risks from all dangerous
chemicals, including their sYnergistic effects, must be assessed
and remedied.
3. The tribal ARARs must be met to protect hum~n
health, the environment, and tribal resources, including the
Tribe's federally-guaranteed treaty rights.
4. The selected remedy must be a permanent solution to
the existing problems.
5. The Tribe must continue to have a meaningful role in
iecisicn-~aking concerning the developmen~ of source con~rol
~easures. design of remedial actions, and natural resource
=estora~ion-
6. The Agency of Toxic Substance and Disease Registry
is in the process of revising its earlier study in order to
je~ermine whether there is a causal relationship between the
bioaccumulation of hazardous substances and ~he alarming cancer
ra~e among tribal members. EPA must reevaluate the remedy
selec~ed in ~he aOD in light of ~he results of that revised
s~udy.
7. There must be a more thorough study to test for the
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e
Mr. Robie G. Russell
September 26, 1989
Page 3
generated by the study and included in the evaluation of that
data. -The selected remedy must be revised to deal with the
presence of any dioxins demonstrated by the study.

one clarification and one correction need to be made to the
list of ARARs on page 90 of the ROD. The Puyallup Tribe of
Indians Settlement Act is noted as an ARAR applicable to
"Puyallup Tribe lands." -The clarification is as follows:
The specific standards for protection of the
environment which are adopted as an ARAR are found in the
Agreement negotiated by the parties to the Settlement. The
Settlement Act mentioned on page 90 incorporates and adopts
Agreement. We want to be sure that people are not confused
they read the Act and do not see the specific environmental
standards. They are found in the Agreement.

The correction is as follows:
that
when
The environmental standards in the Settlement Agreement
are applicable to a much wider area than "Puyallup Tribe lands,"
if that phrase is interpreted to mean parcels of land owned by
the Tribe. A shorthand means of referring to the location to
which this ARAR is applicable would be "Commencement Bay/Puyallup
River watershed."
The Tribe's conditional concurrence expressed in this letter
does not in any way address or limit ~he Tribe's right to pursue
and collect damages or other relief against potentially
responsible parties under applicable law for harm caused to
natural resources by those parties.
The Tribe's conditional concurrence expressed in this letter
also does not in any way address or limit any action the Tribe
~ay take in the future to protect and enforce its treaty-reserved
::shing rights including pro~ec~ion of the fisheries habi~a~.
~he Tribe's conditional concurrence expressed :n this le~~er
also does not in any way limit or bind the Tribe in discussions
that are taking place and agreements that we anticipate with the
Port of Tacoma concerning certain property-that is to be
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. 0
Mr. Robie G. Russell
September 26, 1989
Page 4
Please do not hesitate to contact our staff if discussion or
clarification of any of these issues would be helpful.
sincere"ly,

)f~~

Henry John {/
Chairman, Puyallup
Council
9t~t
Tribal
CC:
Tribal Council
Bill Sullivan
Law Office
Richard Hibbard, DOE
Mike Stoner, EPA
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APPENDIX B
-------
CONTENTS
I.
OVERVIEW
STRUCTURE
~
II.
SCOPE OF RESPONSE TO COMMENTS
COMMUNITY lNVOL VEMENT
THE PUBLIC COMMENT PERIOD
FUTURE COMMUNITY RELA nONS PLANS
CONCERNS RAISED DURING THE INVESTIGATION PHASE OF THE
PROJECT

m. RESPONSE TO COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD
1. PROGRAM ISSUES
1.1. Comments Related to CERCLA Requirements
1.2. Comments Related to Coordination with Other Programs
1.3. Comments Related to ARARs and TBCs
2. HUMAN HEALTH RISKS (SEAFOOD CONSUMPTION)
2.1. Comments Related to Baseline Risk Calculations for Human Health
2.2. Comments Related to Cleanup Level for Human Health
3. ENVIRONMENTAL RISKS (SEDIMENTS)
3.1. Comments Related to Baseline Risk Concepts for Environmental
Protection
3.2. Comments Related to Baseline Risk Calculations for Environmental
Protection
3.3. Comments Related [0 Cle:u1up Goal for Environmental
?rotection .
.!. THE A.PPARENT EFFECTS THRESHOLD APPROACH
4.1. Comments on Conceptual Basis of the AET Approach
4.2. Comments on the. Application of the AET Approach for Decision-Making
J.3. Comments Related to Chemical-Specific AET Values
~.4. CJmmentS on [he Establishment of AET Values for the C3/NT Site
~.5. Comments on the Relationship at AET [0 Human Health
. 20URC:: LOADING ESTIMATES
5.1. Comments on Identification of Present and Historical Sources
5.2. Comments on Adequacy of Nonpoint Sources Relative to Point Sources
5.3. Comments on Loading Calculations
B-ii
~
B-1
B-2
B-2
B-3
B-4
B-4
B-S
B-7,
B-7
B-7
B-9
B-IO

B-ll
B.,.12
B-15
B-15
B-16
8-17
3-~9
1-:1
8-21
8-2:
.8-::
3-:3
8-:~
J- :S
B-25
B-26
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J. SOtJRCE CONTROL

6.1. Comments on the Appropriateness of Source Control
6.2. Comments on Remedial Technologies Cor Source Control
6.3. Comments on Relating Source Control to Sediment Quality Objectives
6.4. Comments on Appropriateness of Feasibility Estimates Cor Source Control
6.5. Comments on the Status of Source Control
7.
NATURAL RECOVERY AND THE SEDIMENT CONTAMINANT
ASSESSMENT MODEL (SEDCAM)
7.1. Comments on the Protectiveness of Natural Recovery
7.2. Comments on Modeling Predictions Using SEDCAM
8. SEDIMENT REMEDIAL AL TERNA TIVES
8.1. Comments on the Permanence of Commement Options
8~ Comments on the Feasibility of Commement Options
8.3. Comments OD the Impacts of Dredging and Disposal
8.4. Comments on Cost and Volume Estimates
8.5~ Comments on the Cost-Effectiveness of Sediment Remedial Action
9. IMPLEMENT A nON AND MONITORING
9.1. Comments on Timing of Source Control. Sediment Remedial Action, and
Natural Recovery
9.2. Comments on Time Schedules
9.3. Comments on Routine Dredging Projects
9.4. Comments on Source Monitoring
9.5. Comments on Sediment Monitoring
IV. REMAINING ISSUES
V.
ANNOTATED BIBLIOGRAPHY
VI. REFERENCES
GENERAL REFERENCES
COMMENTS RECEIVED DURING PUBLIC COMM ENT PERIOD
B-iii
~
B-27
B-28
B-28
B-28
B-29
B-29
..
B-29
B-30
B-30
B-31
B-31
B-31
B-33
B-34
B-35
B-35
B-35
B-36
B-37
B-37
B-38
B-40
B-41
B-64
B-64
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RESPONSIVENESS SUMMARY
L OVERVIEW
The purpose of tJUs document is to summarize and respond to the public comments submitted
in regard to the proposed plan and other alternatives for cleanup of the Commence Bay Nearshore/
Tideflats (CD/NT) site. It addresses comments for the eight problem areas covered in this Record
of Decision. This Responsiveness Summary is required in Section 117 of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA).

The Washington Department of Ecology (Ecology) and U.s. Environmental Protection Agency
(EP A) identified a preferred alternative for the CD/NT site in the feasibility study and proposed
plan which were made available for public review and comment from 24 February 1989 to
24 JUDe 1989. The agencies' preferred alternative addressed conrnminmted marine sediments in
nine problem areas identified in the feasibility study. The agencies recommended selecting a
combination of source control. natural recovery, and active remediation of those sediments in the
problem areas that would not recover naturally to the sediment quality objective within 10 years.
The agencies further recommended that the selected sediment remedial alternative (for are~
requiring active remediation) be performance-based. rather than selecting a single specific remedy,
as lonl' as the technology chosen satisfied the performance criteria, as well as all CERCLA
requirements.
The agencies have carefully considered all comments submitted during the public comment
period. Based on comments received during the public comment period, members of the
community are generally supportive of. the overall approach that combines source control, sediment
recovery.. and sediment remediation, if necessary. Most commenters agreed that there are
demonstrable adverse environmental impacts associated with the CD/NT sediments, that the area
should support multiple uses (e.g., commercial, recreational), and that control of sources should be
a high priority. ..
Commenters expressed divergent opinions on a number of key issues. These issues included
the risks posed by the site, the proposed cle:lDup goals, the feasibility of and timefmme for source
conuol, and the protectiveness and proposed role of natural recovery as a component of the remedy.
Those who are not potentially responsible parties (PRPs) tended to be concerned chat the cleanup
objectives do not address aU impacts and are not protective enough. and that the preferred
Jlternacive. particularly the natuml recovery ~omponent. is neither protective nor permanent. PRP~
.;ommented in detail that the cleanup objective is (00 stringent. that significant he:llth ~ff~:s h:lve
:'lot je~n Jemonstr:lted.. (hat natural ~ecovery should ;Jiay :J. l:lr!;er ~ole. lna :!1:lt lc:ive ~~media(Jon
is warranted only in severely impacted :lre:J.S. These divergent comments have been .;onsiderea In
,he :;election of remedy :lnd responded to in Section m or' :his Responsiveness ::::ummary.
The selected remedy, described in (he CB/NT Record of Decision. has been modified from
~he proposed plan in response to comments. The changes. discussed in Section !II ,)f chis
Kesponsiveness Summary 'lnd in Section 12 of ~he Record of Decision. included:
.
Postponing the selection of remedy for sediments in (he Ruston-Pt. Defiance
3horeiine oroblem ~re:l '.1ntil r"urther :lnaJysis 'Jr' :he ,jet:liled ..:ommenrs .lna .,ew
im.ormation :lDOut (his :lrea ''::In oe '.;ompleted. .lnd :l :1eW ;:>ropOSCll presentee :0 ,he
public

Establishing source control as an operable unit to be guided by this Record of
Decision
.
-------
.
Enhancing and clarifying the role of habitat restoration and fisheries enhancement
as a component of the CB/NT cleanup objective

Selecting a range of containment options as the sediment remedial alternative rather.
than specifying a performance-based remedy or a single containment alternative

Revising. the cost estimates

Lengthening the estimated time to achieve sufficient source control.
.
.
.
STRUCTUKE
Section n briefly describes the history of community involvement in the CB/NT Superfund
project from 1981 to the present (September 1989). It includes a very brief summary of key issues
raised by members of the community during that time and a similarly brief discussion of how the
agencies have responded to those concerns to date. A list of the community relations activities
conducted at the site throughout the project is attached at the end of the Responsiveness Summary.
Section m is a summAry of comments submitted during the public comment period which
were germane to the selection of the remedy, and EP A 's response to those comments. The
comments and respoases have been categorized by relevant topics and numbered.
Section IV is a very brief summary of. remain.Lng issues and concerns, and how they will bel
addressed during monitoring, remedial design, or remedial action. Comments submitted by
ASARCO that are specifically concerned with the toxicity characteristics, and the area, extent, and
volume of COnt:lm;nated sediments off the Ruston-Pt. Def"W1ce Shoreline have been deferred to the
Operable Unit 06. A revised feasibility study for that problem area is currently being prepared
and will be released for further public review and comment.
Section V is an annotated bibliography that has been developed to help EPA organize and
respond to the large volUme of comments submitted. It will also assist commenters in tracking
between their original comment language and the responses provided in this appendix.
SCOPE OF RESPONSE TO COMMENTS
This Responsiveness Summary addresses the significant commentS affecting selection of
remedy (pro and con). It does not address many less significant commentS that were nonetheless
considered. or commentS not germane to the remedy selection.
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IT. COMMUNITY INVOLVEMENT
Local concern about environmental issues focused on contamination of the marine enviroiunent
in 1980-81. In 1980, the National Oceanic and Atmospheric Administration (NOAA) released a
study that indicated elevated concentrations of organic compounds and metal contaminants in
Commencement Bay sediments, fish, and shellf'lSh. As a result, in January 1981, the Tacoma-
Pierce County Health Department (TPCHD) issued a warning recommending the public not
regularly consume the resident bottomilSh or shellfish from the Hylebos, Blair, or Sitcum
waterways.
In April 1981, approximately 120 persons attended a meeting called by federal, state, and local
officials to explain what the government had done, was doing, and was about to do with
environmental and public health problems in the Commencement Bay area. A cross section of
interests were represented at the meeting, including the Puyallup Tribe of Indians, local business
and industries, the Tahoma Audubon Society and the Washington Environmental Council, and
individual citizens with no apparent affiliation. The later three groups were the most active
participants, stressing their indignation that not enough was being done to correct the problems.
On 23 October 1981, EPA announced a list of 115 hazardous waste sites targeted for actio~
under the new Superfund law. . Commencement Bay was included on the list as the top priority sice
in the state of Washington at that time. That announcement sttengthened the public perception that
the site had serious hazardous waste problems and resulted in increased public pressure on the
agencies to take action. Area residents continued to complain that not enough was done to correct
the problems.
In 1981, the agencies committed themselves to making information about the agency activities
and the hazards presented by contamination in Commencement Bay timely and accurate and
available to all interested paries. The agencies interviewed a range of interested community
memben in 1983 to determine community concerns. and to plan community relations activities and
opportunities for public involvement. The agencies interviewed about 30 more interested persons
in 1987 to update their knowledge of community interest and concerns and to revise the community
relations plan.
The most interested groups, on a continuing basis, have been local officials. the Puyallup
Tribe of Indians, loc:u businesses, local environmental and citizens groups, and other federal, st:lte,
and local agencies with an interest in this project. The 'most consistent community involvement has
been in the form of 1 Citize~s Advisory Comminee lnd l T~chnic:lI Oversight Commictee.
The Citizens Advisory Cummittee was org:lOized JY TPC-ID in September 1983. The C:[iz~:1s
-\dvisory Committee was originally established as a specific group of -:itizens from Tacoma. Vashon
~sland. :md r'ierce County, ~:lch or' whom represented ln ,)rganized .;itizen 3rouD ,)r .5eo~rapnic
':ODStltUency. Membership has been limited to 12-;6 volunteers interested in foHowing the
agencies' progress and serving as a. conduit for community interests in the investigation of
Commencement Bay. :Vfemben of the committee have met regularly with agency representatives
:'or 6 years to help provide a community and individual ..:itizen's perspective of the ;:>rocess.
.J..gency representatives have attended meetings at the request oi the Ctizens Advisory Comminee.
providing and receiving information and responding to Questions. The Citizens Advisory
':umminee ,)rganlzed :l citizens workshop in Aoril 1989. to discuss ;.lnd ..;omment on [he Jrooosed
jJlan.
Ecology and EPA established a Technic:u Oversight Committee during the remedial
investigation to serve as a scientific and technical review panel for the project and to encourage
the participatWu of in.terested loca1. S13t8. and federal !\Vnci~ The T~hn;~1 Oversight
Committee was established in recognition of the existence of many other ongoing :lnd related
-------
studies and overlapping environmental authorities. In addition to representatives from federal.
state. and 10c:a1 agencies, representatives from the Puyal1up Tribe of Indians, Port of Tacoma, city
of Tacoma, and several local industries also served on the committee and regularly attended
meetings. The Technical Oversight Committee met on an as-needed basis with at least one meeting
every 3 months through the spring or 1988. The remedial investigation. risk assessment, and some
preliminSlry feasibility study reports were reviewed by the Technical Oversight. Committee prior to
their release. The draft feasibility study was provided to all Technical Oversight Committee
members at the beginning or the public comment period in February 1989.
More than 700 individuals and businesses have requested information about the site and have
been included on the agencies' mailing list. The agencies have mailed periodic updates and fact
sheets on Superfund projects in the Tacoma area to those on the mailing list. Site-specific fact
sheets describing source control, interim remedial actions, the results of the remedial investigation,
the draft feasibility study, and PIO~ piaD have been distributed. Ecology and EPA representa-
tives attended many meetings of interested citizens, industry, PRPs, and local government leaders
to discuss significant milestones and cleanup action alternatives.
Much of the visible community involvement has centered on specific project developments
within the overall scope of the CD/NT site, such as individual source control activities, and the
ASARCO smelter. ASARCO-related concerns have consistendy drawn considerable interest and
involvement. Many members or the community have spoken out in favor of environmental
protection in coexistence with a health economy. For example, in late 1987, a large number of
environmental groups, community organizations, and citizens spoke out in favor of cleanup of the
tideflats and restoration of the environment when the Simpson Tacoma Kraft Company took early
action to remediate the tideflats area around the Simpson plant. Local residents are actively
involved in ongoing discussions about the proper use and regulation of a municipal incinerator
located in the tideflats.
THE PUBUC COMMENT PERIOD
Media and community interest in the CD/NT site increased as the feasibility study neared
completion, focusing on the COSts, benefits, and other considerations of cleanup. . At the request of
several parties, the agencies provided for a 120-day public comment period. The agencies held tWo
formal public meetings and the site managers met with over 20 interest groups. The public meeting
transcriptS are in the Administrative Record. The Citizens Advisory Committee attracted
approximately 50 people to a citizens workshop designed to inform community members :lbout
these projectS. During the public comment period, EPA and Ecology established an information
booth at the Tacoma Fire Department Fir:eboat Station. Agency representatives were available at
the boothl day per week to answer questions from members of the community. During this
period. che prinr, radio. and television media aU increased their coverage of che issues.
FUTURE COMMUNITY RELATIONS PlANS
In recognition of the scope and complexity of the CB/NT site. EPA is establishing :l Technicai
Discussion Group for the remedial design and remedial action phase in recognition of the scope and
complexity of the CB/NT site. and to integrate and expand the information exchange functions at
the Technical Oversight Committee :lnd Citizens Advisory Committee. Membershie!)f ,he
Technical Discussion Group is therefore intended to include the CB/NT :jite management te:lm.
representatives of re~ulatory ::1gencies :lnd programs. PRPs. local government. interested citizens.
l.nd organized citizens groups. The purpose or" ~he Technical Discussion Graue :$ :0 provide .1
forum tor the general review or technical :.1Od planning issues during the deanup phase of the
project. Discussion topics may include a wide range of issues related to project status, planning,
sediment management and habitat concerns, health issues, 10c:U development, and others. It is
hoped that the Technic:a1 Discussion Group will provide EPA with valuable insight into issues of
CODCem~ and thereby ccmlribute [0 project direction and fiadiags. Ha.e~er, group input win nOt
form EPA policy or determine EPA's course of action, nor will it preclude the 30-day public
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+. .... ..~-'.- .. -.. ....
. .
comment period required upon completion of negotiated agreements betWeen EPA and PRPs for
sediment cleanup in each of the problem areas.. Meetings will be scientific and technical in nature;
legal matters will not be discussed.
CONCERNS RAISED DURING THE INVEsrIGATION PHASE OF THE PROJECT
Several major concerns were expressed by residents of the 1cx:a1 community during the course
of the project. These concerns are briefly summarized below, followed by summaries of the
agency's response(s):
Residents qu.estion~d how reports 01 releases or ongoing dischQ/'ges were addressed.
Respoase: Ecology's Commencement Bay Urban Action Team (UBA T) and TPCDH's Marine
Resource Protection program have responded to reported spills and discharges and ordered
cleanup or other actions as appropriate. Some problems were addressed by other Ecology and
EPA regulatory authorities. Work on conttolling releases and ongoing discharges is a
continuing activity because the site is complex, with numerous potential sources. Source
conttol activities will be increased during the active cleanup phase of the project due to
additional funding of the Commencement Bay UBA T through a Superfund Cooperative
Agreement.

Source conttol programs at a variety of facilities are already underway. For example, ~e
Simpson Tacoma K.raft source conttol program has removed more than a million pounds of .
pollutmtS from the facility on an annual basis.- Other elements of the source control program
include chip containment and control of facilities and collection and secondary treatment of
all stormwater before discharge through the new plant outfall. To address concerns over
municipal storm drain discharges, the city of Tacoma has initiated a program to identify and
remove existing sources of contamination, and is also studying the feasibility of treating storm
runoff entering the head of City Waterway. Best management practices have been
implemented at various facilities to control spillage of materials containing contaminants into
the waterways. Other programs have, for example, concentrated on investigation. contain-
ment, removal, or treatment of historical wastes located on lands adjacent to the waterways.
Residents asked whal potential health problems are caused by groundwater. soil. and sediment
contaminalion. and whal potential health problems might result from the consumption of contam-
inated fish and sheil fish. Information was requested on the effectS of Commencement Bay poiluJion
on environmental quality and recrealional values of Puget Sound. includiltg protection and recovery
of holtomfish and sheilfish resources.
Response: The agencies developed the Superfund studies to define the nature lnd ~:([ent ,)(
.:oncamination. the risks from contamination. lnd possible solutions. According to (he risk
~sessment. most of the health risks lre based on lang-term .;onsumption or" iarge yuantiues
of seafood. To reduce those risks and reduce harm to the ~nvironment. the agencies workeo
:0 control or oaiiminate ongoing sources or" pollution. TPCHD issued a fishing ;lovisory ::nci
posted warning signs to discourage fishing in contaminated are:lS. Federal 1gencies stucijeo
seafood consumption in Commencement Bay :lDd Puget Sound. helping the agencies to better
understand J11d protect populations at risk. The Puget Sound Estuary Program has monitoring
lnd restoration protocols that wiiI be followed during remediation to ~nsure that the remediai
lctivities result in oanhancement of fishery resources.
.~esidents 'ilressea :he ,'leed for commumcalWIl 0.' pme1ll1al \.ea,ooa ,:omamillacu)f! .iallr;ers :0
residenrs with differences in language or cuiturai iJackgroullds.
Response: TPCHD posted warning signs and notices in several languages along the waterways
and shorelines to try to discourage fishing and heavy seafood consumption by residents with
differing language or cultural bac:kgrounm.
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Residents expressed concern abouJ possible job loss and economic effects on residents. the Port and
city of Tacoma. tideffats business. and others. Concerns included potential adverse publicity about
Tacoma's pollution problems which may drive potential new businesses from the area.
Respoue: In recognition of the potential adverse economic impaCtS of a rigid cleanup
strategy, the agencies have recommended.and now selected a remedy that provides maximum
flexibility during implementation while still achieving the project cleanup objectives in a
timely manner. The agencies must carry out their statUtory mandates to protect public health
and the environment. Economic concerns are therefore of secondary importance in the
selection of remedy, although the agencies consider cost effectiveness when deciding among
equally protective remedies. In the selected remedy, the agencies ensured protectiveness and
then built in flexibility by allowing a choice between four different confinement options if
sediment remedial action is necessary. This choice will be guided by technical and economic
considerations, involving the port, the city, businesses, and the entire affected community.
Environmental protection, cleanup and restoration should yield long-term benefits for business
as well as benefia to people and the environment. As the Tacoma News Tribune stated
fOllowing the public comment period, cleanup should result in the enhancement of Tacoma's
reputation as a progressive city, and promote economic groWth.
Residents htne consiste1'llly been concerned abouJ public inyolyemenl in Superfund decisions and
receiving timely and accurate information about area Superfund actiyities.
Respoase: The agencies have responded to this concern by working with interested citizens,
including the Citizens Advisory Committee (composed of citizen volunteers and representative
of organized citizens groups), publishing periodic and site-specific fact sheetS, releasing
significant information to the press, maintaining 16 information repositories, and holding a
120-day comment period on the proposed plan. The " agencies also plan a continuing effort to
facilitate information exchange between the agencies, PRPs, organized citizens groups, and
citizens at large in the general review of tec:hnic:aJ and planning issues during the cleanup
phase of the project (see Future Community Relations in this section).
Some residents haYe questioned the effectiveness of the agencies inyolved with the investigation and
site cleanup actions. as well as the degree and effectiveness of cooperation and consistency among
agencies.
Response: The agencies recognize this concern and agree that this has been a problem at
times. However, the agencies believe that the proposed plan and selected remedy reflect an
awareness and consideration of the opinions and concerns of the affected community, and
local, state, and federal agencies. The complex. unique, and precedent-setting nature of the
site has required extensive involvement. cooperation. and commitment on the part of the
1gencies. The Commencement Bay UBA T. Marine Resource Protection. :md storm drain
programs developed in resoonse to the site Jre three ~xamples or these dfofts. inrefagenc::
cooperation through the Technical Oversight Committee has enabled scientific and technical
~eview I)f work products. Project management support ilas been facilitated chrougn the
Superfund Cooperative AgreementS with Ecology and the PuyaUup Tribe of Indians.
Some cirizens raised questions about ash and potential air emission from a proposed illczneralOr ill
lhe lidei/azs.
Response: TPCHD has monitored existing incinerator emissions and determined that ,hey 1re
,lOt :1armrul. fucure .:misslOns ;1:lVe been modeled. ';nd ~o iong :lS ;Jrooer procedures Jfe :"oiiowea.
lC is Jeiieved the ~missions will continue to oe safe. The health department i:i che :J.ppropn:lte
agency to address these concerns.
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m. RESPONSE TO COMMENTS RECEIVED
DURING THE PUBUC COMMENT PERIOD
Section m is a summAry of the agencies response to comments submitted during the public
comment period which were germane to the selection of the remedy. The comment period was
held from 24 February to 24 JUDe 1989. The comments and responses have been categorized by
relevant topics and numbered. Section IV is a summary of comments that have not yet been fully
responded to and a discussion of how they will be addressed during monitoring, remedial design,
or remedial action.
Since such a large volume of comments was submitted, Section V has been included as an
annotated bibliography. This section was prepared to assist commenters in tracking between their
original comment language and the responses in this section. .
1. PROGRAM ISSUES
Program-related comments questioned the suitability of the cleanup goal and the IO-year
recovery timeframe, and the role of evolving state policy. concerning sediment contaminatiOJ1.
Comments were received fE:Om the Puget Sound Water Quality Authority (PSWQA), U.S. Army
Corps of Engineers, Washington Department of Natural Resources, tRe' Puyallup Tribe of Indians,
and several private citizens. Comments generally addressed adherence to existing policies (e.g.,
no net loss of wetlands), programs [e.g., Puget Sound Dredged Disposal Analysis (PSDDA)], laws
(e.g., CERCLA), and treaties.
1.1. Comments Related to CERCLA Requirements
1.1.1. The failure to consider alternatives for permanent treatment of wastes is contrary to
Superfund regulations (CERCLA). The preferred alternatives in the feasibility study do not
represent permanent solwions.
Response: CERCLA specifies a preference for permanent treatment as a principal component
of the selected remedy. However, EPA guidance indicates that this preference is appropriate
for wastes that are highly concentrnted, toxic, and involve relatively mobile contaminantS. In
contrast. contaminated sediments at the CB/NT site. while toxic, involve very large volumes
of ~e!atively low concentrntion wastes with relatively high panicle lifinity I i.e.. :ow mobiiity J.
Confinement llternatives thus offer the most '.;ost-~ffec:ive means 'Jr" lchieving :1 ~e:-manem
,olution 1t :ne CB/NT:ite.
i.i.:'. The 'Jom 0; "'/0 acuce ur chrome adverse effects" till marine ur!:amsms ;s 1101 reaUlred 11\' W/V
u.ppiicaiJie iaw and shouid !lot he adopted as [he goal lor cleanup.
Response: Under CERCLA, the degree ot' cleanup is often set by JPpiicable i:lws. However.
when no lpplicable promulgated standards or requirements exist, dean up levels must Je
developed utilizing other appropriate 3uidance Jnci risk JSsessment methoas. Since:1o
promulgated criteria exist for sediment quality, the goals of the PSWQA olan provide
;moortant -:;uidance on ~stabljsnjng C3/NT deanup ~oals. ~lement ?-2 ()t' :t1e ;Jian reauires
Ecology to develop and lciopt standaras (or iong-term sediment 4uaiity in ?uget .souna mat
will help prevent acute and chronic adverse effectS on biological resources and significant
health risks to humans.
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1.1.3. The feasibility study has failed to comply with the Nalionai Contingency Plan. For example.
the study is too broad (comprising the entire bay) and is based upon inadeqU/Jte data for any given
segment of the bay.
Respoase: Throughout the CB/NT Superfund project, EPA has followed the regulatory
provisions contained in the National Contingency Plan (NCP). The NCP requires a remedial
. investigation/feasibility study prior to making cleanup decisions to gather enough data to
characterize the nature and extent of contamination, and to evaluate alternative remedies for
problem areas. The remedial investigation/feasibility study for the CB/NT site, therefore,
began by enm1ning the entire bay. In later phases of the study, nine specific problem areas
were deimed, and remedial alternatives were examined for each problem area. The remedial
investigation/feasibility study database was adequate for these decisions. This Record of
Decision recognizes that additional monitoring data must be gathered as part. Of the next
phases of the project to more accurately assess source control, natural recovery rates, and the
volume of contaminated sediments.

1.1.4. The PuyaJ/up Tribe of Indians has not been provided a meaningful opportunity to participate
in the deY~lop1M7U of the feasibility study. The PUYaliup Tribe of Indians also maintains the
feasibility study should take into consideration EPA's DroDosed NCP which implements SARA.
Respoase: The involvement of the Puyallup Tribe at the CB/NT site has been important in
the remedial investigation/feasibility study as a member on the Technical Oversight Committee
from 1983 to 1988. For example, the Puyallup Tribe was instrumental in identifying habitit
and marine resource issues that were included in the feasibility study. The Superfund
Cooperative Agreement between the Puyallup Tribe and EPA (April 1989) was the first in
Region 10, and establishes the Puyallup Tribe as a supporting management agency for the
project. The role of the Puyallup Tribe as a supporting agency in the selection of remedy has
been important to the project and significant to the Puyallup Tribe as evidenced by their
concurrence on the selected remedy. The combination of the Puyallup Tribe's historical
involvement at the CB/NT site and their current status as a supporting project management
agency suggests a meaningful opportunity to participate.
1.1.5. The feasibility study has failed to take into consideration the fact that much of the
contamination targeted for remedial action (in some areas) is a result of a "federally permitted
release" and therefore !lOt actionable under CERCLA.
Response: Section 107(j) of CERCLA provides that response costs or damages incurred by the
United States resulting from a "federally permitted rele:l5e" are not recoverable under
CERCLA, but only pursuant to existing law, such as other applicable federal statutes or
:ommon law. Section 101(10) of CERCLA defines 1 federally permitted defense by
specifically enumerating certain rele:l5es in compliance with permirs or luthorized Unl!~:-
:'~der:ll or stolte ~nvironment::ll laws. EP.\ proDosed re~ujations to define rhe ~':ooe .1{' c!lis
~.v;emption 0n ;9 J"uiy ;988 i53 ?~deraj Register ::-:6~)..vith :;ubsequent ;lotices ~:ope~rin~
:n .he Federal J~e~ister on II July 1989 t 54 Federal Register 29306i ~nd ~ -\ugust : 989 ; 54
Federal Register" 32671). At this time. rhe regulations are not final.
The fe:l5ibilicy study is not reauired to evaluate or enumerate federally-permitted releases.
Although there may have been federally permitted releases :It the Commencement Sav :;jre.
it is not :1ecessary :0 examine whether J ,ele:l5e was federally permitted 1t chis :ime. The
burden or proving :l federally permitted rele:l5e rests with rhe P:lrty daiming chis defense :0
:i:lbility. !ts :1Dplication is likely to be limited lt che Commencement Bay site :lOd m:w "e
,nore :mproOrJ:lteiy ~'.'aluatea ,m :J. case-i)y-..:ase 'J:lsis :,y SPA .lurin~ Clle '::OSt-:"ecoven'
~niorcement and negotiation process.
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1.1.6. Considering urban runoff. historical sources. and NPDES-permitted discharges exempt from
CERCLA coverage. the Superfund should be tapped to pay at least a portion of the remediation
costs at Commencement Bay.
Respoase: Ljability under CERCLA is strict~ joint~ and several~ meaning any party liable
under Section 107(a) of CERCLA may be held responsible for reimbursement of all of EPA's
costS. With the exception of federally permitted releases, there is no defense for historical
conrnmination sources or urban runoff. Superfund monies have been used to date to pay for
the entire remedial investigation/feasibility study and related enforcement. costS. EP A will
aggressively pursue recovery of these costs from the over 100 named PRPs at the site, and will
attempt to reach settlement agreementS with the PRPs for future remedial action described in
the Record of Decision. To the extent that no viable PRPs are available, or if they are able
to successfully prove a defense to liability, EPA may use Superfund monies for such cleanup
(consistent with EPA guidance, e.g., for mixed funding) or seek to recover such costS from
the other PRPs. .
1.1.7. The proposed plan would not satisfy the CERCLA preference for onsite remediation where
feasible.
Response: The selected remedy satisfies the preference for onsite remediation since the
selected suite of sediment commement options includes feasible onsite options including in situ
capping, confined aquatic disposal, nearshore confinement, and upland disposal, all of which
are to be implemented onsite.
1.2. Comments Related to Coordination with Other Programs
1.2.1. While apparent effects thresholds (AETs) satisfy cleanup goal requirements. these mayor
may not be in agreement with final state sediment quality standards. The use of alternalive criteria
would have major imp~l.s on remediation plans and costs. This issue and any potential conflicts
should be resolved before selection of a final remedial alternative.
Response: As noted by the commenter, the AET approach is one of the alternatives for
developing state sediment quality standards and satisfies the criteria for identifying sediments
having adverse effectS on biological resources. Interim standards to address Element P-l of
the 1989 Puget Sound Water Quality Management Plan (PSWQA 1988) are in the process of
being released by' Ecology. These sundards will be used to identify an inventory of
contaminated sedimentS to be managed through various programs but not :lS enforcement
standards for sediment cleanup. The target cleanup levels at the CB/NT site are generally
higher concentrations than the interim standards :lS ~urrently proposed. The PSWQA (PS\VQ,-\
1989) has supported the use of the amphipod :md oyster embryo bioassays :md benthi.: ~nt":1unJ
lnalysis and the .Iowest AET Jssociated wirh these three rests to me:lSure ,;omolian.:~ '.vim :h~
:ong-term deanup goal ~n CJmmencement Bay. However.:::s '.vith .lny Suoerr'unc.i ;Jroj~~:.
::s :lDplicable standards :md requirements ::tre promul~a[ed :It ~irher rhe federaL .,r:lte. .)r :riinl
level. they will be evaluated by EP A in relatIonship to this Record u( Decision :0 determll1e
wnether the selected remedy can 5till be considered adequately protective of human neaithlna
the environment. .
! ..:..:. The reiallonshio netweell rnUlille t.ired~ifl{: ..7rojeCtS wIder PSDDA tlllci Ic:dimelll rc:mc:dialliJ/l
:maer CERC1:.A is :lOt ciear hecawje !lIe C3, .VT I'edimelll :{uaiit)' on /ecllveszre liignUl"l1lJrc
;trillr:enc than (he PSDDA '.:!Iideiilles t'nr "fJen-water. :/Ilcollfilled ,iisfJosai 'If \cdimcms. Ti!l
.::aimems ..vititill 1.1 C3/:\fT )rohic:m urea ,hat ::ass /'SDDA. .;wdciillcs .7C .:CCCDlea .ur .:i.\rfl\(:z .:
a PSDDA disposal site? .. . .
Response: As a general pOlicy, theEPA Superfund program does not intend to require PRPs
to remediate sedimentS that could be taken to il PSDDA site. Such sedimentS would likely be
in marginally C'Onrnminared portions of problem are:1S rtr.rr:lre prediCTed fa recover It:uuraHy
and will therefore not require active remediation under Superfund. Sediments passing PSDDA
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guidelines may, therefore. be considered for disposal as non-Superfund wastes under Clean
Water Act Section 404 regulation at a PSDDA disposal site. However. there may be situations
where PRP3 will be required to undertake sediment cleanup actions for sedimentS that pass the
PSDDA guidelines. Examples of such situations include the following: elevated concentrations
of PCBs or other conr.amin~ntS that have a high potentia! for bioaccumulation in a nearshore
area. but demonstrate relatively low toxicity in laboratOry tests; elevated concentrations of
conr.amin~nts that are highly toxic to benthic communities but exhibit relatively low toxicity
in laboratory tests; highly conr.amin~ted surface sediments with relatively clean underlying
sediments; and elevated contamin!lnt concentrations at sites with low sedimentation rates.
Based on available sediment data., it does not appear that problem sediments requiring active
remediation will pass the PSDDA guidelines. If they do pass, but are removed as part of the
Superfund enforcement action, it is unlikely that they would be accepted at a PSDDA disposal
site. .
1.2.3. Ecology and EPA should continue to monitor a&tivities in areas other than the CB/NT
problem areas and require site chara&terization and remediation w/rnt warranted.
Respoue: Although agency oversight of Superfund response actions for CB/NT source control
and sediment remediation will be limited to the problem areas described in this Record of
Decision, EP A and Ecology will' continue to investigate aDd regulate activities in other portions
of the site. However, in areas that were not identified as high priority, the agencies will
!ldmini.r and enforce environmental laws and regulations iaciuding CERCLA authorities. but
not as response actions related to the CB/NT site. Ecology's Commencement Bay UBA T, for
example, will continue to coordinate its efforts with sever.al other Ecology programs to address
contamin!lted properties, wastewater discharges, air emissions and storm drains that are within
the CB/NT site but not related to Superfund response actions at the site. Similarly, various
other feder.al, state, tribal, and local programs will continue to be implemented throughout the
site in circumstances that may not be related to the CB/NT selected remedy.
1.2.4. What is the regulatory status 01 the integrated a&tion plan and what is its relationship to the
Record 01 Decision? What is the process lor public comment on the integrated a&lion plan?
RespoDse: The integrated action plan was part of the overall feasibility study for the CB/NT
site and is used for resource planning and scheduling, rather than for scheduling of
compliance actions. The timetables outlined in the integr:1ted action plan are intended to be
updated on an annual basis to reflect changes as over.:ill project implementation proceeds. The
integrated action plan was therefore part of the material which the public was invited to
comment on during the public comment period. BeQuse this planning document will be
updated periodically, new comments and concerns should be raised to the agencies as they
:lrise. :lnd where possible and consistent with the law and the selected remedy. changes may
be made. Information exchange berween the agencies and the affected <.:ommunity should J.iso
'Je ~nhanced through Technical Discussion Group meetings JS Jescribed in Scc:ion a ur' :IH~
Responsiveness Summary.
1.3. Comments Related to ARARs and TBCs
1:3.1. The /989 PSWQA plan goals shouid he adopted o.l.S applicable or "eievam and r..J.oprooriate
:eOUlremems I ARARs I.
:~esponse: The! 989 ?SWQA ;Jian Joes 'lOt provide i')romui~ated ,:riteria. 3randards. )r
~equ1rements: rather it requires their Jevelopment. Because ;he ;)Ian does not provide
applicable or relevant and appropriate standards, criteria. or requirements. it is not listed as
an ARAR. However,several plan elements (e.g., Elements P-6, P-7, P-2, and 5-4) call for
the development of ARARs at some point in the future. These elements are listed as major
requirements.. guidelines. aDd policies to be considered (TBCs) in. the Record of Decision. in
accordance with EP A guidance on compliance with other laws.
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1.3.2. Maximum Contaminant Level Goals. the indian Religious Freedom Act. and the Narional
Historic Preservation Act must be adopted as ARARs.
Response: In a clarification letter from the Puyallup Tribe of Indians to EP A (22 August
1989), these laws were not cited as applicable or relevant and appropriate requirementS and
have not been included for this reason. .
1.3.3. Promulgated allowable concentrations in lish 01 PCBs and mercury should be considered as
ARARs.
Response: There are no promulgated criteria or standards for PCBs and mercury concentra-
tions in fish tissue. The cleanup goal selected for PCBs in sediment is based on conservative
risk assessment mOdeling. A sediment PCB concentration of ISO ~g/kg (the cleanup goal)
would be expected to result in a mean fish concentration of 37 ~g/kg (wet weight) or less than
0.02 of the FDA action level for PCBs (2,000 ~g/kg). FDA action levels are included in the
list of major chemical-specific TBCs; however, they incorporate economic considerations as
wen as risk assessment calculations. Site-specific risk information, as developed for this
Record of Decision is generally considered to be more appropriate for setting cleanup
objectives. There are currently no tools available for estimating sediment mercury
concentrations relative to fish tissue concentrations except risk assessment methods similar to
those described in this Record of Decision.
1.3.4. Protection 01 human health and the environment must be the most important evaluation
criteria. Federal and tribal standards must not be violated.
Response: EPA recognizes the importance of these factors in the decision-making process.
CERCLA guidance requires that each remedial alternative be evaluated according to specific
criteria. Both factors mentioned in this comment are reflected in what are considered the
~threshold criteria" for evaluating cleanup alternatives. The threshold criteria must be met by
the candidate alternatives for further consideration as possible remedies. The threshold
criteria are 1) overall protection of human health and the environment, and 2) compliance
with ARARs (where appropriate or relevant and appropriate federal, state, and tribal
regulations are applied).
1.3.5. Interim tribal water quality standards must be considered as ARARs.
Response: The Record of Decision lists Puyallup Tribal Council Resolution :--10. 15\ :33C
(resolution adopting the Puyallup Tribal Water Quality Program) as a chemic:lI-specific AR.-\R
bec:luse this resolution adoPts Washington Water Quality Stand:lrds and requires nondegrJda-
tion and enhancement of water quality (this resolution 1lso Jpplies to sediments I.
: .,::.u. The P:.Jyallup'Trine of {lldiml::;" cu.itUrai rJ./ui \pirwwi ,fes ;u cite _';)lIltJ.mill~I~'a' ..i:~' 1::;.\: "-'
t;(Jl/sldered ill the selecrioll of remedy.
Response: Tribal Council Resolution No. 71k38 is listed in the Record 01 Decision JS J TBe.
This resolution requests EPA to include tribal environmental standards within the t'e:lsibiliry
5rudy, lI1d includes by reference rhe Tribe's fishing rights :md .;ultural :md spiritUal :ies :0 :11e
C3/NT site.
1 ,-
,..J..' ,
The Puvalluo Land Claims Settlemem should he illcluded ~s illl-lRAR.
Response: The land daims settlement is included as an ARAR t'or the site beC:lUse it '.VJS
recently promulgated as federal law and because it specifies enhancement of fish resources in
the Puyallup Delta,
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2. HUMAN HEALTH RISKS (S~OOD CONSUMPTION)
Two main categories of commentS on the Commencement Bay health risk assessment and
feasibility study were received. In the first series of commentS, the reviewers maintained that the
human health risk assessment (Versar 1985) for the CB/NT remedial investigation overestimates
risks to consumers of I1sh and shel1iISh in the study area. The major comments in support of this
position were submitted by the Commencement Bay Group, as prepared by ENSR (1989), and
Pennwalt (1989). Other comments supporting this position included Manke Lumber (1989),
Pickering (1989), Port of Tacoma (1989), public and environmental group (1989), and City of
Tacoma (1989). In the second category of comments, the PuyaUup Tribe of Indians' (1989)
maintaiJied that the remedial investigation/feasibility study risk assessment underestimates health
risks to humans consuming iISh and shellfish in Commencement Bay. They suggest that the
remedial investigation/feasibility study risk assessment should address cumulative health impactS
to tribal families that rely aD fISh for large portions of their diets.
The risk estimates based on contaminant concentrations in English sole muscle tissue as part
of the CB/NT remedial investigation are approximately 5 times higher. than those calculated as part
of the ENSR (1989) comments. The average risk estimates calculated as part of the CB/NT
remedial investigation would be lower than estimates taking into account factors such as high
seafood consumption rates by tribal Indians. The risk estimates for PCBs in English sole calculated
during the CB/NT remedial investigation are therefore intermediate in magnitude between those
estimates suggested by various commenters on the feasibility study.
2.1 Comments Related to Baseline Risk CalcuJatiODS Cor HUIIUID Health
2.1.1 The feasibility study overestimated the humtJn health risks in Commencement Bay by nearly
an order of magnitude. This lower risk is within the generally acceptable range and is comparable
to the risk reported in the feasibility study for the reference area. Carr Inlet. This indicates that
sediment clean-up based 011 human health risk is not warranted in Commencement Bay.
Respoase: The baseline risk assessment for the CB/NT remedial investigation indicates aD
unacceptable excess risk compared with other Puget Sound reference areas. The assessment
concentrated on PCBs and arsenic in muscle tissue of English sole and crab. Only PCB
contamination was predicted to produce more than one cancer case over a 70-year exposure
period in the exposed population. Risks from arsenic consumption in Commencement Bay
seafood were less than corresponding risks in the Carr Inlet reference area. Based one these
data, only data for PCBs were used in the feasibility study to establish a target cleanup level
for sediments.
Only two setS of data are available to evaluate the relative excess risk of cancer JSsoci:Hed
with PCBs in English sale muscle tissue in the CB/NT waterways c:omp:ued with reference
.lre:lS of Puget Sound: :J. :Jtudy by Gahler ~t at. (198:) and the remedial investig:Hion (T ~[r:J.
Tech 1985). Assuming equivalent fish consumption rates in the CB/NT waterways :lnd
;eference area. the estimated risk of ..:ancer JSsociated with ..:omamination or" Sn~lish ~ole
muscle tissue would be directly related (0 the concentration or" PCBs in the fish. Based on .he
data of Gabler et aI. (1982) and the remedial investigation (Tetra Tech 1985). cancer risk
JSsociated with PCBs in muscle tissue of English sate from the CB/NT waterways is an order
or" magnitUde or more greater than that JSSociated with PCB contamination in reference :lre3So
Therefore. an excess risk or" "::J.ncer ~xis[S in :he waterways relative [0 remote :md relatively
uncontaminated areas of Puget Sound. The CB/NT remedial investigation also demonstrated
:hat ?C3 concentrations in Sn~lish sole muscle tissue [orom the C3/ NT waterways :lre ~ie'!:uea
relative to those Jiang the SOuthwest snoreline of [he cay.
The CB/NT remedial investigation estimated individual cancer risks for consumption of PCB-
contaminated fish to be somewhere in the range from 6x10.3 to 2xlO" (depending on the
assumed CODSUlllpUOD r31&). Risk revels of to" to ro-s are higher than EPA's ~irrt of
departure (Le., 10.0) for determining remediation goals. An additional lifetime cancer risk
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greater than I x 10"3 .is definitely considered unacceptable.. Thus, the predicted lifetime risks
associated with PCB contamination of English sole muscle tissue in the CB/NT waterways may
present an unacceptable excess risk compared with reference areas of Puget Sound.
. Further discussions related to this comment are provided in the fOllowing portions of this
section.
2.1.2. The estimate 0/ carcinogenic potency lor PCBs 1PUZy be incorrect.

Respoase: A carcinogenic potency factor of 4.34 (mg kg"1 day"1)"l was used in the CB/NT
remedial investigation to calculate PCB risk from rJSh consumption. ENSR (1989) used a value
of 7.7 (mg kg"1 day"l)"l for the carcinogenic potency of PCBs to estimate risks from fish
consumption in Commencement Bay. A value of 7.7 is the current carcinogenic potency factor
estimated. for PCB 126Q by EPA. and was used in the feasibility study to establish recom-
mended cleanup goals for PCBs at the site. Use of the higher carcinogenic potency estimate
in a revised baseline risk assessment for Commencement Bay would result in higher risk
estimates by a factor of approximately 1.8 from those reported in the remedial investigation.
2.1 J. The selection 0/ English sole t1S an in/iiCl1lor species was i1Ulppropriate lor the risk t1Ssessment.
The feasibility study should June used data/or species that are more commonly ho.nested by local
fishermen Sll&h t1S market squid. salmon. Pacific 1ulIc6. and Pacific cod. This would htlVe resulted
in lower risk estimates because commen1ers further claimed that concen1rations 0/ PCBs in the
commonly ho.nested species would be lower tJuzn those in English sole.
Respoue: The selection of English sole for the remedial investigation risk assessment was
appropriate because the species could be used as an indicator for both human health and
ecological risk assessment. English sole were selected because they occur in relatively large
numbers in Commencement Bay. English sole also live in closer association with the sediments
and would be expected to accumulate bioavailable conrnminants in sediments. They were cited
in the remedial investigation report (Tetra Tech 1985) as a conservative indicator of the
maximum conrnmin~nt levels that would be expected to occur in edible tissue of harvested fish
species. The remedial investigation acknowledges that English sole are not commonly caught
by local fisherman. English sole does not necessarily represent the most contaminated species
among those- harvested by recreational anglers. Available data from the CB/NT waterways and
Puget Sound as a whole suggest that PCB concentrations in muscle tissues of other fish soecies
may be higher than those in English sole (Gabler et aI. 1982, Tetra Tech 1985). Basea on a
limited number of samples, Landolt et al. (1985) found the opposite pattern (i.e., concentr:1-
tions of PCBs in muscle tissue of English sole were lower than those in some commonly
harvested species). Tetr:1 Tech (1988, Figure 6) showed that mean concentrations of PCBs in
muscle tissue of Pacific cod was higher than that for English sole based on data collected
:hroughout Puget Sound. The mean concentration of PCBs in English sole (approxim:ltely 130
,ug/kg wet weight) throughout Puget Sound was within ~ factor of approximately two times
~he concentration in commonlv harvested species (i.~." ~tarrv r'lounder. Pacific ;,aK~. C:1inooh:
saimon, and rocki'ish) (Tetr:1 Tech 1988), .
The data cited by commencers (ENSR (989) [0 suPPOrt selection of commonly harvested
species applied to ail urban bays sampled by NOAA in 1985, not just in Commencement Bay.
~oreover, corrections of consumption rate data to account for seasonai :J.vailability of species
[which were not performed by ENSR (1989)] would affect the choice of dominant species in
the diet of recreational angiers. PCB .;oncentration data selected by ENSR (1989) in their
lJternative baseline risk assessment are biased toward low values when aJ1 data for commonly
:Iarvested species and English :iole :1re I.:onsidered. Cuncentration Jata in E:NSR (1989) ;nay
have Jeen biased coward low values lJecause :iampJing locations where ;"isn were ..:oilected were
not considered (see response to Comment 2.1.5).
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2.1.4. Fish consumption rales may be overestim~ed or underestimaled.
Response: Estimates of seafood consumption rate to be used in a risk assessment depend on
human subpopulations surveyed, seasonal availability of fish species, and assumptions used to
ca1cu1aa! consumption rates from survey data. Many limitations are inherit in surveys for IlSh
consumption. rate data (Landolt et al. 1985; ~rok 1988). Because of the uncertainties in
estimating IlSh consumption rate, it is appropriate to use a coaservatively high estimate in risk
assessment. As noted earlier, risk estimates in the remedial investigation were presented for
a range of consumption rates. The estimate of approximately 12 grams/day used in the
feasibility study to generate a PCB cleanup objective represents the average consumption rate
for Puget Sound anglers, but only about 10 percent of the anglers surveyed in Commencement
Bay (Pierce et ale 1981) apparently consume seafood at a higher rate than that. The value of
12 grams/day. also corresponds to the approximate averaae IlSh consumption estimated for
Puget Sound anglers (Tetra Tech 1988). Adjustment of consumption rates for seasonal
availability of fisheries may result in a lower estimate, but uncertainties regarding actual
changes in harvest and consumption over an annual period make such corrections tenuous.
Moreover, anglers may shift species preference as the availability of species changes over the
year, while maintaining an approximately constant consumption rate. Therefore, the estimate
of 12 grams/day represents an appropriate moder.ue CODSUIDpQon rate for recreational anglers
for use in a risk assessment. However, this rate is less than the consumption rate for special
subpopulations that may rely on local seafood for a large portion of their diet (e.g.,
consumption rates in excess of I pound/day were also identified in the Commencement Bay
survey.
2.1.5. The effects of fishing location preference and a mixed seafood diet should be considered in
developing risk estimales.
Respoase: Gabler et ale (1982) and the CB/NT remedial investigation (Tetra Tech 1985)
provide the only data setS available for PCB concentration in muscle tissue of fish from the
CB/NT waterway system. Data cited by some reviewers in support of an alternative risk
~ent were taken from Tetra Tech (1988) and Landolt et at. (1985). Station locations for
these studies were primarily away from the waterway system either in Commencement Bay
proper (e.g., salmon data) or along the southwest shoreline of the bay. Because PCB
concentrations in fish collected from the waterway system are substantially higher than those
collected from other loc:1tions in Commencement Bay, data for open waters of the bay and the
southwest shoreline are inappropriate for use in estimating risks associated with consumption
of fish from the waterways.
2.1.6. CumuJalive health risks from ail dangerous chemictiis such as 2J.7.8-tetrachiorodibe1r=odioxill
must be addressed in the establishment of a protective cleanup objective.
Response: As explained in the Record of Decision (Section 7), PCB mixtures were che onl\'
C3; ~T chemic:lls .01 concern posing l human health risk :lbove ret'erence conditions :lna
therefore warranting remedial action under Superfund. However. recent informauon
developed during EPA's ~ational Bioaccumulation Study indicates that contammauon iJY
chlorinated dioxin and furan isomers in CB/NT fish and sheHfish may be comparable in terms
of human health risk to those associated with PCB contamination. Thus. baseline health risks
identified in the remedial investigation may be low by a factor of cwo. The study did :lot
present sufficient data to compare chlorinated dioxin Jnd furan contamination in sediments
:md biota with reference areas in Puget Sound. nor is it sufficient to determine the spaual
distribution of contamination in Commencement Bay. Additional data will be collected :lS l
~esuit 'JI planned i::P A 3tudies J.nd J..S part i)[' s::unoiin~ ,)f selected eEl NT sources ~nd :)roolem
lreas auring the remeaiai design pnase. These additional data will be used [0 :vaiuate :he
protectiveness of the selected remedy relative to chlorinated dioxins and furans prior to
implementation of sediment remedial action.
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2.1.7. The method 01 lish preparalion lor consumption may reduce contaminant concentralions.
Cooking in particuJar may result in up to an 80 percent reduction in the PCB concentralion in
ingested lish.
Respoase: It is recognized that the various methods of preparing tuh for consumption may
affect a>ncentrations of PCBs in tissue consumed. Although some studies repon that cooking
can substantially reduce PCB concentrations in tISh tissue, other studies have shown that PCB
loss during cooking may be as little as 2 percent. Some cooking methods also activate or
create carcinogenic chemicals. Because of the uncertainties about the net effects of cooking
on PCB .concentrations, corrections for the effectS of cooking in the risk assessment are not
possible at this time. Although the lack of correction for PCB loss in cooking may result in
a slight overestimate of risk, the use of data for skinned fillets during the CD/NT remedial
investigation would tend to underestimate risk. Studies have shown that PCB concentrations
in unskinned. fillets are higher than those in skinned fillets. Landolt et aL (1985) estimated
that 19 percent bf the meals consumed by Commencement Bay anglers consisted of unskinned
fillets. Therefore, the actual method of tuh preparation may result in either higher or lower
estimated' risk when compared to direct assessment of raw, skinned fillets. Because of this
uncertainty, PCB concentrations were not adjusted for the preparation technique prior to
consumption.
2.2. ColllllleDts ReJated to Cleanup Level tor HUIIWI Health
\
2.2.1. The sedi1lW1fl qu/lJity objective lor PCB mixtures represent a level 01 excess risk that is not
protective to the ](1" level.
RespoDse: The sediment Quality objective for total PCBs at the CB/NT site represent an
excess risk level of 10'.5 for a consumption rate of 12 grams/day of English sole. The
objective was established relative to both risk assessment calculations and ambient levels of
PCBs in English sole caught in reference areas (which also correspond to 10'.5 risk levels).
Management of site risk! was based on an. assumption that it would be infeasible to establish
sediment Quality levels at the CD/NT site that were cleaner than reference areas. Thus, high
consumers of seafood at the CB/NT site may experience risks in excess of the 10..0 level, even
after site remediation is complete, but it will be similar to reference area risks.
3. ENVIRONMENTAL RISKS (SEDIMENTS)
Potential environmental risks of sediment contamination were evaluated in the CB/NT
feasibility study using a suite of biological indicators, including sediment bioassays and in situ
~valuations 0" the benthic macroinvertebr:1te lSsemblages indigenous to the bay. The primary
0bjective of these evaluations was to provide a direct measure of the effects of sediment
;::>ntamination to determine baseline risks ,0 Cummencement Say biota. These melSures were :naue
by making statistical comparisons to conditions at relatively uncontaminated referenc~ areas. The
;ieanup goals derived from the biological :.ssessmentS were t'ocused on :ninimlzing :11e -isk )(
future ad verse biological effects as a result ot" sediment contamination in the bay.

Three major kinds of comments were received with respect to the biological indicators :.lsed
in the CB/NT feasibility study. They include 1) those related to the appropriate use oi ':Jioiogic::l1
:ndic:1tors ana reference 'lreas in general. :) those related specificallv ,0 sediment bioa.ssavs :100
benthic macroinvertebrate analyses. and J) those related to the approp~iateness of the clean~p goal
'.lased on environmental health. [n ,his section. ~he major issues iel:lted ,0 each of :he :hree !:inas
\Ji .;omments Jre d.iscussed. The use oi 'various biological indicators :lS :lSsessment ,OOIS. ,nelf
calculation, and application in developing the cleanup goal were Questioned by several PRPs; their
comments were generally summarized by ENSR (1989). The lack of chronic tests (or the exclusion
of the Microtox test) for use as an assessment tool was questioned by NOAA Ocean Assessments
Divisia~ the Puyallup Tribe of {prli~n~. and the Sierra. Club.
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The rationale for the selection of the biological indicators used in the CB/NT remedial
investigation and the AET database is an important consideration for these issues. Biological
testing was used to determine impacts of sediment chemical contamination for several major
reasons. First. it allows evaluation of the potential effects of chemicals for which standards are not
available and chemicals tbJu may not be measured during typical assessmentS. Second, it allows
assessment of the effects of complex mixtures and thereby accounts for interactions among
chemicals (e.g., additive, synergistic, antagonistic). F"malIy, biological testing provides an empirical
assessment based on the actUal bioavailability of chemicals in sedimentary environments.
3.1. CoDUDeDU Related to Baseline RIsk. Concepts tor EDviroDlDeDtaI Protection
1.1.1. Approprimeness 01 btUeline risk assessmenl targets some sediments 10,. aaive remedialion
where t~e~ May be thriving ecological communities.

Respoase: The environmental risk assessment focused fint on toxic chemicals in the marine
environment with respect to reference areas, and second on the relationship to ecological
function. It was recognized that all biological measurements (as wen as chemical measure-
ments) have a certain amount of uncertainty associated with their measurement and
interpretation. This uncertainty arises largely from the complexity of biological systems.
Because of tlUs uncertainty. multiple biological indicators were used in the remedial
investigation and AET database. The use of multiple indicators allowed impacts to be
determined using a preponderance-of -evidence approach. That is, as more indicators
identii1ed a station as impacted, confidence increased that the station was truly impacted. (See
the responses to Comments 3.2.3 and 3.2.4 for additional discussion on the appropriateness of
designating adverse impacts based on laboratory bioassays compared with in situ benthic
analyses.)
1.1.2. The relerence areas selected lOT evalualion 01 bemhic macro;nvertebrmes may be inapprop-
rime.
Respoase: The appropriateness of the reference areas used to evaluate potentially impacted
sites was questioned. Several commenters suggested that the reference areas did not match
the potentially impacted areas with respect to all important characteristics, and that effects
determined at the latter sites may have been due to characteristics other than chemical
toxicity.
It is recognized that the characteristics of benthic macroinvertebrate :lSsemblages are
influenced by a wide variety of physical. chemical. :md biological variables. Bec:lUse there
are so many potentially important variables. it is unlikely that a perfect reference :uea can be
found for any potentially impacted site. Instead. it is more practic:11 to select :l reference :lre:1
that is :lS similar :lS possible to the potentially impacted sites with respecr ro che most
;mportant "ariables. For the remedial :nvestig:ltion :lnd AfT datab:lSe. che vari:loies ~sed ro
~eJect reference sites were season. depth :lnd sediment character (represented by sediment grain
3ize,. These- variables :lre. chree- of che most important ones !,nown ,0 influence the
characteristics of benthic macroinvertebrate :lSsemblages (Gray (981). In :lddition co chese
three major variables. the artificial environment created by the manmade waterways of
Commencement Bay was :lddressed by selecting :l manmade waterway (i.e.. Blair Waterway)
JS :he reference :Irea for those ~nvironments.
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3.2. Comments Related to Baseline Risk Calculations for Environmental Protection
3.2.1. There is a lack of ecological relevance for bioassay test species used in the remedial
investigation and tM AET database. Because these indicators do not measure in situ biological
eflecu. they 1uzN little ability to pt"Nict impacts on tM CB/NT' ecosystem. The use of mIljor taxa
(i.e.. Polychaeta. Mollusca. Crustacea) is too crude of a response variable to determine impacts
accurately: mll&h vaJUlJble informolion is lost by not considering species abundances.

Respoue for use of bioassay test species: As mentioned in the introduction to this Response
Section 3, the bioassay test species were selected because they are residents of Puget Sound
and are relatively sensitive to chemical conrnmin~tion. Their use in assessing sediment
conrnminllnt impacts has been established in many studies in Puget Sound and elsewhere (PTI
and Tetra Tech 1988; Chapman et aI. 1985, 1987). Because they represent one of the most
se1JSitive ecosystem components, their evaluation is assumed to be protective of the larger
ecosystem. The use of bioassays as indicators for larger groups of organisms has a strong
historical precedent. Most of the EP A water quality criteria used to protect aquatic life in the
U.S. has been derived directly from water-column bioassays conducted on sensitive species.
Respoue for use of major taxa:. Although patterns based on species abundances were
analyzed and discussed in the remedial investigation, major taxa were selected as the indicators
of benthic effects for several reasons. First. abundances of major taxa generally exhibit less
variability than species abundances and therefore are more amenable to impact determinations
based on statistical criteria. Second, the use of major taxa avoids many of the uncertainties
associated with interpreting the causes and significance of subtle shifts in species abundances
at different locations. Finally. it was assumed that large reductions in the abundances of
species groups (i.e., those species pooled within each major taxon) would be more meaningful
ecologically than reductions in the abundances of single species. Although different species
may exhibit variable responses to different kinds of environmental pollution. several
investigators (Pearson and Rosenberg 1978; Rygg 1985. 1986) have suggested. that most taxa
will exhibit reductions in abundance in response to chemical conrnminlitioD. Use of major
taxa as an indicator should therefore reflect the patterns of abundance of most species.
3.2.2. Non-toxic effects can bias the biological indictllors used to assess toxic effects. For
e.'Cample. low dissolved oxygf!n may bias results of the bivalve larvae abnormality test and sediment
grain size may affect results of the amphipod mortality test.
Response for biyaive larne abnormality test: Low concentrations of dissolved oxygen (i.e..
<4 mg/L) were found in the test chambers for the bivalve larvae abnormality test for six
Stltions in Commencement Bay. Sever:1.l commenters suggested that the observed abnormalities
at these stations may have been due to the low levels of dissolved oxygen rather than to
chemical toxicity.
7:,e potential cc~founding ~ffects of low ,;oncentr.uions vf dissolved oxygen at the :)1:'( :>,:ltions
were discussed in the remedial investigation. Significant (P<0.05) values of abnormality were
:.ound at aU six stations. To be ~nvironmentlily protective. rhe significant abnormalities were
attributed to chemical toxicity. rather than low levels of dissolve<1 oxygen. The assumption
that chemical toxicity was largely responsible for the observed values of :lbnormaiity was
supported by results based on the other biological indicators lnd sediment chemic:lI
concentrations. Significant (P
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grain size may have confounded the results of the amphipod mortality tests and resulted in
erroneous impact designations.
The potential confounding effects of sediment grain size in the amphipod test was acknow-
ledged in the remedial investigation. However, the effects of grain size are highly unpredict-
able. In the reference-area database used by DeWitt et a1. (1988), monality ranged from 0 to
70 percent at values of percent fine-grained sediment greater than 70 percent. The
considerable scatter in the data resulted in a regression relationship that. while significant
(PO.05) in any
instance. These results suggest that the biological inaicatOrs used in the remedial invesrig:lCion
and AET database were in general agreement with respect to impact designations. but thar
~naicator-speciiic differences were also present. Therefore. the use of multiple indicators
resulted in genera! substantiation of adverse ~ffects in high priority areas while also ~nsuring
the detection of effects due to species-specific factors in contaminant sensitivity or exposure
route.
J.~.+. Use of suuisticai criteria lO Jeiine impacts may be inappropriate.
1esDonse: A ?rimary criterion in ;jelectin~ the biological indicatOrs 'Jsed in :he C3/ NT
remedial investigation and the AET database was ecological relevance. Benthic macro-
invertebrate assemblages were selected because they are a critical link in detrital-based
ecosystems for energy transfer to higher trophic levels (e.g.. larger invertebrates and fishes).
In addition, because these organisms are relatively stationary and live in close association with
bottom sedimeDts', th~ represent an ecos-y!tem '::uukv"neftt with one of ~ Itigh~t risks of
being affected by sediment contamination. It was therefore assumed that evaluations based
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on benthic macroinvertebrate assemblages would be protective of most of the remaining
ecosystem in the bay. .
Sediment bioassays were used in the remedial investigation and the AET database because they
allowed an evaluation of sediment toxicity under controlled laboratory conditions. To ensure
that the bioassays used in the remedial investigation and AET database were ecologically,
relevant, the test species were selected on the basis of their presence in Puget Sound and their
sensitivity to conrnminlltion. Both the amphipod Rh4poX}'1lius abronius (used in the amphipod
mortality test) and the Pacific oyster Crassostrea gigas (used in the bivalve larvae abnormality
test) are members of the Puget Sound ecosystem. In addition~ both are considered relatively
sensitive to chemical conrnminlltion and are therefore representative of the ecosystem
components most likely to be affected by sediment contamination. It was therefore assumed
that evaluations based on these bioassays would be protective of the larger ecosystem.
Statistical criteria were used in the biologic:aJ evaluations because they allowed explicit
hypotheses related to impacts to be tested in an objective manner, and with a known degree
of confidence. The use of statistical criteria removed much of the potential subjectivity
involved in determining whether a biologic:aJ effect was important. Although ecological
relevance was not addressed directly, it was considered indirectly by the choice of biological
indicators. In additio~ the mapitude of effects determined to be S18tistica1ly significant were
large enough to be considered ecologic:aJly important. For the tWO ".wti1lMDt bioassays~ effects
(i.e.~ amphipod mortality and oyster larvae abnormality) were generaJly found to be significant
when responses were found in more than 25 percent of the test orpnisms. For the benthic,
macroinvertebrate ana1yses~ effects were generaJly determined to be sip.ii1CaDt when organism'
abundances were less than half the values observed in reference areas. Therefore, the
statistical tests used in the remedial investigation did not result in the detection of very small
changes in toxicity or benthic abundance:
Impact designations and biological test procedures described in the Record of Decision will
continue to be adjusted in accordance with changes in Puget Sound Estuary Program protocols.
These changes may result in I) changes in the AET database, 2) changes in test evaluation
procedures, or 3) replacement of any of the three biologic:aJ indicators by more appropriate
testS, as described in Section 8.2.5 of the Record of Decision.
3.3. Comments Related to Cleanup Goal for Environmental Protection
3.3.1 The cleanup goal of "no acute or chronic adverse effects on biological resources" represents
pristine conditions in an area that is an active port. For the remedial action evaluation criteria. the
apparent goal of converting the waterways to the conditions 0/ unindustriali=ed deep aquatic
-!!!Vmmments is inconsistelll wuh their origillal cOl/ditioll as mudflats al/d the realit.v of lireir C:.4rrelll
:J.se ;,y industry. All achievable and sustaillable sedimem cleal/up objective alld standard inouiJ he
~sla.hi ished he fore Impler.nemilll( seciimelll remediatioll.
~espODse:' The goal or" the CB/NT project is not to restore (he environment ,hat preaated
man's arrival in Commencement Bay. The goal ot" the project is to ensure chat che
environment is not acutely toxic to organisms that would ordinarily inhabit it and does not
pose significant human health risks. as mandated by Superfund regulations and allows for the
continuation 01 the native American fishery as mandated by treaty. The cleanup goal
~epresentS conditions chat currently exist in urban :md non urban lreas vf Puget Sound
(includin~ parts of the CB/NT site). not pristine conditions. As stated in the Record of
Decision (see Section 7), ,he lon~-lerm deanup vbjectlve representS .;hemic:l1 ..;oncentrations
,hat :lre weH above ret'erence lrea concentrations. Moreover. che reference .;onditions used
to discriminate adverse biological effectS for the remedial investigation and AET database
were not based on pristine conditions.
The reference areas' used (ar ~imeDt bioassaY5 have included nonurban embayments sw;h u
Carr Inlet. Port Susan, and Sequim Bay.' Although these embaymentS are not influenced by
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major sources of chemical contaminatio~ none of them can be considered pristine because of
other local human impacts and indirect contamination at low levels via air and water
circulation throughout Puget Sound. The closest approximation to pristine conditions used for
the sediment bioassays are the sediment samples from West Beach on Whidbey Island and clean
seawater that are used as negative controls for the bioassay testin.. Because these controls are
only used to determine the acceptability of bioassay results, they do not dlrect1y. influence the
determinations of cleanup objectives.
The reference areas used to evaluate adverse effects on benthic macroinvertebrates have
included Blair Waterway (in Commencement Bay), Blakely Harbor, Carr Inlet, Port Susan, and
central Puget Sound off Seahurst in West Seattle. As with the bioassay reference areas, none
of the reference areas used to determine benthic effectS can be considered pristine. This is
particularly true for Blair Waterway, which was used as a ime-grained reference area for
stations in other Commencement Bay waterways as part of the remedial investigation.
3.3.2. There is no adeqUllle assessment of chronic effects in the A.Er values used in the feasibility
study for assessing environmental risk.
Respoue: Reliance on acute responses (i.e., acute toxicity bioassays) to generate sediment
quality values may not be protective of aU chronic health imI)8CtS to aquatic organisms.
Although AETs could be developed based on results of chronic: laboratory tests, standardized
tests to assess chronic adverse effects associated with sediment con~mination were not
available for the feasibility study. By necessity, AETs were developed using available\
biological indicators, and the sediment quality objective for the CB/NT site recognizes this
practical limitation. The generation of AET values based on a variety of sublethal and lethal
biological indicators does, however, address many complex biological-chemical interrelation-
ships. The various biological tests used to generate AET values use sensitive species and are
therefore representative of ecosystem componentS that are most likely to be affected by
sediment contamination. These indicators include benthic infauna analysis that incorporates
a measure of both in situ chronic: and acute effectS. These effecu couJd include, for example,
chronic toxicity to aU life stages, behavioral changes, reproductive alterations, tumor
inductions, and altered predator-prey relationships. For the CB/NT site, a significant response
according to anyone of the three acute biological indicators will be used as a criterion for
presumptive harm during the cleanup phase because not all possible biological effectS have
been me:1Sured.
In addition to toxicity from me:1Sured contaminantS, the AET approach also incorporates the
net effectS of the fOllowing factors that may also be import:lnt in field-collected sediments:
.
Internctive effectS of chemicals (e.g.. synergism. .anugonism. and additivity)
U nme:1Sured chemicals :lnd other unme:1Sured. potentially adverse variables
.
31
y(:mix effectS and bioavaiiability (Le.. phase associations betWeen contaminams Jnd
sedimentS that affect bioavailability of the contaminants. such as the incorporation
of pOlycyclic aromatic hydroc:ubons (PAH) in soot particles I.
The AET approach c:mnot distinguish and Quantify the individual contributions of interactive
effects. unmeasured chemicals. or matrix effectS in environmental samples. but AET values
may be influenced by these factors. Only laborntory-spiked sediment bioassays offer 1
::iystematic and reliable method for identifying lnd quantifying chese complex interactions.
A great deal of research effort would be required to test the ran~e of chemicals potentially
)ccurrmg :n ~he environment I both individually lnd in .;ombination I. 1 sufficientlv .viae
range of organisms. and a wide range of sediment matrices to e5cblish definitive criteria. The
AET approach has an advantage over single chemical spiking studies because it incorporates
the influence of these factors in the generation of AET values from field data.
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. .
4. THE APPARENT EFFEcrs THRESHOLD APPROACH
Although the sediment quality objectives for the CB/NT site are defined according to three
biological indicators and human health risk assessments, AET values developed for Puget Sound
have been used as the primary technical basis for establishing chemical-specific sediment cleanup
objectives relative to environmental protection at the CB/NT site. Three major kinds of comments
with respect to use of the AET approach were received. . They include questions concerning I) the
conceptual basis of the AET approach. 2) appropriate generation of AET values. and 3) appropriate
regulatory applications of AETs in making cleanup decisions. Major issues related to these
comments are addressed in this section.
The AET approach was supported as the best method available at the present time to identify
sediments requiring remedial action or to estimate chemical concentrations associated with harm to
marine life by Eco108Y. Washin8toD Department of Natural Resources, PSWQA. the Commence-
ment Bay Citizens Advisory Committee, the Sierra Club, and the NOAA Oceans Assessment
Division. Various concerns over conceptual aspects of this approach were advanced by the
Commencement Bay Group, the city of Tacoma, Foss Maritime, Kaiser Aluminum and Chemical
Corporation. Manke Lumber Company, Pennwait Chemical Corporation, and the Washington
Department of Natural Resources. The Commencement Bay Group also proposed ecologically
significant benthic effectS AET be used as an alternative guideline for sediment assessment.

It was noted that site-specific biological data used to generate AET values were not available
at every station sampled at the CB/NT site. Superior Oil Co. requested confirmation of chemical
predictions prior to determining the need for sediment remediation. Regulatory issues raised by
the city of Tacoma. Martinac Shipbuilding, Port of Tacoma. and "Tacoma-Pierce County Chamber
of Commerce included questions on the relationship of AET values used in the CB/NT feasibility
study to proposed state sediment standards and whether AETs were being used to enablish a goal
of pristine conditions in Commencement Bay (this latter comment has been addressed in
Section 3.3). .
4.1 Comments OD Conceptual Basis 01 the AET Approach
4.1.1. The AET approtXh does not provide an appropriate cleanup standard because AET values are
strictly predictions of correlations. and fail to prove cause-effect relationships between contaminallls
and biological responses.
Response: This concern applies in practice to all sediment quality values available because
none (including spiked sediment bioassays) can provide proof of cause-and-effect under
actual field conditions. Research to assess the correspondence of AETs to toxicological studies
has been recommended and is underway to a limited extent. However. -::luse-effect proof of
harm is Clot required under Superfund to be included in the decision-making process lC the
r1:ltional priority list sites. [n the interest .)(. protecting human health lnd .he ~nvironment.
Superfund law :1Od guidance requires timely decisions lnd lctions based on the best
:nt"ormation available. Therefore. the potemial for :ldverse bioiogical :lnd human i1eaith
effects is sufficient to pursue regulatory lctions :It the CB/NT site. Proposed :lctions ~tiiize
a preponderance of evidence of the association of chemical contamination and adverse
biolo~ical effects in assessing cleanup levels. The problem chemicals idemified bv (he AET
lpproach at a panicular problem area represent a best effort (0 discern between' measured
':hemicals that do ClOt appear to be associ:lted with adverse biological effects :1Od those that \.l0.
rn :lddition. because 111 potential contaminants cannot be measured routinely. de:mup strategies
:nUSt :.Iso .ely ~o some ~xtent \)n the ie~ui:ltion ::md mana~ement of ";urrogate" .:nemicals. :r.
for example. an unmeasured chemical (or group of chemicals) vanes consistently in :he
environment with a measured chemical, then the AETs established for the measured
contaminant will indirectly apply to, or result in the management of, the unmeasured
contaminant. In such cases, a measured contaminant would act as a surrogate for an
unmeasured CODt!tmi~nt (or group of unme:uured COQt:uninantS).
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The correlative evidence of the AET approach in Puget Sound is based in part on field data
on chemical cont::l.min:ttion in CB/NT areas that evidence adverse biological effects by multiple
indicators. The chemical contamination in many of these areas has been associated with
particular sources both by chemical composition and by spatial distributions. This
preponderance of chemical and biological evidence is judged to be sufficient in high priority
areas considered in the feasibility study. Because strict cause-effect relationships are not
proved., the AET approach is used as.only one tool that guides the overall decision-making
process. This protective assumption can be confirmed by optional site-specific biological
testing in the remedial design phase.
4.2 Comments oa the Applkation of the AET Approach tor Decision-Making
4.2.1. The AET approach is used to establish cleanup goals solely on the basis of predictive
capabilities. Confir7fUllion of results is necessary before proceeding with eleQllup. The approach
should be used as a guideline ralher thlJ1f a strict stQlldard.
Respoase: CB/NT !lNtimeut quality objectives are def'med ac:ording to biological test results.
The AET database is used only as a tool for predicting levels of chemical conrnminal1ts above
whicl\ adverse effects would be measured using those tests. However, confirmation of
chemical predictions using biological testing has been established as an option during the
remedial design phase. The results of such site-specific testing would outweigh the AET
prediction of biological effects and therefore determine the final action to be takeu..
Therefore, the AET approach is not being used as a strict standard for required sediment
cleanup, only to provide a basis for estimating potential cleanup volumes of sediment. This
application of biological testing and the AET database is similar to that used in other Puget
Sound programs such as PSDDA, the Puget Sound Estuary Program, and emerging state
standards and regulations.
4.2.2. Use of A-ETs is particularly questionable in intertidal areas.
Respoase: The different contaminated matrices to which AETs have been applied in the
subtidal environment represent a broader range in matrix type, and associated variations in
bioavailability. than do differences between subtidal and intertidal environments. Based on
this consideration and preliminary reliability resultS for testS involving AET application to
intertidal sedimentS, existing AET values have been recommended for use in identifying
potential problem areas at intertidal stations in Puget Sound (Becker et aJ. 1989). Ongoing
review of any additional verification data is also recommended. The sediment quality
objective at the CB/NT site is based on biological test resultS that have been interpreted
relative to conditions at suitable reference stations" Until further data can be evaluated. it
may be appropriate for final remedial action decision~ to rely on site-specific resting rath~r
than the AET predictions in intertidal :lre:lS of the CB/NT site.
~.3.
CommenlS Related to ChemicaJ-Specific AET Vajues
4.3.1. In generating AET values. all effects are attribwed to single chemicals aithoulfh Other /aJ:wrs
couid be reievQllt: water depth. turbuience. saiinity, sediment texture can a/fect bemhic abundance
/ and sometimes tOxicity J and are IlOt adequately addressed.
Response: The AET aoproach attempts to distin~uish patterns of natural variabilitv t"rom
.hose iOdic:lt1n~ (oxic ;mo:lctS by statistically.:omparin~ sample responses m reference ;Jemhic
samples that have slmiiar grain size distributIons ana :lre ~oUected :u similar water l1epthS.
This statistical comparison reduces the potential for habitat-related factors [0 confound the
resultS or mask apparent relationships. The relationships observed between certain chemicals
and benthic effects cannot be explained solely by habitat. In cases where potentially
anomalous habitat variations and sediment toxicity could contribute to the statistical
differences noted, the condition was protectively defined as an adverse biological impact..
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This protective assumption can be confinned by optional site-specific biological testing in the
remedial design phase.
4.3.2. AETs fail to qumrlify the e:ctenl 01 adverse effects. . . The AEf derivation process treats all
statistically sigYlificanl clumges as equally adverse. without regard to their nature. magnitude. or
ecological importance. . .
Respoase: AET values are designed to predict adverse effeca that can be statistically
distinguished from reference conditions. This magnitude of adverse effect is consistent with
the need to address feasibly a Jong-term cleanup goal of no adverse effects. The magnitude
of effect above this threshold is not directly taken intO account in a single AET value but the
range of AET values from lowest AET to highest AET for a range of biological indicators
. does provide a preponderance of evidence of different Idnds of adverse effects. Of the 201
benthic wanna stations and 287 amphipod bioassay stations e~uated for 13 Puget Sound
embayments with the AET approach (including Commencement Bay), approximately 85
percent (174 stations and 243 stations, respectively) are in accordance with the predictions of
the 1988 AET values for these indicatOrs (i.e., they do not" exhibit adverse effects at chemical
concentrations less than the AET values, and do exhibit adverse effects at chemical
concentrations above the AU values) (U.s. EPA 1988). The reliability of AET values for the
oysUlr larvae indicuor was even higher, but only daIa for Commencement Bay were available
for analysis. Therefore, the analysis correctly identifies impacted stations using several kinds
of bioassessment techniques that employ different endpoina. These biological tests use
sensitive species and are therefore representative of ecosystem components that are most like!}'
to be affected by sediment contamination (see additional discussion in response to Comments
3.2.1 and 3.3.2). Sediment quality values that would focus only on severe adverse effects, or
would otherwise be influenced by the magnitude of adverse effect that exceeded reference
conditions would be less sensitive in identifying many of these measurable impactS than the
AET values used at the CB/NT site.
4.4. COlllllleDts OD the Establishment of AET Values (or the CB/NT Site
4.4.1. Operationally, the AET is a concentration at which no effect occurred. not the concentration
above which effeclS are always expected. Define AET as the contamillanl concentration above which
effects were always observed in the data set for which AET was derived. .
Response: This precise definition is appropriate in order to be environmentllly protective and
has been incorporated.
4.4.2. [TJhe goal for the cleanup [shouldJ be defined based on what is Ilecessary to protect human
health and {he environmem from sigJlificallt adverse impacts. . . cLeaJlup should unLy be required ill
areas ..vhere all ecologically significallt (1101 staIistically sit:Jlificallt) bellefit (.'WI he shulV1I.
Response: ENSR f 1989) proposed a variation of the sediment quality goal by derining Jn
~cologicaHy significant benthic effects AfT. This measure was defined JS the occurrence or"
significant benthic infaunal depressions in more than one major taxonomic group ~ i.e.. two 'Jr
more depressions .among Mollusca. Crustacea. and POlychaem). The agencies had considered
a similar measure during the development of approaches to sediment quality values. which '.vas
termed the "severe effectS benthic AET." and was- defined :JS the sediment concentration above
which statisticaUy significant benthic infaunal depressions occurred in more chan one major
taxonomic group (i.e,. two or more depressions Jmong Mollusca. Crustacea. Jnd Polychaet:l)
(PTI 1989). This measure,. Jnd :he ENSR i 1989) measure were not considered m be :ldequJteiv
protective for mitigating environmental risk at the CB/NT site..
4.4.3. AET values should be adjusted to illclude safety factors for unmeasured chronic effects.
Respoue: Inc:orporatioD of mery f~ to :rdjatt AET vatDeS' dOwnwinti W3$ ~valaated
(Tetra Tech 1986). The use of a safety factor of 10 :JS representative of an acute-to-chronic
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ratio (EPA198S) recommended in water Quality criteria guidance has also been evaluated (PT!
1989). In both cases, the number of correctly predicted stations exhibiting adverse biological
, effectS increased slightly. However, there were a number of stations that did not exhibit
significant adverse biological effectS but were predicted to have adverse effectS by AET that
iDcorpcmUed . safety factor. These stations may have exhibited chronic effect! that were not
measured. However, the evaluation suggested that incorporation of safety. factors would
reduce the ability to discern measurable effec13 from reference conditions and therefore safety
factors were not recommended in the feasibility study or selected in the Record of Decision.

4.4.4. Larg~ dQta se(s are r~quir~d to establisJr AU ,alues and no minimum requirements lor an
acceptable dQta s~t lor deriving .4ET have been established. T1r8 1UI1IIber and distribution 01 effect
stQtions and th~ size and distribution 01 the total data set should be considered in interpreting
uncertainties with AETs.
Respoase: Minimum requirements for deriving Arts were addressed by recommendations set
forth during the reilDement of AET values through incorporation of data from multiple Puget
Sound studies (Barrick et a1. 1988). This expanded database of approximately 330 stations
from 13 embayments of Puget Sound (including Commencement Bay) was used to establish
AET values that were used during the CB/NT feasibility study. It was recommended that at
least 30 and preferably 50 stations be used to establish AET. However, a small number of
staticas that is representative of the range of chemic:al coacentrations and biological responses
in a regioD may be as or more effective in establishing reliable AET values as using a large
database that is not representative of environmental conditions.
The effect of .weight of evidence. for different AET values based on the size and disttibution
of the total data set is one means of assessing uncertainty. Unquestionably, there is less
uncertainty for an AET based on many observations than for an AET based on few
observations. This is the reason that revised AETs based on a larger database than available
during the remedial investigation, and with wide-ranging chemical concentrations, were
incorporated into the feasibility study. Uncertainty ranges for AETs defined as the
concentration range from tWo or three non-impacted stations below the AETs to one
biologically impacted station above the AET have been evaluated based on statistical
classification arguments (Tetra Tech 1986). The number of stations used to establish an AET
(i.e., weight of evidence) could have a marked effect on this uncertainty range, because small
data sets would tend to have less continuous distributions of chemical concentrations than large
data sets. That is, small data sets would tend to have larger concentration gaps between
stations (and correspondingly wider uncertainty ranges for AET) than larger data setS.
4.5.
Comments on the Relationship of AET to Human Henlth
.J,5.1. AET cannot address human health fisk because {he,v do not aCCOWll for bioavailaoili!.\' v.i
.o;cu.:ams ill situ and aO./lt establish causality. ,-iET call/wt cJ.daress r,wavaiiaOllit.l' o.{ d:emlcais ill
situ t' ailhoul(h other commencers recommended (hal AET values for h.varophobic orgallic cnemicals
.;e normalized to organic carnon concent to cJ.fidress bioavailaDiiit,v).
Res'poase: AETs are not used as the sole basis for addressing human health risk in [he
feasibility study. A PCB bioaccumulation AET was assessed during the feasibility study but'
was not used JS [he sale method. for selecting areas for remediation because of uncertainties
in ics derivation. The cleanup of sediment [0 reduce [he risks [0 human health ;'rom ,he
consumption of edible fish tissue was addressed using eQuilibrium partitioning princioles.
A£T lio address oioavaiiabiijrv of ~hemicais in sediments because ......£T values :lre esrablishea
based on observed biological effeccs in field samples. AET normalized [0 [he organic carbon
content of sediment, presumed to be a major factor controlling the bioavailability of
contaminantS, have also been generated. The reliability of organic carbon-normalized AET
values in correctly identifying adverse biological effectS is approximately the same as that of
dry-weight norm::a1i7pd AET values (U.s.. EPA 19&&). Dry-weight norma1ized AET values
were used in assessing cleanup volumes of sediment because there was no direct evidence of
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"an improvement in the ability to correctly predict adverse biological effects using organic-
carbon normalized AET, and dry-weight normalized AET require less manipulation for
application by regulators and potentially responsible parties (i.e., can be directly compared to
chemical concentration data routinely reported by laboratories).
S. SOURCE LOADING ESTIMATES
Source identification and characterization (Le., loading estimates) were performed based on
historical data and data generated by sampling and monitoring during the remedial investigation/
feasibility study process. These data were used for deilning source control priorities and strategies.
Most of the comments received on source identification and loading were criticisms that
identification and loading estimates were incorrect or inadequate and based on incorrect or
insufficient data. and that loading estimates were incorrectly calculated. In addition, several
commenters stated that source characterization and identification was strongly biased toward sources
for which there are data available (Le., other potentially significant sources such as nonpoint
sources may be important but are poorly characterized). The majority of the commentS received
were from the Commencement Bay Group (including many major PRPs).
gim~n Tacoma Knit. Washington Department or Transportation, Louisiana-Pacific, Kaiser
Aluminum. General Metals, and ASARCO all commented that source data relating to their facilities
and OpenCoDS are outdated or inadequate for decision-making. Grifnn Galbraith, Foss Maritime,
General Metals, Dunlap Towinl, and USG stated that nonpoint sources are inadequately
characterized and may contribute significantly to contamination. Louisiana-Pacific stated that
loadinl data are not properly calculated. The Puyallup Tribe of Indians commented that the
feasibility ~tudy should present a detailed stormwater control plan.
5.1. Comments on Identification of Present and Historic:a1 Sources
5.1.1. CJuzrt1l:terization 01 PCB lood;", ;s inadequDle to idenlily sources or support remedial action.

Respoase: PCB source identification was noted to be incomplete in the CB/NT remedial
investigation/feasibility study and the integrated action plan. Additional source identification
and monitoring activities are being conducted by Ecology t as described in the Record of
Decision. The implementation section of this Record of Decision emphasizes that the
acceptabilitY of source identification and conuol will be reevaluated before sediment remedial
actions are required.
5.1.2, Existing or historical contamiltant loading" is inadequately characteri =ed.
Response: The loading dat3 limitations were stated in the remedial investig:lrion Jnd
te:lSibility study: Because of these limirations. source identification was Jlso b:lSed on known
use of problem chemicals. documented historical and ongoing disposal practices. and proximity
'Ji :::ediment contamination [0 suspected source. [n" Jddition. source loading data were rlOt used
to determine the need for or effectiveness of source con~ols. or to develop sediment recovery
scenarios, or to allocate responsibility among PRPs.
An Jccurate characterization of historical loading of contaminants was not possible because
few studies were conducted in [he past. Jnd [hose studies that were conducted Jid nOt
generaHy address contaminants of concern. Where possible. sediment core profiles were
: nceroreted to determine if ;oadin~ has increased (characterized.!)V 1 i1road surt"ace jedimenr
maxima) or decre:lSed (characterized by J sure'ace sediment minima).
Loading data limitations, noted early in the study t triggered a number source characterization
studies. However, not all discharges are given equal weight in terms of focusing additional
source identification :met ~()lIhut activities. or conducting MOnitorin8 studies. For example.
it is not considered cost-effective to monitor drains that serve small are:lS where historical or
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ongoing activities within the drainage basin are unlikely sources of problem chemicals.
Similarly, it is inappropriate to sample all discharges to a waterway' if there is compelling
evidence indicating a probable source or sources.
5.1J. How will MW inlormtllion on sources be incorporazed into the decision-making process?
Respoue: New data collected from ongoing or future monitoring' programs will be
incorporated as they become available. After signature of the Record of Decision, Ecology
will continue to identify CB/NT sources, select appropriate source control measures, and
enforce those measures. Several factors will be consid.ered in this evaluation including the
possibility of unidentified major sources within the problem area, the status of source cona-ol
for known major sources, and the possible cumulative effects from other CD/NT sources.
New information on previously unidentified sources and contaminants will be evaluated by
EPA during th& remedial design phase and integrated into the remedial design sampling and
analysis strategy for each problem area. .
5.2. CollUllellts oa Adequacy of Nonpoint Sources Relative to Point Sources
5.2.1. Th~r~ i.s i1UldeqrMll~ cOlUiderazion 01 non-poilU sources 01 pollution, including the potential
impact 01 r~ctmtami1UZlion Irom continuing source.s.
Respogse: This comment refers to nonpoint source conmmination that is generally discharged
to Commencement Day via storm drains. Storm drains are included as potential sources to
Commencement Bay and can be regulated as point sources, although they may represent
contributions from nonpoint sources of contamination. However, not all storm drains are
given equal weight as potential problem sources (see Response 5.1.2). The factor that street
dust exceeds target cleanup levels does not indicate that urban runoff is a major source of
contamination to Commencement Bay. To determine the impact of street dust (or similar
material contributed by runofO on the marine environment, several factors are considered;
1) the types of contaminants present in the street dust, 2) processes influencing the fate and .
transport of conmminantS in street dust on the way to the marine environment, 3) the rate at .
which street dust (or related contaminants) are supplied to the marine environment relative to
other sources of the same contaminants, and 4) the ability of the receiving environment to
assimilate (or dilute and disperse) the total contaminant load. Ecology is responsible for
evaluating these factors and developing permitS for storm drains under the Clean Water Act
and the PSWQA plan. New information from other studies regarding airborne emissions and
other nonpoint sources that are not incorporated into storm drain permits will also be
evaluated by the Jppropriate federal, state, or local agency.
5.2.2. A storm drailt comrol plait should he developed before che Record vf Decision is ;"inali=ed.
Wichour a remedial investigaliollj feasibiliry srudy al/d a Record vf DeCISimt for source cOlllroi.
poceJlllaiiy responsible parlles call1tot obtailt CERCLA resoiulimr 01 Superful/a [iaoiiity.
:lesPODse: For problem areas where storm drains have been identified as a significant ongoing
source. storm drain control pjans must be impjemented before sediment remediaj action ..;an
proceed. A detailed storm drain control plan can be considered an ejement of remedial design.
Jnd does not need to be finalized before the Record of Decision;
5.3. Comments on Loadin~ Calculations
5.J. ,,'. Loati ing calcuiallons are //tcorreCl aI/a slallsricaii.v iI/valid.
Response: Loading calculations were conducted by averaging available concentration data and
flow data, and multiplying the two averages to arrive at the loading rate. The correct
procedure is to first multiply' data pai~, and' men rime :rverage data pairs. ~ former
procedure was applied to CB/NT data because synoptic data for concentration and flow were
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often not available. This simplified procedure introduces a great deal of uncertainty into the
loading estimate for sources that display a great deal of temporal variability. As noted earlier
(Comment 1), limitations in the loading data were clearly noted in the remedial investigation;
feasibility study. Source loading estimates will be refined during source monitoring, and the
relationship of source loading to sediment accumulation will be examined in greater detail
during sediment remedial design sampling.

It was noted that by not using undetected values for chemical measurementS, loading
calculations result in overestimates of the discharge load. This is only correct if I) detection
limitS for chemicals are well below measured values, and 2) loading values from paired data
that are based on detection limit values are less than loading values based on detected values.
(It is assumed that paired flow and concentration data are first combined to estimate loading
for discrete pointS in time; the correct technique described above.)
It was argued that loading data are statistically invalid because the EPA Test Method for
evaluating solid waste, SW-846, suggests that the variance of the test data should be less than
the average mean concentration. This guideline. while appropriate for solid waste, may not
be appropriate for storm drain sampling programs where extreme amountS of data would
have to be collected to characteri%e the highly variable flow and loading conditions. However,
EPA and the state encourage the collection of comprehensive loading data where resources
permit.
5.3.2. There are problems with the source loading database. especially at concentrations below ERA
method detection limits. .
RespODse: Data reported at levels below EPA method detection limitS mayor may not be
incorrect. Modified analytical techniques are sometimes used to Quantify below these limits
based on specific project requirementS. Such modifications are typically documented in
sampling and analysis plans and Quality assurance project plans. However, in some cases,
particularly. with older data sets, false positive values are of concern. In these cases. source
loading data should not and will not be used a the sole basis for identifying a potential source.
Rather, chemical usage and dis'posal practices will be evaluated.
6. SOURCE CONTROL
Source control and sediment remediation are two key components of site cleanup. Source
control is important for preventing ongoing degradation, ~nabling natural recovery, and preventing
recontamination of remediated areas. Comments received on source control t'ocused on three
themes: the emphasis placed on source control. the feasibility and effectiveness of source control.
Jnd source loading estimates.
TPCHD. the Washington Department ,)f :'\!atUral R.~sources. Jnd P'Jger Sound ?~y,,\"J0J
:ornmented that the feasibility study should place more emphasis on source control ::md .the PSWQA
;tated that .he integrated action pian shouid :lddress spills ~:nd spill prevention. The T::lcoma- ;>ierce
County Chamber of Commerce ~xpressed ~oncern over the tOact that :1reas outSide the CD/NT site
Jre not :1ddressed and should be monitored by EPA and Ecology. The Puyallup Tribe of Indians
;tated that source control should be implemented immediately Jnd ..:onsiders ~he r'easibiiity stUd\'
: nadeQuate to ::lssess source ;;ontrol needs.
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6.1. Comments OD the Appropriateness of Source Control

6.1.1. A systematic look at all sources. their contribulion. degree of ~hieyable control. and priority
for comrol. should be defined. The framework for $uch a plan should be established prior to lhe
Record 01 Decisiorr.
Respoase: Source control is considered a key element of the site remedy; source control
efforts to be conducted by the Commencement Bay UBA T has been enhanced through a
Cooperative Agreement betWeen EPA and Ecology. Control of major sources of problem
chemicals to a level that uti1.i.zes all known available and reasonable methods of technologies
(AKARTs) is required before sediment remedial action is scheduled to proceed. Source
control at the CB/NT site is a complex process because of the large variety of sources, the
various status of sources (i.e., historical, ongoing. increasing, decreasing), and the changing
institutional structure of environmental standards and requirementS. Consequently, source
control is addressed through a variety of programs that are either being implemented by
Ecology or coordinated with Ecology's Commencement Bay UBA T to ensure consistency with
the objectives of the CB/NT project. These programs are described in greater detail in
Section 3 of the Decision Sllmmllry and in the integrated action plan (PTI 1988) of the CB/NT
feasibility study.
The feasibility study focused on sediment remedial action but source control was also
integrated into the overall process. General response actions for various types of source
control were described. feasible levels of source control were estimated. and enhanc~
regulation and control of significant sources was described as a key element of all CB/NT
remedial alternatives, except the No Action alternative. More specific information regarding
the status and nature of major sources in each CB/NT problem area was also described. The
integrated action plan was developed as a framework for scheduling and planning both source
control and sediment remedial action at the CB/NT site. The timetables outlined in the
integrated action plan are intended to be updated on a regular basis to reflect changes as
. ovenUJ project implementation proceeds. Details of source control strategies, including
specific remedial technologies. are available in the various individual facility or source studies.
In general, such cOntrols require AKARTs to all point sources and rigorous application of best
management practices to nonpoint sources.
6.2. Comments on Remedial Technologies for Source Control
6.2.1. The feasibility study proposes infeasible end-of-pipe source cOlllrol measures.
. delailed COSl evaluation for individual source control measures should be presented.
A more
Response: Source control estimates Jre based on existing compliance Jnd inspection schedules
as well as the best professional judgement of Ecology experts responsible for implemenr:uion
of 30urce control.' and as such Jre adequate for planning purposes Jnq prioritiz:uion ()(. bo[h
30urces and sediment remedial action planning. The agencies recognize [hat 1) source control
measures must be evaluated more closety on a property-specific basis. 2) comoliance $che
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determination will be made by Ecology and EPA. There may be facilities which, after
implementation of AKART, continue to discharge contaminantS at levels that will exceed
sediment cleanup objectives in the vicinity of the source. For these facilities, a waiver will
be incorporated into applicable permits to allow a temporary sediment impact zone with
specified requirements for monitoring and closure.
6.4. CollUllellts on Appropriateness 01 Feasibility Estimates for Soun:e Control
6.4.1. TM l~tUibility .study 0'e'~sti1fflJt~d 1M letUibility and effectiveness 01 source conlrol
measur~s.
Respoue: The percentage reductions estimated to be feasible were intended to be extremely
rough estimates (see re5.,oases in Sec:tiOD 5.3). Most assumptions are conservative. For
example, the reduction in HPAH release already attained by Kaiser Aluminum probably
represents greater than the 90 percent reduction (relative to an assumed steady state with
existing surface cont2minauon) that was estimated to be feasible in the feasibility study.
However, the effectiveness of source controls will be reevaluated during source monitoring
and remedial design. For some waterways, conservative estimates of the rate of natural
recovery provided in the fcmibility study will be adjUSted with new data and will likely have
the effect of decreasing the areas or sediment volumes that will require remedial action.
6.4.2. Sourc~ comrol eSli1fflJtes in lh~ lelUibi/ilY sludy Q1'~' blUed on l~chnicaJ/y unsupportab(e
tUnmtptiolU.
Response: The source control estimates developed during the feasibility study cannot be
considered guidelines for source control.. These estimates were developed to estimate the
relative importance of source control and natural recovery, and to estimate the cost benefitS
associated with the consideration of natural recovery. It was necessary to use this extremely
simplistic approach to estimating source control because source loading data we~ inadequate
(see responses in Section 5.3). Specific requirements for source control, including the
relationship of source loading to sediment accumulation and the role of sediment impact zones,'
are currently being developed by Ecology, and will be in place before sediment remedial
action takes place.
6.5. Comments on the Status of Source Control
6.5.1. Recent activities and loading daJa indicaJe thaJ many sources are controlled.
Response: (t is recognized that source controls have been implemented and that their succ~ss
has been documented at several facilities. This will be confirmed on the basis of )ourc~
!oading :maJyses c0nducted before sediment remedial design.
7.
NATURAL RECOVERY AND THE SEDIMENT CONTAMINANT ASSESSMENT MODEL
The Sediment Contaminant Assessment Model (SEDCAM) was developed and applied to CBI
NT problem areas to describe the relationship between source loading :md sediment accumulation
01 problem chemicaJs. and to estimate the relative importance or" natUraj recoverv. Comments on
SEDCAM related primarily to the modej's simolifyin~ :lSSumptions and itS lack of "field verific:1tion.
-:'"he Puyallup Tribe of Indians commented ,hat SEDCAM will overestimate recovery r:ltes ~eC:luse
assumptions about source con trot. However. most commenters (primarily PRPs) stated that
SEDCAM would underestimate recovery. Louisiana-Pacific, Port of Tacoma, and NOAA expressed
concern over model uncertainty, the limitations to the use of the model because of inherent
assumptions, and the lack of field verification. .
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.
1.1. Comments on the Protectiveness of Natural Recovery
7.1.1. Nalurai reco'H!ry is de Ia&to in situ capping. bul in situ capping was rejected as an aiternalive
in ail walerways ball St. Paul becaJI.Se o/the high li/ulihood thal the sediments in ail 01 the' other
waterways would". dredged lor mDilUnuznu or new corcslructioll.

Respoue: [II situ capping was not rejected; in fact. the selected alternative identified in the
Record of Decision broadly defines sediment confinement to include ill situ capping. In
natural recovery areas that may require maintenance dredging. the dredging and dredged
materjal disposal would be regulated by Clean Water Act Sections 40 I and 404 (Le.. the state
water quality certification process). Washington Department of Fisheries and Washington
Department of Wildlife (hydraulics permits). Washington Department of Natural Resources
(aquatic d.is1'QS3l site permits), city of Tacoma (shoreline substantial development permits), and
PSDDA (procedures and guidelines for dredged material and disposal site testing). Routine
navigational dredging actions must meet an substantive and procedural requirements of these
permit and certification programs.
7.1.2. The proposed natwal recovery is simply a slow /omr 0/ dilulioll. The StlJ'fU! result. without
the delay and uncertailUy 0/ recovery. would occur by allowing in situ capping.
Respoase: In marginally cont!lminqted areas. natural accumulation of cleaner sediment that
would result in recovery over a reasonable time period was preferred to the potential adverse
impacts of sediment confinement operations (e.g., burial of existing benthic communities).
Natural recovery increases the feasibility of sediment remedial action by enabling resources
to be focused on more highly contaminated areas, and by reducing overall costs.
7.1.3. Natwal recovery should be. the pre/erred aiternative except in cases where it plainly will not
protect human health and the environmellt in the long term.
Respoase: Natural recovery has been determined by EP A and Ecology to be appropriate in
marginally contaminated areas, because recovery can occur in a reasonable time period
following source control. In more heavily cont!lminated areas. the predicted persistence of
significant adverse impacts over long periods of time outWeighs the potential short-term
impacts from active remediation; therefore, sediment remediation is warranted ~n order to be
adequately protective of human health and the environment. .
1.2. Comments on Modeling Predictions Using SEDCAM
7.2.1. Simplifying assumptions limit the wility of the model.
Response: The simplicity of the model. :md the additional simplifying :LSsumptions chat were
incorporated into its applic:ltion reflect che data limitations noted ~::lrlier (or source loading.
Sedimentation rate. depth of the mixed layer, and chemical-specific degradation (or loss I r:ltes
,'simulated as a first order process) are a150 pooriy known. Further refinements ootn cO [he
mode! formulation (e.g., simulation of sediment mixing with an eddy diffusion coefficient.
inclusion of enhanced exchange with overlying water during sediment resuspension.
t'ormulation of J time-variable input function, :uld to itS :lpplication (e.g.. use of recently
';oUected loading data that had undergone comprehensive data validation) will ,)ccur juring
source monitoring and sediment remedial design.
-..2.':'. Too man.v conSerVQllve assumptions are II1ciuaeci ilr ,ire aopiicazwn 0.,. SEDC..HI.
Response: In the absence of adequate da~ conservative assumptions were applied. It should
be noted that the assumption of a 10-~m thick mixed layer translates to a comparatively
nonprotective (Le., Qon-~onservative) cap thickness. That is, surface sediments that undergo
natural recovery are considered to ha~ attained ~ long term objective wben chemic31
concentrations in the mixed layer (upper 10-em) meet long-term objectives: however,
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sediments that are not predicted to undergo sufficient recovery in a reasonable time frame are
subject to burial with a 3- to 6-foot layer of clean sediments.
7.2.3. Insulficimt and unreliable model input data from Commencement Bay has resulted in
recovery ti1M3 tluzl mtJy be several times longer (some commenlers claim shorter) than actual
recovery ti1M3. SEDCA.M has not been field tested.

Respoase: Conimnation of model predictions with sediment monitoring data is a required
element of the site remedy. Predictions regarding the effects of source control and natural
recovery which were developed during the feasibility study must be rermed based on new data
obtained during source monitoring and sediment remedial design sampling.
7.2.4. The SEDCAM application to the Head of Clly Waterway used erroneous data. A. sedimenta-
tion rate of 600 mg/c"; /y' is used inslead of the value of 1.760 mg/c"r /yr indicated by the Z1tIPb
data.
Respoase: The commenter indicated that depth changes since last dre~ing indicates a
sedimentation rate of 3.0-3.7 cm/yr instead of the 1.26 cm/yr indicated by Opb or the value
of 0.43 cm/yr used in the feasibility study. A lower sedimentation rate was used because
existing information on the loading rate of material from the tWO major drains at the head of
the waterWay indicated much greater discharges of particulate material in the past. This
change in sediment accumulation confounds interpretations of 2lOpb da~ because the %1Opb
darin. model. assumes constant sediment accumulation (on the average) over the time periOd
that is being dated. Similarly, if the average sedimentation rate was used (on the basis of the
dredainl horizon), the sedimentation rate would also be greatly overestimated.
8. SEDIMENT REMEDIAL ALTERNATIVES
Sediment remediation is one of the major components of the. site cleanup. Comments
regarding remedial alternatives included discussion of evaluation criteria used in the feasibility
study, the feasibility and impacts of dredging, natural recovery, and monitoring requirements.
Most of the comments were made by the major PRPs, both individually and together (as the
Commencement Bay Group). In general, comments of the PRPs questioned the need for, and
feasibility of, remedial actions.
8.1 Comments on the Permanence of Confinement Options
8././ The feasibility study is clear in recagni=ing that none of the conjineme1ll options meet the
SARA preference for a permanelll solutiml.
Response: The remedy selected in this Record uf Decision is inrended to provide 1 permanenr
solution to CB/NT sediment problems. (See response to Comment 1.1.1 :lOd further discussion
in Section 11.4 of the Decision Summary regarding differences between permanent ~olutions
and utilization of permanent treatment technologies.)
~.: Comments on. the . Feasibility of. Confinement Options
1.2.1. The /easihilic.v stud.v Joes not identify feasible and cost-I!ffective disposal sites. Site-speczfic
dala are not detailed t!1lou~h to identify the disposal site capacity needed and available. Disoosai
;.ite ,1ath.vmetn'. calculated capacltv, .iikillt{ :'on,irruratum alld .:oiume. £IlId ./tner.:emecirlllcc't
considerations are required evaluation criteria ill;lead vf specifyillg all ullidelltlfiedupland :me
within a J-mile radius.
Respoase: The assessment of disposal site :Lvailability will change depending on changes in
alternative ~ of me site and estimates of total volumes of material to be dredged as part of
sediment removal action. The selected remedy includes a suite of containment options which
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e
include some with definite disposal site availability (e.g., confined aquatic disposal in
waterways). All of the candidate sites in the feasibility study are located near the problem
areas and represent near-minimum transportation costS. Final selection of a disposal site for
each problem area is most appropriately decided during remedial design when more accurate
clara on Vltti",ent volumes are available.
8.2.2. The proposed remedy does not adequ/llely take into account the lack of suitable. available
. onsite disposal capacity.
Response: The selected remedy includes a suite of containment options which include some
with built-in disposal site availability. The options are considered equally protective and
feasible. EPA recognizes that the containment option selected for each waterway will force
certain economic/development choices by PRPs. The agencies do not see the need to specify
disposal sites in the Record of Decision.
8.2J. Blair Waterway Slip 1 is not available for neQ/'shore disposal or of inadequate capacity. The
Wheeler Osgood waterway. the St. Paul Waterway, and the Hylebos Disposal Sile #1 Q/'e suggested
as allernative sites.
Response: The comment noted that volumes cited in the feasibility study are various and
overestimated even presuming a vertical wall at the outer end of the slip. A vertical wall is
unreasonable, and construction of a berm would further reduce slip capacity. Capacity is
estimated to be 590,000 cubic yards for a 55-foot rill and 347,000 cubic yards for a 30-foot
rill. Changes in the Port of Tacoma's intended use of Slip I have occurred since the collection
of clata for the feasibility study, and it is uncertain whether this site will be available for
nearshore disposal.
Nearshore disposal has been included as one of the four confinement options within the
selected remedy. As a general policy for the CB/NT site, EPA would prefer that the
nearshore disposal option only be utilized in conjunction with projectS that would otherwise
be permitted commerical development. The intent of this policy is to minimize unnecessary
impact to nearshore habitat, consistent with the provisions of the Clean Water Act Section 404.
Therefore, the use of these other areas as potential nearshore disposal sites would be limited
according to the CB/NT policy to minimize impact to intertidal and nearshore areas.
8.2..1. The feasibility study incorporates unrealistic goals 01 clean sedimem availability.
estimate 01 the quantity 01 capping material Ileeded and available should be made.
All
Response: The volume of clean sediment required varies with the alternative. For ill litu
capping, the entire problem area must be covered with :1 cap of 3-6 feet in depth. or :1 rotJI
of 792.000-1,548.000 cubic yards. For nearshore Jnd upland disposal. only the incenidJi Jre:1
must be c:lpped (for habit:lt mitig:1tion), requiring :1 rotal 1)( 31.000-64.000 .;ubic ::1rcls. F')r
in-waterway CAD,. overdredged sediment will be used for ';:1pping.
-3.2.5. Use 1)/ deep-waIer CAD IS un pro veIl. and r!xperience suggests it \Viii llOl relia.bly L'iimlllace
exposure 01 biota to toxies.
Response: Although deep-water CAD sites have effectively been used in other .3ites. it :5 nor
. included in the selected remedy for the CB/NT :;ite.
,'.:.5. Soecification of (he :lse of /lew !echnolo1?ies ill St. Paul Waterwav, /01' which ,Ire .~r(!!c"".(,~1
.;uerl1ative !S !lalurai ,.ecovert'. IS /lOt ,lppropnatq. :Jnd >houid I/()t;"e !IIClluicd :Il :he .\ccora '.f
Decision.
Response: No such technology is specified in the selected remedy. The remedial Jction
undertaken in the St. Paul Waterway area by Simpson Tacoma Kraft included containment of
conrn.min~ted sediments behind ~ berm. capping \Virtr clean material. and habitat restoration.
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.
place and monitor contaminated sedimentS at great depth, and due to conflictS with the
CERCLA preference to avoid offsite disposal of untreated wastes.
8.S ColllDlellts oa the Cost.ElrectiveDess of Sediment RemedJa1 AdfOD
8.5.1. TM pgfonruznu-based Record of Decision must idenJify feasible and cost-effective remedial
actions. not simply specify cleanup standards.

ResDOIIIC Although based on performance objectives, the CB/NT Record of Decision
specifies conf"mement as the preferred disposal alternative for contaminated sedimentS,
including four options (i.e., in situ capping, commed aquatic disposal, nearshore disposal, and
upland disposal). Each of these. options has proven feasible and cost-effective at other sites.
The inclusion of disposal options in the Record of Decision allows PRPs to select the most
appropriate disposal strategy for each problem area. Records of decision have been issued in
other circumstances (e.g., the Colbert Landf'ill site in Colbert, Washington) that allow
flexibility in the remedial design/remedial action phase.
8.5.2. A.ccordin, to EPA.'s firures. confi'fU!d aqtIQlic disposal is about 1/3 the cost of nearshore
disposlll and muda more likely to bt! feasible. giMl tM ItlCk of 'fU!tlrshore disposlll sites. Therefore.
confi'fU!d aqtIQlic disposal is more cost-effectiye tluzn nearshore disposal.

RespolllC The Record of Decision specifies four confinement options for remediation of
coomm1ftated sediment! and thus allows flexibility in selecting the most appropriate option for
each problem area. As the commenter notes, cost and availability of disposal sites will be key
factors in this selection process.
8.5.3. The benefits of remedial action have not been clearly identified and demonstrated to e."Cceed
the costs. .
. Respoase: CERCLA does not mandate that individual remedial actions be selected based on
the result of a cost-benefit analysis; a consensus on assignment of monetary values to
environmental q~ality and. human health is impossible to achieve. Cost is merely a balancing
~riterion for consideration of remedies that are otherwise equally protective of human health
and the environment.
9. IMPLEMENTATION AND MONITORING
A number of commentS were received on the process for implementing key elements of the
selected remedy. particularly source :lnd sediment monitoring. Comments on these topics were
received from various PRPs. and federal Jnd state Jgencies. Cumments gener:llly :lddressed [he
~iming Jnd suitabilicy of rhe IO-year recovery period. [he role of routine dredging, :lnd :he process
(or implementing monitoring programs :lnd interpreting monitoring Jam.
9.1 Comments on T~ming of Source Control. Sediment Remedial Action. and Naturnl Recovery
9.1.1. Slormwaler drains and ()(her IIonooim sources of pollulion are /101 idemified vr ;vill /wt he
controlled until aiter other sources. and therefore sedimelll remedialion will 1101 he ~lfecllve. The
ooli~alion lor stormwater source control must he established by the Record oj Decision.
ltesponse: Storm water drains have been identified. :lnd :l monitoring program :lciministered
by Ecology is to identify those to which source control shall be applied. Demilsof the source
control element are described in the response to CommentS 6.1.1 and 6.2.1. Sediment
remediation in a problem area. cannot proceed wuil adequate source control is achieved in that
problem U'e3'.
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.
9.1.2. The 10-year period for nalural recovery appears to be arbitrary and unjustified.
Response: The remediation of all sediments jn the CB/NT site with contaminant concentra-
tions at or above the cleanup goals was considered inappropriate because remediation of all
such sediments may result in more environmental disruption (tJuough dredging and capping
activities) than might be expected if some of the Jess coammin!lted ~iments were allowed to
recover naturally. In addition. the cost of remediating margina1Jy conmmiftAted areas could
not be justified in all cases. To achieve a balance between protection of human health and
the environment. and cost-effectiveness. the feasibility study employed a sediment recovery
model (SEDCAM) to derme areas of the CB/NT site that wou1d be expected to recover within
a la-year period.
Many commenters suggested alternative natural recovery periods. ranging from 2 to 2S years.
Some suggested that natura! reCovery should be allowed to proceed for 10 or more years even
in the most higJUy contaminated areas before remedial action is undertaken. The la-year
recovery period was selected by Ecology and EP A to deilne areas requiring sediment
remediation. The la-year recovery period was selected based on assumptions about source
control. the rate of accumulation of Dew sediment. and the degree of mixing of old and new
sediment because of burrowing organisms and physical processes. Control of all priority
sources in the CD/NT site is planned accordin8 to the implementation schedules in Appendix
C. Muimum environmental and human health benefit will be derived in a cost-effective
manner by remediating the most conmmin!lted sediment sites rmt. because of the time
required for full implementation of source control. The results of the SEDCAM modeling
indicate that some sediments will recover naturally durina a la-year period. and therefore. do
not warrant further disruption by sediment remedial action. Such actions would also be less
cost-effective in the short-term. Sediment monitorin8 will be implemented to verify the
results of SEDCAM modeling. The results of modeling will be periodiCally evaluated to
. determine the status of sediment recovery and the potential need for additional source control.
measures or sediment remediation.
9.2. CollUlleDts oD.TIme Schedules
9.2.1. Timetables for remedial a&tion do not give an adeqUQJe allowance for the completion of
source control.
Response: Updated versions of the implementation schedules presented in the integr:ued
action plan (PT! 1988) are provided in Appendix C. Schedules have been revised to reflect
more recent information on the status of source identification and control activities. These
schedules were developed for planning purposes, and depend on continuing resource
availability, succ~ssful negotiations with PRPs. :lnd timely implement:uion ot' source control.
').~.~ Comments on :he .draft leasihilil? \'ludv are far reachillJf alld CaJlIWI ,rr.lh' ;'e -...a"ttqualel.1'
addressed and responded to in }USI a few months fi.e.. b.v summer or eariv fail 0/ 1989).
Response: The agencies have reviewed and considered aH commentS. AU commentS that
were considered germane to the selection of remedy have been summarized and responded to
in chis Responsiveness Summary. Other commentS that were not germane to the selecrion of
the remedy but .hat may be important for remediai design. remedial action. or additional
source controi are summarized in Section IV and are listed in the annotated bibliography in
Section V.
} .2.J When the proposed i 0- year dock /or Ilalurai remedial ion Slares is IlOI c.:ieariy sealea. it is
essential that the sequence of all events be clearly eSlab/ished.
Response: The beginnin8 of the la-year time period for natural recovery will coincide with
implementation of ~l"tii~"t remedial actioDS. which will bqin after colltl"Ol of major ~ources
as described in Comment 6.3.1. For problem areas where the entire area of s~diment
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exceeding sediment quality objectives is predicted to recovery naturally in 10 years, the
recovery period will begin after the baseline monitoring program (which may correspond to
remedial design sampling). Adequate recovery in natura! recovery areas is to be confirmed
by biological and chemical testing as part of required monitoring. If the agencies determine
from these monitoring data that adequate recovery has not occurred in the designated
timeframe, then remediation may be required even if the area was originally predicted to
recovery naturally.
9.2.4. FurtMr testing and e'lalUlZlion is mandaled to idenJify and f/U/Jlftify .toxic hot spots. before
implementing remedial action.
Respoase: Reimement of the areal extent and severity of conmmination will be refined
during remedial design sampling.
9.3. CollllDeDts OD Routfne Dredging Projects

9J.l. MainJmance and development dredged malerial which passes PSDDA requirements should be
allowed to go to the PSDDA disposal sites.
Respoasc This comment assumes separation of sediment into suitable and unsuitable
categories for open-water disposal by applying PSDDA testing methods. It is recognized that
clamshell dredges have a horizontal accuracy sufficient to maintain separation of sedimentS.
Maintenance and development dredging waste is allowed at PSDDA sites if it meetS PSDDA
clisposat guidelines for open-water unconf'med disposal CERCLA actions do not cover routine
maintenance dredging activities.
9.3.2. Maintenance dredging may remove contaminaled sediment. making remedial dredging
. unnecessary.
Respoue: Feasibility and cost analyses have been prepared presuming .that all sediments in
problem areas, even those in channels that may be subject to maintenance dredging, will be
removed by remedial action dredging. As the extent ~d schedule of maintenance dredging
is unknown, this is a conservative assumption, and allows planning for worst-case remedial
actions. It is not likely that maintenance dredging will make remedial dredging unnecessary,
because for the eight CB/NT problem areas described in this Record of Decision, any material
that is not predicted to recover naturally and that does not pass PSDDA guidelines for open-
water unconfined disposal, will be remediated as part of a Superfund action.
9.3.3. Additional volumes of contaminated material and disposal options have not beelt recoglli=ed
for maintenance and development dredging that may occur ill .'iOme areas desigllated lor Ilaturai
recovery.
Response: CERCLA actions do not cover maintenance dredging. Contaminated sediments
~ncountered during remediai dred~ing must be disposed at in Jccorciance with PSDDA I)r
other appHcable guideHnes.
9.4. Comments on Source Monitorin~
9.4.1. Washin~ton Department ot" TransDortaliml has ."erlormed remediation altd mmtitorim: of lar
:.;na' ..'ooper hordermrr Cit.l' Waterway 1.1Ird '.lIould .'Wt he listed I.lS .:l PRP.
Response: Runoff from Interstate-5 is the primary source of contamination of concern
relative to Washington Department of Transportation, not the contaminants uncovered and
removed during construction of the Tacoma. Spur.
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9.4.2. The Washington Department of Transportation and the state of Washington should be listed
as PRPs. based on an eStimate thal lnterstale-5 contributes about 40 percent of the pollution entering
Commencement Bay.
Respoase: This comment is being considered by EP A in its PRP search.

9.4.3. Tire feasibility study d~s not acknowledge the efficinu:y of the mtZMgement practices.
including source control. remedial actions; and implementalion of secondary trealment that !rave
already been implemented allhe ore handling facilities on Sitcum Waterway and Kraft mill on St.
Ptml W'alerway.
Respoase: The feasibility study focused on sediment remedial alternatives for the nine
problem areas. The integrated action plan provided a general description of source control
actions still needed at major sources, but it was not intended to provide a detailed history of
source control actions at each facility. It is the responsibility of Ecology to track environ-
mental management activities at each facility, to review past actions, to determine what
additional source control measures are necessary, and to see that those additional measures are
implemented.
9.4.4. Developing stale policy indicales thal a sediment i",ptlCt zone lfIUIy be desig1faled fo,. sources
thal are imple1Mnting A/URT. but are unable to meet sediment criteria withOUl unreasonable cost.
Tire feasibility study should address: 1) How the decision to require (0,. not require a sediment
impact zone will be lfIUIde: 2) JVlraltechnical bases are to be u.ud to define the area of a sediment\
impact zone: 3) JV1ral effect will a sediment imptJJ:t zone lurIe on the long te,.",ti",ing of sediment
remedial actions: 4) What monitoring of a sediment impact ZOM will be required: 5) W1rallong term
remedial actions will be required where a sediment impact zone is established: 6) W1ral parties will
be responsible fo,. monitoring and. in essence. stand behind the sediment impact zone.
Response: Guidelines for the development, operation, 'and closure of a sediment impact zone
are ,being developed by Ecology. The sediment impact zone policy will be recognized in the
evaluation of the acceptability of source controls that is conducted prior to implementing
sediment remediation. If the continued discharge resuJting in sediment contamination is
clearly in the public interes.t, a wastewater discharge permit may define a specific sediment
impact zone for the discharge, and requIre periodic maintenance until better methods of
treatment can be identified and implemented. This permit) would not likely delay capping or
dredging contaminated sediments because such cleanup actions provide a clean baseline for
monitoring the discharge.
9.5. Comments on Sediment Monitoring
9.5.1. Location of a' confined aqumic disposal site ill Commellcemem Bay must take inca accoullt
?SDDA sillng consideraLions illld mOllllOrmg.
Response: The selection of in-waterway ~oniined aQuatic disposai :IS the preierred alternative
will not conflict with the PSDDA disposal site or monitoring locations.
9.5.2. Monitorintr of newiv exposed sediment [oi/owing Jred!(ilf!( should flat be done :miess there
is an expectation [hat the flew surface will he [oxic.
ReSDonse: Monitoring of the newly ~xposed surface is intended to characterize the
,:offiDleteness or ,he;!eanuD '.lnd .;stablish :J. JaslS :or later Jetermining whether :1atUr~l1
recovery or recontamination is taking place, Jnd if habitat restoration is successfuL
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9.5.J. Monitoring of the newly exposed sediment should be done. but by a surfa&e grab sample
taken immediately after dredging rather than by a core; this will be a considerable cost savings.
Respoase: The newly exposed surface is expected to be subject to mixing with deeper
sediments. both as a result of bioturbation and physic:a1 disturbance. A core taken after
dredging :will indicate whether there is 'subsurface contamination that may be brought to the
surface. and will provide a basis for interpretation of long-term monitoring data. .
9.5.4. Monitoring of sediments not clearly exhibiting benthic toxicity is recommended at five and
10 years following source control. Monitoring followin, cletllWp must be required..

Respoue: Monitoring requirements are discussed in Section 10 of the Decision Summary and
in the integrated action plan (m 1988). Monitoring is required after source control and any
sediment remedial action to demoDStrate the effective remediation of problem areas and
integrity of disposal sites.
9.5.5. Confined aqruuic disposal sites are experimental and therefore require more compliance and
environmental monitoring than stated in the feasibility study.
Respoue: Conf"med aquatic disposal site monitoring is briefly outlined in the integrated
action plan. Specific monitoring plans for each site will be developed during the remedial
design phase.
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IV. REMAINING ISSUES
Some issues and concerns were raised that were not germane to the selection of remedy but
which do warrant consideration by the agencies. These issues are marked as "Deferred" and will
be considered and factored into remedial design and action. These issues and concerns included:

1. Incorporation of new information developed post-record of decision as described in
Section 10.3 of the Record of Decision and briefly discussed in the response to
Comment 5.1.3
2.
Success of future source control and the impact on remedial action plans; the success
of source control will be monitored and adequate source control will be required
before sediment remedial action begins

Future public input to the integrated action plan, which will be through participation
in the Technical Discussion Group and public comment periods on individual consent
decrees that implement specific cleanup plans

ASARCO's comments specific to sediments in the Ruston-Pt. DeilaDce problem area,
which will be coDSidered public comments for the new ASARCO sediments operable
unit

Other detailed comments that are relevant to remedial design considerations (i.e.,
specific comments on the area, volume, and characteristics of contaminated
sediments); these comments were not relevant to the selection of remedy but will be
further considered at the start of remedial design.
3.
4.
5.
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v. ANNOTATED BIBLIOGRAPHY
Comments abstracted from materials submitted by citizens, and representatives of various
agencies, PRPs, and citizen groups are summarized in this section. Additional detailed comments
were submitted durin8 the comment period as part of major documents, such as ENSR (1989),
Kaiser Aluminum and Chemical Corporation (1989), Penn walt, Corporation (1989), Puyallup Tribe
of Indians (1989), and ASARCO (1989). These comments were considered in developing responses
to the major summary comments that were identified in these reports and listed in, this section.
AOL Express, IDC. (1989)
See Response 3.3.1
See Response 6.1.1
and 8.2.1
Deferred
ASARCO (1989)
See Response 1.1.3
S~e Response 3,3.1 '
See Response 6.1.1
and 6.3.1
See Response 7.2.3
{W]e feel il is important tluzt consideralion be given to the level of'cleanup,
taking into account the mulliple use nature of the area and the importance
of a heallhy local economy.
We feel that wilh effective sOW'ce control moniloring and the availability
of an adjacent disposal sileo a reasonable and cost-effective remedy CQ1l
be achined.
The public slorm drains in oui- area drain into the . Blai,. walerway, a sile
!lJll. designaled lor any cleanup action...we support {the position to have
.responsible parties" do the cleanup}. but strongly maintain thal we are !1JlL
a responsible party [in the Hylebos Waterway}. The best way to deal
equitably with the smaller business who is demonstrali,vely not involved in
poliUlion of tM waterway is to enter into immediate negotiilliolis for release
either by oUlright dismissal or deminimis settlement.
The Feasibility Study has failed to comply with the NCP in that it is too
broad [comprising the entire bay} and is based upon inadequate data [for
any give,r segment of the bay}. Based upon the [recem} findings of (the
Tacoma Smelter site RI/ FS}. EPA should withdraw in its 1!1Ilirety that
portion of the Commencement Bay FS dealilrg with the area of/shore 0/ the
Tacoma smelter and should revise the FS iJas(?d UPOfl the Jwa.
The Feaslbiiity Study is based !.lpOfl all imprnper remedial w:wm ;uai , .
the sediment Quaiity goal. "I/O acUte or chronic adverse effects Ofr hiaiOf!lCai
resources or sigl1i;icam health risk to ;Iumans" , . , IS ;UlCOlll1eCted '.vllh aJ/v
requirement of CERCLA and is lIot mandated by any ARAR , , , {the ']oaiJ
far exceeds CERCLA'J goal of protecti,rg the environment, , , alld is lIot
attainable (as a dean up objective. .-I. goal of sediment quaiill' that SUOP0rlS
a properlv /wrctionmtf ill \'itu hemhic commul1ity aJ/d ioes lInt :"ose .1
\'lgmficam nsk (0 human health. is attainable and much more :11 .::eepl1!!?
with the slated statutorv objectives of CERCLA.
Appropriate source comrol should he wrdertakel1 aJ/d achieved r,er'ore aJ/v
offshore remedial action. ' ,
The impact of 1UJlJU'ai reco'#!1'Y processes we been greally underestimated
I:1y rerra redr. Once onshore source control has been attained [at the Asarco
Tacoma Smelter J. it is highJ.v iikeJ.v thill physical removal of contaminated
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See Response I.J.5
See Response 8.3.1
sediments by currents and wave action ~ill be achieved. This activity was
not properly considered by the FS.
The FS has failed to take into consideration the fact that much of the
ctmli11lti1uztion targeted for r~ditli a&tion {althe A.sQ1'CO Tacom/l Smelter J
is a result 01 a "federtlily permitted release'" and therelore not actionable
under CERCLA.. .. At a minimum. the FS should consider the impact 01
federtlily permitted releases and exclude contamination from such releases
from any remedial action recommended or set up the proper method for
crediting the PRP for s~h releases.
The FS alternalive for the area offshore of the Asarco Tacoma Smelter is
contrary to the objectives 01 CERCLA. {beCQUSe it . . .J contains a healthy,
and in some cases. very unique benthic community. . . extensive dredging
is not only unnecessary. but would itself adversely impact tHe environment
through tOtal destruction 01 health benthic communities.
[Numerous SpecUlC comments followed in the comment letter that pertained to the Asarco Tacoma
Smelter site; attachments included a "Review of Commencement Bay Feasibility Study" by
Parametrix. Inc. and Black & Veatch. "review of Commencement Bay Integrated Action Plan" by
Parametrix. Inc.. "Review of 13.0 Ruston-Pt. Defiance Shoreline Commencement Bay Feasibility
Study" by Parametrix. Inc.. and '7echnicaJ Review of the Apparent Effects Threshold Approach" .
by Tetra Tech. Inc:.. and the "Asarco Tacoma Smelter Remedial Investigation" by Parametrix. Inc.
. (1989).]
Deferred
American SaYiDp Bank (1989)
{OJbjects to its designation as a potentially responsible party. . . [and]
resenes the riglu to comment further when -{the Proposed PianJ is
completed.
BuffeleD Woodworking Company (1989)
See Response 6.1.1
and 6.3.1
See Response 8.2.3
See Response 1.1.6
We agree with EPA that the priority should be to work with the responsible
parties to ensure that source control is complete before starting sediment
remediation.
The EPA should consider altematives to the Port of Tacoma Slip '*1 Olt
{he Blair Waterway. Cvmnu!1lt.'i... illdicate {hat :he Pore needs {he use
of this site before clealt-u.p calt reasonably expec! to he ~'(}m.p{e[ed.
We disasrree with {he method {he EPA has for assessill!! costs Q!!aillse {he
PRoP's as tl1l aggrelfate group rather than OIl tl1l indivrduai .,asts. Tilis
method can resuit ill the PRP with the mOSI e/leetive altorney being
responsible'lor ehe smQlleSI percentage a! the COSI. . .
.::ee ~esDonse :;.:.-:
Clampion international (1989)
ill "few 0" :Ile "'-act lIral /the ':leaJt-!lO o( St. ?c.ui TruenvQv c:s ,IUliinea ./1
Ute CUllsent Decree! has aeell completed alIa. itas aeel1 jut.lgea 10 .7e
successful. Champion urges EPA to aceept the projeci as completed in {he
ROD for the Commencement Bay site. Champion agrees with the FS
conclusion as set forth in [Set:lUJn 8.6J tJuu in situ capping of the problem.
aJ?tZ.ol St. Paul Waterway is the preferred alternative. ihe ROD should
accept chis recommendation.
-------
Information noted
Infonnation Doted
Information noted
Request noted
Request noted
Cldze. Letten (1989)
CIty of Tacoma (1989)
See Response 3.3.1
See Response 4.3.1
and 3.1.1
See ~esponse 7.2.2
See Response i .2A
S~e ResDonse ~.:.l
:hrou~h 3.:.3
~~e :~esDonse .~.4, j
See Resj1Od::ie 2.1.1
[The St. Paul/project was completed under Ecology supervision and with
EPA being kept fully informed of the nature of the project and its progress
. . . [the} Consent Decree. . . provides. among other things. for long-term
maintenance and monitoring.
'TM Tacomll kraIt mill was acquired by C1uzmpion as a result 01 the merger
01 St. Regis Paper Company into Champion.
The actiyities described in the subsection entitled. Sediment Remediation
and Habitat Restoration- haN been completed and approved by Ecology.
The administrative record lor this FS should include the Consent Decree
[for the St. Paul Waterway area].
Champion agrees with the comments of the Commencement Bay Group
[and} urges EPA to seriously consider those comments in connection with
the ROD.
(See Background on Community Involvement section)
{T]hese elforts (to facilitate a cleanup plan] must be cost-effeclive and
focused on achievable goals that accommodate the valuable commercial
and industrial activity surrounding Commencement Bay.
The Apparent Effects Threshold (AET) does not provide an appropriate
cleanup standard because it does not adequately differentiate between
elfects caused by individual chemical contaminants and effects caused by
other factors. The proposed AET -based standard also targets some
sediments for active remediation where there are thriving ecological
communities.
We concur with the Feasibility Study that ongoing sources of contamination
must be curtailed before any remedial dredging occurs. and support the
concept of natural sediment recovery. However. we conciude that the criteria
defining areas aJlowed to recover naturaJly are too restrictive, . .
An error was made ill aopl.\'illg the sedimem recover\' model at the Head
of City WatenvQ\,. .-4 recalculatioll of lhe !?wdel :ISI1l~ ,he c'orrcc: .1 ala.
from the Feasibiiitl' Study illdicated that most O( ,he ;valerwilY IVlii rcco"er
IlaturaJl.v il source comrols are implememed. The Jredf!e bOUlldarres
proposed. ill the Feasibi/il.\' Stud)' .vould result ill !leedless ~'OStS :J.na
disruption IJ/ biological commullilies at ooth the dredge alld disposal sites.
The Feasibilil.\' Stud.\' does /lOt identify feasible alld c'ost i!lfeCllVe response
actions jor most ',vatenvavs he cause il Faiis [0 Ideml!.\' avatiaiJle .lisposai
:iles fnr the quamiliesoi materials proposed for Llredr:illg . . .
Tlte .:'easlnilitv .';ludl' uoes 1l0{ :demiiY ..'easlbie ..1lla .~'ost _.rfecllre 'cSO()I/se
aClions for most waterways. . . hecause il greally ullderestimates
remediation costs. The cleanup plan proposed in the Feasibility STudy for
. $28 million could cost in excess of $100 million to implement.
CQmmcrit.c;rr.mr Bay sediments do not pose a significant human health risk.
The actual health risks from Commencement Ba.v sediments aTe similar to
-------
See Respeme 6.5.1
See Response 4.4.2
See Response 3.2.1
and 3.2.2
See Response 9.5.4
Request noted
The actual heallh risks from Commencement Bay sediments are similar to
those reported for Carr Inlet and other non-urbanized Puget Sound
waterways. and are within the range of risks that EPA has considered
acceptable in other situations.
TM /irst element 0/ the cleanup plan to proceed with is implementation
0/ source controls. The City 0/ Tacoma has already initialed a program
to identify and remove existing sources 0/ contamination from municipal
storm drains. and we are also studying the /etlSimlity 0/ trealin, storm run-
all elflering tM Head 0/ City Waterway.
In recognition o/the AET and sediment recovery model /imitalions. we
su.ggest thQt only sediments with concentrations clearly exhibiting bemhic
toxicity be remediated immediately, in order to take full advantage of
nalural recovery.
Biological criteria used to define dredging boundaries must be based on
aMly:sa 0/ the resident benthic communities. These aMlyses should be of
sufficient detail to differentiate toxic effects from other site specific or
emirorll"l1Itlzi e // eets.
In aretlS not clearly exhibiting benthic toxicity. sediment concemrations and
biological recovery {should] be monitored at 5 and 10 years following
completion 0/ source controls. Sediments not meetin, the long-term cleanup
goal alter 10 years (should not] be remedialed.
We suggest that the U.S. Environmental Protection Agency and the
Washington Department of Ecology open a local office for their joint use.
We further suggest that the local site managers be assigned full-time at thal
ollice.
City of Tacoma (1989); Attachmeat A-Review of 10.0 Head of City Waterway
See Response 5.3.1
and 5.1.2
See Response 7.2.1
through 7.2.4
See Response 8.4.1
See Response 6.2.1
~eQuest noted
The Feasibility Study overestimates mass loadings for most sources. . .
[and] has not adequately evaluated the nalure and extent of [sources
within drainage basins] based on our more extensive informalion.
The SEDCAM model. as used in the Feasibility Study. overestimated :he
time required for nalural recovery o{ City Waterway sedimems. This
uvereslimale uf the time required for IltlIurai recuvery is .ire result u/
erroneous assumptions.
The eSlimtlIed CO.'iIS of 5edimellt remeciitlIion are SerlUWii.l' uJlcieresllmaled
by the Feaslbilil.v Study.
The Feasibility Study proposes infeasible end-uf-plpe source control
measures.
The "EJlvironmental Sir:llificallce' ralilll: for lhe ;lead of C:ll' :1'Qtenva\'
5hould he "low" rather than ., medium."
i,Plus Jddicionai '.;ommentS foHowing summary commentS.)
See ReJponse 1.2.4
City of Tacoma (1989); Attachmeat C-Review ot CQlDmencelDelL1 Bay lnte&1'ated ~tiQI1 Pla.n
The fntegrared Action Plan. . . .5uffers from the same reliance an AETs
-------
[as the Feasibility Study]; ignores dredging and disposal impaczs; wes the
SEDCAM model that underestimates the rate of natural recovery; does not
consider the benefits to be derived from wing a natural recovery goal
greater than 10 years; proposes an inadequate biological testing program.
Thes~ short comings. . . should M remedied befor~ any actions are
undertaken.
(Plus additional comments following summary comments.)
Commeacemeat Bay Group (1989) (also cited u ENSR (1989)1
See Response 5.1.2
6.4.1
and 6.4.2
See Response 2.1.1
See Response 3.3.1
See Response ~.I.I
See Response 4.2.1
See Response J.3.1
See ~esponse c.!.3.:
See Response 7.2.3
The RI did not idenlify and quantify contaminant sources in suf fident
detail to allow reliable estimates 01 current corrtaminant loadings and
achieveable source control. Because 01 inadequate source characterization.
the source loading and source control estimates mtJde in the FS are based
on technically unsupportable assumptions. These estimates of two of the
most fundamental ele1'Mnls of sit~ clean-up. are highly uncertain and are
likely to M in e"or {detailed discussion in Chapter 4 01 the ENSR report].
Th~ FS o'~r-estimated the human h~alth risle.! in Commencement Bay by
n~arly an order 01 magnitude. This low~r risk is within the generally
a&c~ptable range and is comparabl~ to tM risk reported in the FS lor Carr
lnletth~ (the relerence area) {sic]. This indicatestJuJl sediment clean-
up based on human health risk is not warranted in Commencement Bay
(detailed discussion in Chapter 3 of the ENSR report].
The sediment clean-up objective. -noacule or chronic adverse effects on
biological' resources., wing Apparent Elfects Thresholds (AETs) as the
clean-up standard. is not attainable sustainable {sic] in Commencement Bay.
This goal defines pristine conditions. Commenceme1ll Bay is an active port
and industrial area which cnC% {sic] ~ achieve pristine conditions. Prop
wash. maintenance dredging and other urban activities will prevent the
pristine goal from being achieved. There. is insufficient source
characterization information to predict attainment and maintenance of the
AETs without repeated dredging and disposal. An achievable and
sustainable sediment clean-up objective and standard should be established
before implementing sediment remediation [detailed discussion in Chapter I
of the ENSR report]
AETs failta establish cause (lJld eifect relationships heClveen L'OllCaminaJlts
and hiolofJical responses.
The long cerm sediment c:iean-uo slandard ( AETs j e(lJ1 he a useful iIIdicaLOr
0/ pOlential ativerse r!fiecls. nUl IS /lOC 
-------
See Response 8.2.1
through 8.2.8
See Response 3.3.1
7.1.3
6.1.1
8.2.1
8.4.J
2.1. J
4.3.1
and 3.1.1
Deferred
is best estimated by monitoring actual recovery following source control
{detailed discussion in Chapter 5 of the ENSR report/
The FS failed to identify feasible and cost-effective response actions for
most willerways. Most altemillives identified and evaluated in the FS
including the preferred altemillives can not be implemented because of the
lack of sufficient disposal capacity. {detailed discussion in Chapter 6 of
the ENSR report} .
Our btzsic concerns about the proposed cleanup plan include {are sum-
mDrized as follows} . . . Th4 cleanup goal for Commencement Bay should
be realistically based on the present and future uses of the Bay. . . Natural
remedialion is an effective way to address this historical process. coupled
with continuing efforts to .turn off the spigot" on ongoing pollution
sources. . . Source controls should be implemented first. and their
effectiveness measured. before any remedial dredging occurs. . . The
Feasibility Study does not idenlify feasible and cost-effective response
actions for most willerways because it fails to identify available disposal
sites. . . and because it greally underestimates remedial costs. . . Com-
mencement Bay sediments do not pose a significant human health risk. . .
AEr . . . does not provide an appropriille cleanup standard. . . The AET
approach also targets some sediments for active remediation where there
may be thriving ecological communities~ . .
The no-effect stillion setting an AEr may appear to sillisfy the definition
of AEr simply because the sampling was truncilled in the midst of a series
of sporadic effect stillions at a point where the highest concentration
happened to be an adverse biological effect stillion. There should be some
assessment as to whether the AET value is likely to be solely the result of
sporadic effects rillher than consistent adverse effects above the AET.

(Plus additional comment! in sections of the ENSR report.)
DNR (1989)
See Response 9.4.3
See Response 9.5.5
See Response 3.2.5
See Response 4.1.1
{T/he FS (should/ address: 1) How the decision to require (or not require
a SIZ (sedimem impact =one/ wiii be made: 2) What technical bases are
to be used to define the area of a SIZ.. 3) What effect wiii a SIZ have on
the long term timing of sedimem remedial actions: 4) What monitoring of
a SIZ wili he required: 5 j What 10llg term remedial actions will he requm!d
where a S IZ is I:!stabiished.. (,) What parties lVill he res pm l5l hie :.or
. monitoring aJld. in essence. :uaJld nenilld [he SIZ.
Any CAD [site I would he tl/I I:!xperrmelll IlJld require more comoiitl/1CC ilna
environmental monitorrng chan wnat has been idemified in [he i"S ..:ost
analysis.
At the current time the Departmem o/ValuraJ Resources .:JCtimr inr 'he Stale
of Washington in terms 0/ aqUatiC lalla ownersnip does /lot apprnve ilf CAD
sites hecause of the issue oj mOnilOri1lf~ Ilnd technical feasibililV. . {a1ld.l
iiaoiiit~'. . . The ./casloiiil.\' of ,he C.iDwe :s ,1uesLlonanie.
The Department agrees with the basis premise that the AET method is the
best method available at the present time to idemify sediments requiring
remedial action.
-------
See Response 1.2.1
See Response 8.4.2
See Response 8.2.1
The Department agrees, that the long term goal as translated imo the AET
values stated. . . in the Feasibility Study is appropriate and that the actWli
decision can be refined through additional biological analysis. . .The
utilization of performance criteria is .very appropriate. . .
TM volUlM 01 sediment proposed for dredging has not been adequately
determiMd eVe7I in a geMrai way
The volume capacity 01 the nearshore fill and the CA.D sites is probably
signilicantly less tluzn proposed.
(Plus additional specific comments.)
DOT (1989)
Deferred
Based on {infor1Mlioll altached]. WSDOT {requestS to] be removed from
[the CB/NT site] PRP list. . . [and reqwSlS a written response as toJ why
WSDOT was not sent (!Jen a general notice letter until A.pril 24, 1989. well
i1llO 1M COmmenl period OIl the R//FS and at least five years into the R/I
FS process.
See Response 5.2.4
DUDlap TowiDI Compaay (1989)
Deferred
See Response 3.3.1
See Response gA.I
See R.esponse 8.5.3
See Response 5.2.1
Jnd 6.1.1
First it must be recognized that Commencement Bay is an urban estuary with
a large drainage basin. Not only are there industrial pollutants emering
the Bay, but contaminantS from automobiles, farms and storm drains also
run off into itS waters.
Some 01 [the fish in Commmt:enrmt BayJ displaY abno,.""zlities. the sources
01 which June not been identified lor cenain. however, they are the type of
tumors and lesions that are generally found ill fish from waters that have
beell contaminated with residues from non-point pollution sources such as
automobile exhaust and pesticides as well as chemical manufacturing
sources.
The goal of "no adverse affects" is illappropriate and would have a severe
negative impact on one of the nations most active ports.
The costs of the remedial altenratives ill the Feasihility Stud)' are ;rossi,"
understated alld have heen pro.iected to he as much as :hree ::mes :.iu:,\'
-------
See Response 3.3.1
See Response 5.2.1
and 9.1.1
See Response 5.1.2
See Response 4.1.1
See Response 8.4.2
See Response 8.2.3
See Response 8.4.1
Deierred
Gotnerai Metals (989)
See Response 1.1.3
See Response 4. i. i
[W]e question whether the long-term cleanup goal of no adverse effects on
marine life is appropriate for an urban bay. a working port. and a
de'leloping economy. .
C01Urol of airbonw emissions and surface runoff from highways. storm
drailU. farms. cOlUtTUCtion acti'lities. an other [non-point] sources simply
1rUlY not be sufficient to support a goal of-no adverse effectS."
We belieye [the FSJ focw 0" ship building and repair activities as the
source of copper and mercury in Middle Waterway is speculative. . .Other
possible sources. such as nearby industries and storm drains in the
Waterway. hme not been considered thoroughly. . .[andJ sampling conducted
to date is not sufficient to provide a clear picture of contaminant
distribution in the Waterway.
[IJt does not follow tJuzt obserHd cOIICerurations of [copper and mercury]
should be the basis for cleallUp decisions. The AET approach to sediment
quality does not establish causality between a particular contaminant and
a biological impact. . . Numerous studies. including ongoing work at the
Asorco smelter in Tacoma. indicate tMt the metals in slag may not be
generally bioaYailable.

The volume of contaminated sedime1US quoted in the FS (57.000 cubic
yords) is likely underesti1Mled [in Middle Waterway]. This volume
assumes a 1.5 foot cut . . . more likely. however. a 2 to j foot cut would be
used. . .
Disposal of the [Middle Waterway] sediments in Slip 1 near the mouth of
the Blair Waterway may not be feasible [because of an unsuited filing]
schldu/e. . . . [difliculties in dellning and apportioning J responsibilities
lor monitoring. . .the capacity 01 Slip 1 may be overstated in the FS . .
[and] altemati'lf! sites for nearshore sills may be available close to Middle
Waterway.
Costs presented in Appendix D of the FS appear low b.v a factor of two or
more. Specifically. the estimated costS listed for dike construction ($0.51/
cubic yard) should be more in the range of 58 to Sl2/cubic yard of dike.
while the estimated costs for mOlritoring wells ($2.000,' well) should be
c/o.
-------
See Response 8.2.10
See Response 5.1.1
See Response 8.5.1
8.4.1
and 1.1.1
We request thal , . . EPA change its preferred alternative for the head of
the Hylebos Walerway to source cOnJ.roi with naluraJ recovery or. in the
altemalive. if EPA re-analyzes i/.S altemalives. to remove PCBs as an
indicalor chemical.
EPA.'s characterization 01 sources 01 PCBs is iNJdequtlle to support remedial
action or to identily sources. .
EPA. has not shown thalth~ Agency's prelerred alternalive lor the head 01
Hylebos Waterway is cost ellective. . . First. the cost a:ntllysis is extremely
inaccurate. Second. the plan is not reliable. Third. the plan does not
adequately provide long term or permanent solutions to the contaminalion
problems at the site.
Grirna Galbraith Fuel (1989)
See Response 6.1.1
See Response 9.1.2
See Response". 1.3
See Response 8.5.3
8.2.1
and 8.4.1
See Response 3.3.1
Deferred
Stopping all sourc~ and non source pollution should be our first priority.
A.lt~r the sources 01 pollution are stopped we should give nalure sufficient
ti1M to remediDle the pollution. . . fT}wenty to twenty live years should be
givDr lor nalural remedialion. .
Save dredging lor those truly -Hot Spots: alter source control. to disturb
and spread the contaminaled sediments as little as possible.
A t:1.Urent cost-benefit analysis should be performed based on disposal sites
and contracting costs available today. . . the sites used in the Tetra Tech
study may not be practical solutions 0'" will not be available.
One ex-director 01 the EPA. staled thal in some cases the agency clean up
demands are lor a more pristine stale than occur in ,nalure. We cannot
overlook the fact that Commencement Bay is an industrial and population
center. We need cleanup goals thal are achievable with not eliminating
people and their livelihood from the area.
Since it is estimated that 1-5 comribUtes about 40% of the Commencement
Bay pollution. the Departmem of Transportation altd the State 01 Washington
should be listed as Potemia/ly Responsible Parties.
See ~esponse 3.3.1
Jones Chemicals. Inc. {1989)
See Response. 1.3.1
Jnd 1.1.:
See Response 8.4.1
and 8.5.3
This site is a !ar:;:e working porr. and Iras neelt an indu:urzai c;.rea /or 100
years. It is /lot realiscic to helieve thal it Call or j'itouid be !'esLOred :0
pristine conditions.
The 60al of "J!!. acUte or chronic adverse effects" 1m marine organisms :s
IIOC required by altv appiicab/e taw and should flOC he adopted uS :ire ;oai
for cIeanuo. . , the .!J/an :IS ,?rooosed could reauire COntlllUOUS c/eanuo
_'J/ores :0 II'.\' '0 reach LUl lmaltamaole '{oai.
. . . EPA's estimale [for costs at Superfund sites) is always below the
actU/lJ cost. often by /00% or more. In addition. this cost does not include
anv 01 the costs 01 source control. which area a key part of the Integrated
Itaicm PftIlr. EPIt i~ t~fore corrtem"lati1rg> a sorieraf cost (~ard/ess 0/
who actually pays) of tens 01 millions of dollars. More consideration
-------
See Response 8.2.1
See Response 9.1.2
See Response 8.5.2
See above Responses
should be given to whether the benefits to thl! environment and indirectly to
human health justify that level of investment of society's resources.
Perhaps the most important [specific problems with the plan] is the lack
01 any suitable disposal site lor dredged mtUerial which is proposed for
-nearshore disposal.-
EP A should recpnsider allowing more time lor natural recovery. coupled
with in.stitUlional conlrols. to work before any dredging occurs.
II dredging is necessary. thl! material should be disposed 01 using confined
aquatic disposal lor all areas within the sileo According to EPA's figures.
tl/lUalic disposal is aboUl 1/3 the cost 01 nearshore disposal and is much
mo~ likely to be leasible. given tire lack 01 nearshore disposal sites.
In short. we support thl! lollowing cleanup plan lor thl! Nearshore/Tidellats
sile: aggressive source conlrol to eliminate conlinuing sources 01
contami1UJlion. lollowed by a period 01 fUllUTal recovery. There is no reason
why this period should be limiled to 10 years il monitoring shows it is
mtZIcing satislactory progress. Dredging should be a last resort il natural
recovery is not mtzking headway.
Kaiser AJumiDum aad Chemica! CorporatioD (1989)
See Response 6.1.1
9.1.1
6.3.1
and 9.2.1
See Response 3.2.1
and 4.4.2
See Response 7.1.2
See Response 8.3.1
See Response 9.1.:
See Response 8.4.1
Ellective control 01 all signilicant sOW'ces must OCCUl' belore [undertaking J
remedial action. . . the FS [has notJ adeqUalely identified potential
sources. characteri::ed sources [including non-industrial sources J. or
. determined source loadings of contaminants to Commencement Bay. . .
[and) timetables lor remedial action do not give adequate allowance for
the completion 01 source control. . .
[T]he goal for the cleanup [should] be dlJfined based on what is necessary
to protect human health and the environment from significant adverse
impacts. . . cleanup should only be required in areas where an ecologically
significant (not statislica/ly significant) benefit can be shown.
[N)atural recovery [shouldJ be the preferred cleanup alternative except in
cases where it plainly will /tot protect human health and the environment in
the long term. . . It does nO( disrupt the existing ecosystem or resuspend
sedimellls. . . r alld J iJ appropriate jor all W'nall bay which has received
cOlllaminams for mall\! years from man.... historic sources.
The /terrative impacts of dredfJillff are 110/ adeouarei.v conSidered ill [fIe
Feasibiiit.v Slud.v and supportillff documents. . . (dredging j shouid I/ot ae
used. . . where the impacts e."Cceed the environmental benefits of remedia-
tion.
hr the FS. the seiecllon 'Jf ten years as an tlpproprlate Ilalural recoverv
;Jeriod appears to ne arbitrary. . . {the reaso,rs cited cio 1101/ r!xoial1l ',vnv
a lonr:er period is !tot preferable. , , the lonrr-lerm goal of "/10 ImoaC1" ',vas
'/Iwl/ded i,V :lle .-P:11:e1 Soul/a/ i'lal/ to 1e much IOl/rrer ilra/l .. :(:1/ . ',-'cr
perIOd.
[T Jhe costs 0/ the pre/erred remedial alternatives are greatly under-
estimated in the FS. In addition. the costs 0/ source control. . . and
mo"itoring costs were Trot irrduded. . .
-------
See Response 8.2.1
See Response 8.5.1
See Response 4.2.1
and 1.2.2
See Response 8.4.2
See Response 8.5.2
and 8.2.9
See Response 9.2.2
See Response 8.5.1
See Response 1.1.6
Comment noted
See Response 1.1.3
S~e 9ackground Section
[T ]he FS does not identify feasible disposal sites for dr-edged material,

It will be difficult for businesses located at the CBNT site to adeqWJlely
budget and plan for the fUJure if critical aspectS of the cleanup plan may
be changed mid-course.
A.ETs may be useful as predictive tools for tM PSDDA. program. . . [but
not for] determining that a particular sediment should be remediated. . .
Nevertheless, tM FS still cites PSDDA. as a justification for using A.ETs
fo, cleanups. Given tM different gOQ/s, 1M citalion is inappropriale.

The FS admits Ihal its area and volWM estimates are based on multiple
assumptions and are not likely to be accurale. . . FS decisions on remedial
action alternatives are not approprialely based on such weak information.
The FS does not adequalely justify nearshore disposal over confined
a.qualic disposal (-CAD-; lor the HHW [Head 01 Hy/ebos Waterway].
. The comments of Kmser and tM CSG aione are far reaching (as
necessitaled by the complexity and size oftM Site) and cannot truly be
adequalely addressed and responded to in just a few months [i.e., by
summer or early fail of 1989 ].

. . . tM agencies must. not [in a perfomrtllfa based ROD] place tM burden'
01 meeting a certain cleanup standard on tM PRPs unless at least one
alteT1UJlive is identified tJuu both meetS the standard and meets CERCLA's
requirements regarding effectiveness. implementability. and cost.
Considering [urban runofl, historic sources. .and NPDES-permiued
discharges exempt from CERCLA coverage], the Superfund should be
tapped to pay lor a least a portion of tM remedialion costS at Commence-
ment Bay.
Kaiser agrees that there are no feasible or cost effective treatment
alternatives available for the large quantities of di/UJe contaminants present
in Commencement Bay sediments.
A single Superfund action is not an appropriate lVay to address such a large
and varied area. If anything. do:ens of sma//er sites should have been
listed instead of one huge site.
(II jelleral. lhe ~tud\' of ,hI! C3NT Site process was cumpronused ;'.\'
IIOC soliciwll: illpuc from illdustry -- lite janies who s;wuiJ .:':'lltJ\V :itl!
mosc about what is feasible at the Sice. Tire agencies shouit.l .'tOW
.:moark on a prnfi(ram to correct Ihe7uscollCeptlOlls ,.e~araill~
Commencement Bay. .
See Response 7.2.3
Louisiana- Pacific Corporation (1989)
Tire SEDCAM moael I/eeds to account for arsellic losses from sedimems.
. . :;ite-,necriic \twiies 
-------
See Response 5.1.2
and 6.1.1
Deferred
See Response 6.4.1
and 6.4.2
The FS does not accuralely characterize arsenic sowces and loadings into
the head of the Hylebos. . . Sources contributing to Hylebos Creek must be
curtailed before any cleanup of sedimentS. . . since Hylebos Creek is the
largest contributor of arsenic in this immedi4te area.
The priority rankings in tM Integrated ActiOll P/QII do not reflect actual
colllributions of arsenic. . . Parties sJrouJd I'lOl ~ giNn lower priority on the
grounds th4t they are recalcitranJ.
T1r4 nalUOlion of sowce cOlllroltechnologies in the FS does not provide
sufficient consideralion of factors encountered 4t log sort yards and wood
waste landfills to hold th4tthe technologies are feasible at log sort yards.
Make Lumber CompaDY (1989)
See Response 9.2.1
5.2.1
ud 5.1.2
See Response 7.1.2
See Response 8.3.1
and 1.1.7
See Response 7.2.3
See Response 3.3.1
See Response 4.4.2
Se~ Response :'.1 A
See Response 4.1.1
See ResDonse 4.3.1
See Response 4..3.2
See Response 8.2.1
The implement4tion schedule suggested by the Feasibility Study (FS)
creates a substantial likelihood of recotfU1mi1ultion of rem4di4ted sediments
{beCl:AlSe/ . . . many of the potential sources of conlamilUllion have not been
identified. . . a number of {idDUified sources of contamilUllion/ htzve not
yet bem controlled. . . there is i1UZdeqruzu d4ta with respect to mDlIY. if
not most. point and non-point sources of contamin4tion.
The n4twal recovery of the sediments should be the preferred remedial
altenuuive. and should be abandoned only if absolutely necessary.
A dredge and fill operalion w.ould fwther. destroy present biological
communities. . . {and / would creale secondary contaminalion problems al
the site of disposal. contrary to the preselll Super Fund Policy to remediale
contami1l/lllls 0" site.
The sedimentalion rale estimated in tM FS ;s based upon assumptions with
out adeqUale dala. and may well be understaled.
. . . the goal of . . . "IlO adverse effects" . . . is not obtainable in an wban
environment. . . Commencemem Bay and its walerways CO.1lllOt be retunred
to the pristine stale they were in before 11T/l1I came to the Commencement Bay'
area.
A more realistic goal ill all urhan environment is IlO significam effect 1J11
biological resources.
The process by wilicn ,reallit I'lsks are 
-------
.
See Response 1.2.1
The cleanup goal has been created in a vacuum and is premature. The
Department of Ecology is obligated in the future to develope [sic] Puget
Sound-wide sedimenl standards for regulating discharges and for
determining when sediment remedial actions are necessary. Those
regulDlory actions should occur prior to the finalization of the FS. and
certainly before the issUJUIce of any Record of Decision.
See Response 2.1.1
Mardaac ShlpbuUdlal (1989)
See Response 3.3.1
See Response 9.1.2
While there does exist a problem to some degree. the implied threat to public
health and the health of the marine environment has been grossly overstated.
What is an appropriate and achievable level of cleanliness for an urban.
industrial waterfronl area? There is a balance that must be struck between
the adverse effects to the marine environment and the adverse effects to the
people who work at the businesses and live in the community.
{W Je should seriously consider eXlending the time horizon allowed for
natural recOYery to occur. We are dealing with a 100 year old proolem and
in relative terms proposing to solve it overnight.
Nadoaal Oceanic aitd Atmospheric Admiaistradoa (1989)
See Response 1.3.4
See Response 3.3.2
See Response ~,.3.:
See ResDonse 9.1.:
The long-term goal of "no acule or chronic effects on biological resources"
would be protective of NOAA trustee resources. [BecOJJ.Se] cost and
technical feasibility are factors that would be considered in the overall
evaluation of actions. . . {the goal] may not be achieved in all areas under
the Super fund cleanup.
The use of lowest AET values is probably the most appropriate general
approach to setting target levels in Commencement Bay. even though the
approach has not been fully developed. . . It is clear that AETs do represem
concentrations that are associated with biological impacts. Thus it can be
concluded that the AETs are clearly based Oil documemed effects. but may
easily underestimate the full range of injury that may be caused by coxic
substances [e.g.. chronic effects J.
The possibility exists {hat comhillatiolls of {wo or "n01'e \'UnSlanCilS ma~'
result ill greater :oxicil.1' {hall illdicated in' {he :ndivhiuai ..;£T ~'aiLles. ,Tn
the case of Cvmmeflcemem Br4y, ;IOWel/er, :he-iET.:' ,Ire ,:"'asea' 0/1 /occ;i ,jata
so (hat [he last COflcern shouid Il()( he ~ problem. 111 ..;.ddillOfl. :he ,eSl
;;rocedures llpon which [he AET ure hased ~Ire ;Jrooaol.l' {he :nOSI reliaole
and may be among {he most ~ensitive available. , , Filla"y, :he~ET
approach provides a means of I!valuatin~ lhe /leed for remediation 0/
\'edimems from deeper cores :hat mav /lot he comaielell' !eslaole :- usimr
hioiofocal :I/dicalors i.
The ,?roposed to-pear "Natural recover" "eriod ,.?roaosed ':1/ ..he:: S .'Jrese1!lS
,nme ',UOSlallllQl' ,yon/ems, , , ,-hecause;' ,)'uoerrlll/d :.!I:!SIQIW/I :;as JIll.\'
he en authorized ill i1/cremellls vi five years vr less. wilh {he slron~
implication that cleanup should be completed at many sites with ill lhat time
frame. . . No justification is presented. nor is any anaLysis given. for the
statement that a JO-year period presents an "optimal balance" between
cleanup-associtued disruption and the problems associated with the toxic
-------
See Response 7.2.1
and 7.2.3
See Response 9.2.3
See Response 9.1.2
See Response 7.1.1
See Response 7.1.3
See Response 1.1.1
See Response 8.4.1
Deterred
Deferred
iJeferred
.
substances {which by allowing J to continue will also continue co injur~
natural resources and threaten human health.
{T Jhe change in concentrations in the surface sediments in most areas will
be on tM order of a factor of two after 10 years of "recovery." This level
01 cbge is on the order of the precision with which the concentrations 01
substances in the sediments can be reliably measured. and within the
accura&y of tM {SEDCAM] model. AS a result. the potential for error in
meeting the cleanup goals if the recovery period calculation is allowed is
large.

{/]t may be difficull to determine afler 10 years that recovery has actually
taken place. /f not. will the PRP be allowed another 10 years to
demonstrate that the process is working? {This] could lead to substantial
failures to meet the cleanup goals.
While tM PSWQA does include the recommendation that natural recovery
be considered in cleanup action. it does not spedfy that 10 years should be
used and the consideration does not necessarily apply to Superfund sites.
In addition, tM contamination at this site was identified and has been
studies, with limited real action. for 10 years already.
Since {the natural recoyery] process is limiled to only the upper layer of
contaminated sediments (upper 10 em). any contamination in the deeper
sediments will be unaffected. This process is therefore defacto in situ
capping. In situ capping was rejected for ail waterways e."Ccept the St. Paul
because of the high likelihood that the sediments in ail of the other
waterway would be dredged for maintenance or new construction.
The proposed "natural recoyery" is simply a slow form of dilution. The
SD7ne result could be achieved withoul the delay and uncertainty that would
occur by ailowing in situ capping. The recovery period sets a precedent of
ailowing dilution as part 01 a Superfund cleanup action. This approach has
been clearly rejected at all other sites.
The FS is clear in recogni:ing that none of the confinement optiollS meet
the SARA preference for a permanent solution. as defined by reductions in
the toxicity. mobility. or volume of the colltamination.
{M lonitoring and maintaninance {sic I {of nearshore disposal sites J will
have to perpetuated [sic! /or ci.:l!turies {() come. {t is questiullabie ~viteliter
the costs 0/ this IUIlf:-lerm 0&.\1 ;lave been fairly incurporall:!a illto :hl:!
feasibility. \tucJy. slIlce It Ilopears ihaI olliy Il 3D-year perwcJ. .vas :ISCcJ.' c,;lIu
jor some sites. mOlUtoring is ,:osted for .he first 10 years.
In general. the {sampling mrd monitOring J guideLines are reasonaiJly lVeil
thought out. but could be more specific with regard lO the numbers 0/
stations that ma.v he needed.
The hioassa.v recommendatiolls are reasmrable. ,jut may '.veil .'Ieea UJ 'e
revisited in lhe not-loa-distant fUture as new hioassays are Jeveiooed. .
The j'laremem ill iJze appendi.'t i' p. .i- iO u/ ihe [megralea .-iCllO" ?laJl / :flat
the e."Cceedance of a single chemical ciemlup goal [in a marginally
contaminared area} may be negotiable does not seem to be supported in lhe
main body of the text. Since six of the nine problem areas have oniy two
or {one 1 problem substances. this provision would seriously weaken the
-------
See Response 9.2.3
potential cleanup and may lengthen the negotiation period. It should not
be accepted.
[W]hen the proposed JO-year clock for natW'al remediation starts is not
clearly stated. . . It is essential that the sequence of all events be clearly
established. .
Deferr~
Occidental Ghelllical Corporation (1989)
The [RI/FS] reports do not consistently and clearly distinguish that
[Occidenlal Chemical Corporation] is !1J1lthe idenlified source of the high
priority contaminant PCBs in the mouth of the Hylebos Waterway. . . [ajs
a result [of the detailed Remedial Investigation at the OCC Tacoma Plant
site] oec concludes they are not tlJ¥. soW'ce for PCBs to the Mouth of the
Hylebos.
See Response 1.1.2
Pennwalt Corporation (1989)
See Response 4.4.2
See Response 8.2.10
See Response 8.5.2
C::Jmment noted
:See ~esponse 3.5.1
[The] 8no effects8 standard is not realistic or achievable as a cleanup
standard for an urban waterway like Commencement Bay. Nor is it legally
required as a cleanup standard under section 121(d) of SARA. 42 U.S.C.
ss 9621( d), the current or proposed National Contingency Plan (NCP). or
EP A guidance documents.
[Anj alternative cleanup 'oal [is proposed]:' mitigate significant effects
to the aquatic ecology. . . Under this objective. only those sediments with
significant benthic depressions and which offer significant and measurable
ecological benefits would be identified as suitable candidates for active
remediation.
The FS does not identify a feasible or cost-effective remedial alternative
for the head of Hylebos Waterway. A modified institutional controls
alternative should be the preferred alternative for the head of Hylebos
Waterway. . . [requiringj removal oflly of the sediments that lIIouid exceed
cleanup standards after source controls. natural remediatiofl. afld
mainteflance dredging.
Confined aquatic disposal may be preferable to Ileanhore disposal for an,\'
sediments (hat require c.iredgil/!.[.
Tire FS correctly rejected treatmelll ilitemallves
A ;Jer formance ;'ased record 01 Jecrsion IS ,mI.l/ aopropnate ii :he
performance standard is based 0/1 a feasrble aJ/d (:ost-.:ffective aitemallve.
. . It is impossible to determifle whether the cleanup standards afld
perlormance criteria are feasible and cost-effective. as .CERCL..i U!Owres.
uniess {hey are tied co a ,1arllcular remedy.
(Plus additional commentS in :m attached report by Ke~nedy/ Jenks/Chilton (1989) following these
. ummary ':omments.)
-------
Pickering Industries IDC. (1989)
See Response 5.1.3
and 7.1.3
. See Response 3.3.1
See Response 2.1.1
Port 01 Tacollla (1989)
See Response 5.1.2
See Response 6.4.1
See Response 6.4.2
See Response 8.4.1
See Response 3.3.1
See Response 5.2.1
See Response 9.4.3
See Response i .:.3
We do not agree thal [City I walerway needs to be dredged. , . We believe
EPA should first co,"rol the sources of contaminalion. and then should
leaN tM City wtllerway alOM for all exzended period of time. for example.
10 yetZ1'$ or more. to see whetJru tM pollutiorr 1uzs aboJed 1U1lurally. . . [iJf
it hQ.$ not. a decision can then be mJlde abOUl dredging.
We are very concerned thalthe standards tM feasibility study uses are too
high for the [City J Walerway. .
[ Apparemly J the feasibility study tlltempts to clean the City walerway so
thal English sole do not develop cancerous tumors. . . a person would have
to eal absurdly large quantities' of fish liver for their entire lives in order
to conuact cancer from such fish. . . this is totally unrealistic and presents
and inappropriale standard by which to determine whether dredging is
necessary.
A particular concern is the inadequacy of the dala base for historic and
currem sources.
IT Jhe FS overestimates the feasibility and effectiveness of source control
measures.
The FS establishes a goal of 60-95% co,"rol of all sources. It is not clear
whether the 60-95% requiremem will be additional to source control
measures implememed since R/ sampling in 198$ . . . lor J how the goal
will ~ verified due to the lack 0/ baselilW dala.
The considerable costs 0/ source co,"rol. monitoring. and /Ulure implemen-
talion are .not included in the FS.'. . The cost estimale of 528 million
significantly underestimales the cost of implementing the preferred remedial
action [which is estimaled to bel three to four times grealer than staled in
the FS.
[T lhe FS' proposed cleanup goal lor this Superfwrd site. wrlike cleanup
levels in ather urban marille sites. requires the equivalent 01 pristine
conditiuns. . . [lhe J propused deaJrup staJrdards . . . are Iwt altaillanle !lor
~ustainab'e. withill Contntellcentem Bay's urban Hut ill!: .
The FS performance standard dues lrot ackllowledge lhe impact (ll
recontaminalwn from conwlumgwurces [illciuaim: urnwr runOff!.
The relalionship between [Ecology's I impiementalion ol sediment impact
:ones and cleanup stwldards !leeds [0 he addressed.
Use of [he SEDCAM model (which has /lot neen fieid tested) ;0 oredict
IUlure sediment conditiulls may have led to illcorrect conclusions concemimr
:Jle ."'rnoosea u!ntediat '.;CtlOIlS.
-------
See Response 4.1.1
and 4.2.1
See Response 4.3.2
and 4.3.1
See ReSponse 4.2.2
See Response 4.4.2
and 4.3.1
See Response 2.1.1
See Response 9.3.3
See Response 8.2.9
See Response 8.2.1
See Response 8.2.3
Deferred
See Response! .2.4
See Response 0.1.1
'~ee ~esDonse 5.:.:
. . . the AET meth.od is appropriaJe only as a screening tool to identify
areas warranting more thorough environmental investigation. . . [because}
AETs cannot demonstraJe specific cause and effect relaJionships. AETs
also cannot predict thal an environmental effect will be caused by levels
of chemicals thal exceed the ..tET level.

The ..tEl" artificially ascribes all changes in benthic communities as being
equally adverse. and assumes all changes are due to the presence of
chemical contaminants.
Use of ..tEl" is particularly questionable in intertidal areas.
Given the probable need to proceed with some cleanup. and in the absence
of consensus on sediment 'quaiity measurementS. the Port supports
applicalion of the AET approach defined in the CBG/ ENSR report.
provided thal proper consideraJion of physical factors is given during
cleanup decisions.
The FS overestimales the relalive hUl1fQ1f health risks of sediment
contaminalion in Commence~nt Bay. . . by using unrealistic assumptions.
Plans for remedial dredging should recognize plans for navigaJion
dredging. When navigaJion needs are considered, the total volume of
sediments requiring confined disposal will be much larger than thal
predicted solely for remedial dredging.
Feasible and cost-effective straJegies for removing contaminaJion under
[pie,.] structures are not identified nor discussed [although} capping or
removal of surface sediments involves a high risk of pier structlUe or slope
failure. . . methods are infeasible. . . untried and costs range from $1.7
to $5.5 million.
The FS does not identify cost-effective and feasible disposal sites for the
large quantities of sedimentS designaJed for cleanu.p.
The present timetable for cleanup will result in [proposed disposal site in
Blair WaJerway} Slip J IIot being available. . . other Port owned disposal
sites are also not available.
[T }he agencies [should! consider further the following three (disposal!
sites: J j the Wheeler Osgood Waterway: 1) (he Saillt Paul lVaterwav: unci
3) the Hylehos Disposal Site -= I (comhi1!ed llse ',vail (isner/e) ,:nncnccmem:,
{n particular. {he Port is L'oncerned about lhe rer:ulacor" ,tatus 0" ,ile
{megraled ,4Cllon Plall. . . ;Vhal is lhe process for public L'omrltelll .)/1 ,he
lAP?
.4 svstematzc look at ail sources. {heIr contrihUlio1!. <.ier:ree 0/ ,zchie,'able
control. and ;riorities (or control \'ilOuid he :ie,1'ined. Tlte irame!vori<. ,'or
,uch a pian should he -lstablished [lnor co lhe aOD. . .
,"?esoiUlioll II" ,\ource '.'Olllrol :lIIa clrall/ar:e :~iall1l111f! issues ,"Cla.lCa '0 :.'lC
uplands must OCClU prior to issual/ce of a ROD for submerged portIOns of
the site. . . Without a RI/FS and a ROD for source control. PRPs call1lOt
obtain CERCLA resolution of Superfund liability.
(Expansion of commentS followed in attachmentS N Analysis of Proposed Surface Water Source
Control RequirementS for the Commencement Bay Ne:ushore/Tideflats Superfund Area" by R.R.
-------
Horner; Hart Crowser review .letter, "Contaminated SedimentS on Side Slopes of Sitcum Waterway"
by Berger/ ABAM Engineers; "Review of Various Aspects of Commencement Bay Nearshore/
Tideflats Feasibility Study" by Berger/ ABAM Engineers; and "Assessment of Risks Associated with
Eating Recreationally Harvested Puget Sound Seafood- by L. Williams and C. Krueger; and public
testimony at 6 June 1989 meeting by J. Terpstra.)
Premier Iadustries IDe. (1989)
See Response 6.1.1
and 7.1.2
~ Respo~ 9.2.4
Deferred
PSWQA (1989)
See Response 1.3.1
See Respo~ 1.2.1
See Response 7.1.2
See Response 7.2.3
See Response 6.1.1
Suggestion noted
See ResDonse 9.4..3
{S]ourc~ control {including non-industrial sources] and nIJJural remedia-
tion appeOl' to ~ tM most economical IlNi effective means for cleaning up
Commencement Bay.
Further testing and evalUlZlion is mandated to idenlify and qumrtify "Toxic
Hot Spots" . . .

AS an dJiernati"~ to r~mo,ing approximlJJely 11.000 cubic yards of
contaminlJJed soil and find;"g a disposal site {for Wheeler-Osgood
s~di1flJ!1Il], why not construct a sea wall and fill in the wIJJerway with
approJCimlJJely 7',000 cubic yards of dr~dged mlJJerial from the City
Waterway IJfId cap with clean soil.
The long-term sediment cleanup goal selected for Commencement Bay is
also the sedime1flgoal of the Puget Sound Water Quality MlJflagement Plan
. . . The AUlhority supports adoption of this goal.
The AUlhority supports tM use of the appare1ll effects threshold method
( A.ET) to estimate chemical concentrations associated with harm to marine
life. The use of bioassays to refine areas and volumes for remediation is
also supported.
The Authority. . . supports the use of natural recovery. after source control
has been achieved. for portions of the sites that will recover within ten years.
The dilution and burial of moderatel.v contaminated sediments by clean
sediment is IJfI acceptable way to accomplish the cleanup goal.
Authority staff have questioned. , . [whether f the rates 0/ recover.v
predicted by the [SEDCAM J model are tuo slow and ullderestimaze the rale
oJ' lIatural recovery.
The application o.f ail kllown, available. and reasonable methods IJ'
treatmem 10 ail pOint sources illld rir:ornus appiiCallOlI ,n ,;est ..nallaf!emem
practices to nonpolm sources is required.
Improved spill pre\'ention programs throughout ,he Jraillar;re has in ana
Improved spill response ,,:apabililles should he addressed! iI/ !lIe tAP,',
fl the comlllued discharr:e (that ,\'tlll re.
-------
See Response 8.3.2
See Response 9.5.4
See Response 3.3.1
The Authority supports the use of a range of remediation techniques.
depending on site conditions. . . {bUll The policy of no net loss of wetland
habitat. as adopted by EPA. the State of Washington. and the Puget Sound
Plan, mwt be met.
Monitoring [of cleanup and disposal sites] must be required.
The Authority supports cleanup of Commencemem BAy because of the public
benefits thai will result. . . [from mitigation of harm toJ natural marine
life. . . I and reduction oil human health risk associated with eating
seafood.
See Response 3.3.1
PU8et Sound Plywood, Inc. (1989)
See Response 6.6.1
See Response 6.6.1
and 7.1.2
See Response 8.2.1
Our first concern is thalthe Feasibility Study's cleanup goals ar~ unrealistic
bectlUS~ they lailto adeqU4lely account lor the present and luture uses of
Commencement Bay. .
[T JM Feasibility Study does not place sulficient emphasis upon stopping
ongoing pollution at its source and allowing nalural recovery processes to
remedial~ much of the existing sediment pollution problem.
~
[SJource control should be lully implemented zd. tested before sediment
remedial dredging occurs.
[T Jhe Feasibility Study fails to identify feasible and cost-effective
response actions because. among other matters. it does not clearly and
. convincingly identify disposal sites for contaminated sediments.
See Response 1.1.4
Puyallup Tribe o( Indians (1989)
See Response 1.1.3
See Response 1.1.1
~cquest noted
See Response 1.3.5
See Response 1.3.7
See ResDonse ! .3.2
See Response 3.3.1
{T Jhe Tribe has not been provided with a meaningful opportunity to
participate in (the FS] proceedillg.
The FS should take imo consideration EPA's ornonsed NCP which
implements SARA.
The goals af the FS must he permaneirt cleanup.
The Trihe formally re(JueSlS Joc:lmemat;mr demmrSlraWl!! :har .' c? .;..\ ,;m.i
Ecologfs comracwrs.i flQVe I/() l'un/licr 1)/ [mereSl \viltz "';IlV ?:Jlelllw;l\'
Responsible Parlv rat the C3/NT ,ite /.
Tribal standards must ;,e cOllsidered as ARARs
The Puvallup Lalld Claims Sealemem ,4f?reemenc , , . mUSl he ::ollsrdered
as all ,..J.RAR.
EPA's nrnrmsed ~"axim/1m COllfamillmimr L;!1'pl (,oals must he adoOled ilS
:l :;rnul/dwarer ,-iR;iR tllnc i.lS' (; TEC,'. . , ?"he imerrccm :llaiaJ/~cli!!!Ous
Freedom Act. the NariOlrai Hisroric Preservatio/r Act and Trrbai srandards
must be considered for all locations impacting Tribal resources.
. . . Commencement Bay {must] be fully remediated. and protected ,as an
exercise o{ . . . public trust.
-------
See Response 7.1.1
See Response 7.2.3
See Response 8.4.1
See Response 1.3.4
See Response 1.1.1
and 1.3.5
See Response 2.1.4
. and 2.1.6
See Response 6.1.1
[T]he identification of contaminated sediments [may be] greatly under-
estimated. . . capping dangerous sediments in place. . . will not provide
adequate human and environmental protection.
The US6 of the SEDCAM model is likely to underestimate recovery rates.
The US6 of a 10 percenJ discounJ ral6 ONT a 30 year period does not
a&Cllrately reflea the 10m! term costs of motritoring and mainJaining a site
through institutional controls.
{A]lI of {the niM criteria used to evalUJ1t6 the alternatives] are not enJitled
to equm weight. Protection of human health and the environment must be
the most important criteria.
The Puyallup Tribe finds th6 recommended remedial a&tion alternative
totally una&ceptable . . . {because it] will not prt!vent bioa&cumulation . .
me6t tribal standards. . . [and] is not a pemument solution.
The FS !mIa address cumulative health imptlCts to Tribal families that rely
on/ish lor a I01'g6 ponton 0/ tMir dim. t1IId to fish4Tmen that spend a lot
0/ ti1M fishing within COmlMnC611WnJ Bay. . . {including] effects of
dioxins. hetlYy metals. and thousands of OIMr chemicals {besides PCB
mixtures] . . . Cumulative health rislc.s from m.I. dangerous chemicals must
be addressed.
A source control strategy must develop specific plans for [immediate}
control of permitted. unpermitted point source. and non point source
discharges. . . before significant sediment remediation is undertaken.
. (Plus numerous additional specific comments and attached Sl1perfund Memorandum of Agreement,
Puyallup Tribal Water Quality Program, Letter documenting Tribal ARAR, resolution requesting
inclusion of Tribal Environmental Standards, and U.s. EPA Drinking Water Regulations and Health
Advisories.)
Sierra Club (1989)
See Response 3.3.1
and 6.1.1
See Response 1.1.2
'See Response 3.3.:
While we recogni=e that industry has been located ill this area for a good
many years. we must flot =one the bay imo cleQJI and dirty areas. bUt rather
assure multiple uses vf ihe bay. . . Appropriate techllologies must he
utili=ed to prevem cOlllillued cOlllamillatimr 0/ (hese waters alld adJolllill~
sediment.').
Tite Sierra Club supports lhe lonr:-term CieQJ1Up goal (0/ I/O adl.'erse
4fecrs I. . . 0/ (he several potemiai approa&nes for establisnim: ~eaimellC
quality .values. the AET approa&h seems the best in measuring acute harm.
. . SPecific cleanup plans must go he,vond the currem AET assessmem (0
, include a complete assessment 0/ chronic," subletnai) impacts aJld \'houid
address these impacts Ilf lhe R.ecord 0/ Declsion.
rr further refilfemelll does IIOt ai/ow comolete assessmelll of 4ETs .1'01'
;hrnmc ~'''fccts. '\le rccommelld (hat ';ome L'!!CmtCal :'OIlCCmratlOfl'CII :0 "lie
izwrdred umes beiow lire lowest .-jET $houid be setected as the lfrresiroid /01'
cleanup and monitoring. to provide a margin of safety and to ai/ow for the
wrmeasured chronic effectS mentioned above.
-------
See Response 1.1.1
See Response 9.1.2
See Response 6.1.1
and 9.5.4
{A}ll cleanup ellorts should meet the requirements 01 SARA and must be
permanent. . . Because {permanence is not assured until specilic disposal
sites can be evaluated} we c.annot support the prelerred alternative.
II r~co'ery cannot ~ demonstrated at {1UIlural recovery sites} in the next
liv~ y~ars. this approach should be reevaluated.
{A} UC!l1JL source control program {is supported} . . . sediments. . .
slrouJd be monitored lor potential re-COnlQmi1Ullion.
Comment no~ed
Simpson Tacoma Kraft Compaay (1989)
Information noted
Information noted
Information Doted
See Response 8.2.7
Simpson agrees with the prelerred alternative and generally agrees with
the conclusions in the FS.
{ThDe is incon'ectJ {aJtlribulion 01 historical problems to Simpson. which
acquired the mill . . in 1985 {rather than to tM Tacoma KraIt Mill and raw
1PUJlerials J.
{O }ucdated inlor1PUJlion {is used in SOI'M clUes] r~garding sourc~ control
and remedial action at tM sit~ {in th~ St. Paul Waterway area].
{S Jome inaccural~ and inconsistent conclusions {ar~ 1NIIi~ J on the summary
charts {lor th~ waterway].
{The FS incorrectly} suggest{sJ that a new technology might be
implemented rather than the preferred remedy evaluated and identified in
the FS.
See Response 7.1.3
Superior 011 Compauy (1989)
See Response 3.3.1
[nformation noted
Superior Qil agrees that {the "wait and evaluate" approach for the mOUlh
of City Waierway} is reasonable. cost effective and protective of human
health and the environment.
The [long-termj cleanup stmrdard of "no adverse effects" does !rot
recognize. . . [the fact thatf City Waterway is unquestianably located in
the heart of an industrial area. , , it is probably an unattainable standard.
(T Jhere is IlOthing in the RI or FS that establishes a fillk. ,;,etween Suner/or
Oil property aJld the comamillatioll /owrd ill ,he C:ty :VaterwQv ,',ics plte !JIle
contradictor" section ill the F S that should he corrected j.
Tacoma-Pierce County Chamber of Commerce (1989)
See Response 6.1.1
Jnd 6..3.1
See Response 8.5.3
Ecology's and EP.4.'s fir.'it objective should he to comrni (!:ctstimr wurces of
poliUlion !O Cummencemem 3a.v ne/ore requiring that indu.scrl.'. {he C;'cy. :he
Pnrt and !andowller.'i ill vest an ,!stimated 5:8 million Oil ~ediment ~emediai
:iction.
No remedial a.ction should be a.llowed. u.silrg private or public fwtds. wttil
the bf!nefits of action are presented for public review and the benefits
clearly e."Cceed the costS.
-------
See Response 1.1.6
See Respoue 3.3.1
See Response 8.4.1
II . . ..sediment remedial action should proceed alter lhe public comment
period closes. lhen lhe only reasonable approach would be to provide lor a
substantial CERCLA-Iunded percentage 01 the cost 01 remedial action.
The govemmelll should not aim to re""" tM Bay to -natural- conditions.
. . EPA's announced goal 01 -no adNrs6 impll&t. is too stringent and lails
to appredlJle tM reality 01 our urbalt s6tting.
EPA's ligure 01 $28 million to cle~ tM Bay is an underestimlJle [because
01 higher costs lor altemlJliv6 disposal Sit6S. and sampling and analysis].
Tacoma-Pierce County Health Department (1989)
. See Response 6.1.1
and 6.3.1
[A] grelJler emphtlSis needs to be placed on source control in the -inte-
grated Action Plan- and a lully lunded. pro-O&tiV6. resource intense. source
control program be developed and impl611W11l6d. .. We would only be
mpporti'6 01 sedimelll remo,al Of' capping lollowinll a re-evalumion 01
tM SU&cess 01 tM above-d6scrib6d SourC6 cOlllrol program.
Tacoma-Pierce County Superfund Clt1zeu Adylsory Co...lttee (1989)
See Response: Future
Community Relations
Plans section
See Response 1.1.1
and 6.1.1
It is unclear how the agencies plan to promote public involvement in the.
cleanup process. bul it is critical tJuzt tM general public have access to
specilic and accurate inlormlJlio" and are able to help shape decisions. .
We hope documents are made available to members 01 the general public
at little or no cost. and that it is easy lor the public 10 obtain them.
The CAC suppons the long-term cleanup goal . . .The CAC also leels lhm
all cleanup ellorts should be permtlMlIl. and that long lerm monitoring is
essential. In addition. the CAC supports implementation o{ a w:Jl!lJl. source
control program.
See Response 1.2.3 . [T Jhe Department o{ Ecology and the EPA should continue to monitor
activities in [areas other than lhe nine high priority problem areas j. and
should require site characteri:ation and remedimion prior to development.
U.S. Army COE (1989)
See Response 1.1.:
Deferred
See Response 3.2.4
See Response 8..2.5
and 9.5.1
Some referellces [to the PSDDA study Jocumems j are 1/0l wiaif.I' correct
WId i1vents suosequelll to [he preparalllJll uf lhe .ext have resuilea 'Il c'i1am;es
[0 [he PSDDA manaSfemem pl(lJr. portions of which are refere1/ced ill ihe
FS [e;tt
Proposed modificalions af the PSDDA procedures r lor anal.vsi~ 0/ dredSfill.Sf
cut sampiesj in hiSfh priority areas, . . Jo flot appear [0 be .:eci'l1licailv
defensible and couid result ill wrnecessar')' costs.
{Il the interest of consistency amnns: [he various sediment .7rn(!rams.
:on.\'laerallon .,nOlud he :;!vell :0 (.aoOtlllq :fle L'urrem /'SDDA :':Sl ~rolOCOIS
i.lJla ;;ulaeiilles for i1stabiisirillg \Viral constitutes Ll nioassay ., flu'.
Siting 01 a deepwater CAD facility. . . should be undertaken. . . with
considermion given to the PSDDA disposal siting process and the wide
range 01 siting lactors which mwt be lake" into account.
-------
See Response 3.3.1
USG Interiors, Inc. (1989)
See Response 8.5.1
See Response 6.1.1
and 6.3.1
Deferred
See Response 8.2.10
See Response 8.2.1
See Response 8.4.1
Achieving [a "no adverse impact" j cleanup standard is neither appropriate
nor achievable in Commencement Bay. . . The environmental concerns of
Ecology and USEP A must be balanced with economic considerations. .
With r~sp«t to the use 0/ a performance-based Record 0/ Decision. . .
CERCLA requires that a remedy be chosen prior to the beginning 0/
ron.edial aclivities. Ecology and USEP A. there/ore. m4Y ,",t implement or
r~quir~ the implementation 0/ remedial measures ,",t speci/ically embodied
in itS ROD.
All [point and non point ] source discharges must be controlled prior to the
implementation 0/ containment measures.
Source cOnlrol coupled with 1UJlural recovery assisted by high tides and the
removal 0/ up to two-thirds 0/ cOnlamiMled sediment through m4lnlenance
dredging may be sufficient to elimiMle cOnlamiMled sediment and obviate
the need /01' further remedial dredging.
[T ]he dredging and disposal options proposed /01' the Head 0/ Hylebos
Waterway problem area both threaten to increase rather than reduce the
negative impactS 0/ existing contaminated sediment and are technically
infeasible. . . Watertighl clamshell dr~dg~s as well as other Japan~se
dredging technologies (mechanical. hydraulic. pneumatic) should be
investigated to reduce the potential resuspension 0/ sediment.
[N]o practical [nearshore] disposal site has yet been identified.
Given the scope and complexity of the proposed cleanup, [the $28 million]
costS appear to be grossly understated.
See Response 9.3.1
Washington Public Ports Association (1989)
See Response 3.3.1
.:See R.esponse 0.'::.1
See Response i ,2..3
S~e Response 4. j .1
S~e Response ..U.2
See Response 8.2.1
It is very important that [maimellallCe] dredged material. , , which passes
the Puget Sound Dredged Disposal Analysis (PSDDA) requirements be
allowed to go to the PSDDA disposal sites.
WPP..t questions the goal of "110 adverse t!l.fects Jue to sedimem I.:omamilla-
tioll" as a cleanup goal
The study should L'OIllaill a more .felaifed cost .!valuatioll ""O/' :lldivlI.iw.lt
wurce control measures,
[Ilt ma.v he deslTabie to /wther test the predictive ability 0/ the SEDC.-lM
model hefore committinrr to remedial actions in ten years. . .
{T/he pores ~uppore !the use o/4.ET i (lS a screenimf coo is : as .vas Jone
in the PSDDAHudv). However. :ve a.re ~'onC(!T1l(!d with the :lse O( ..£T'.;
as a cleanup Handard. . .AET\ cannot he ,Jsed to .nredict cause and t!(fecc
. , . AET do (lIot} clearly illdicate the ecological reievance of ievels of
comaminmion that exceed AET levels.
. [W]e are very concerned about the !tick of disposal sites for the volume of
sediments that may be dredged. , . establishing a superfund disposal site
within an urban area will be a very difficult task , , .
-------
VI. REFERENCES
GENERAL REFERENCES
Barrick, R., S. Becker, L. Brown, H. Beller, and R. Pastorok. 1988. Sediment quality values
reimement 1988 update and evaluation of Puget Sound AET. Final report. Prepared for the U.s.
Environmental Protection Agency, Puget Sound Estuary Program, Office of Puget Sound, Seattle,
W A. m Environmental Services, Bellevue, W A.

Becker, 0.5., G.R. Bilyard, and T.C. Ginn. 1987. Concordance betWeen laboratory sediment
bioassays and the characteristics of benthic macroinvertebrate communities in Commencement Bay,
Washington. Unpublished manuscript prepared for presentation at the Seventh International Ocean
Disposal Symposium in Wolfville, Nova Scotia. m Environmental Services, Bellevue, W A. 28 PI'.
Becker, D.S., R.A. Pastorok, R.C. Barrick, P.N. Booth, and L.A. Jacobs. 1989. Contaminated
sediments criteria report. Final Report. Prepared for the Washington Department of Ecology,
Sediment Management Unit, Olympia., W A. m Environmental Services, Bellevue, W A.

Chapman, P.M., R.N. Dexter, R.M. K.ocan, and E.R. Long. 1985. An overview of biological
effects testing in Puget Sound, Washington: methods, results, and implications. PI'. 344-362. In:
Aquatic Toxicology, Proceedings of the Seventh Annual Symposium. Spec. Tech. Report 854,
American Society for Testing and Materials, Philadelphia, PA..
Chapman, P.M., R.N. Dexter, and E.R. Long. 1987. Synoptic measures of sediment contamina-
. tion, toxicity and infaunal community composition (the sediment quality triad) in San Francisco
Bay. Mar. Ecol. Prog. Ser. 37:75-96.
DeWitt, T.H., G.R. Ditsworth, and R.C. Swartz. 1988. Effects of natural sediment features on
survival of the phoxocephalid amphipod, Rhepoxynius abronius. Mar. Environ. Res. 25:99-124.
ENSR. 1989. Technical review and comments for the record. Commencement Bay Nearshore/
Tideflats Remedial Investigation and Feasibility Study. Prepared for the Commencement Bay
Group (ASARCO Inc., City of Tacoma, General Metals of Tacoma. Kaiser Aluminum, Murray-
Pacific Corporation, Pennwalt Corporation, Port of Tacoma). ENSR Consulting and Engineering,
Redmond, W A.
Gahler. A.R.. 1.M. Cummins. IN. Blazevich. R.H. Rieck. R.L. Arp. C.E. Gangmark. S.V.~L Pope.
:md S. Filip. 1982. Chemical contaminants in ~dible. non-salmonid fish :lnd crabs t'rom
CJmmencement aay. Washington. EPA-
-------
Pastorok, R.A. 1988. Guidance manual for assessing human health risks from chemically
contaminated 1ISh and shellf'ISh. Final report. Prepared for U.s. Environmental Protection Agency,
Office of Marine and Estuarine Protection, Washington, DC. m Environmental Services, Bellevue,
WA. .
.. Pearson, T.H., and R. Rosenbera. 1978. Macrobenthic succession in relation to organic enrichment
and pollution of the marine environment. Oceanogr. Mar. Bioi. 16:299-311.
Pierce, D.S. D.T. Noviello, and S.H. Rogers. 1981. Commencement Bay seafood consumption
study. PreliminSilry reports. Tacoma-Pierce County Health Departmen~ Tacoma. W A. 11 pp.
PSWQA. 1988. 1989 Puget Sound water quality management plan. Puget Sound Water Quality
Authority, Seattle, WA.

PTI and Tetra Tech. 1988a. Elliott Bay action program: analysis of toxic problem areas. Final
report. Prepared for the U.s. Environmental Protection Agency Region 10, Office of Puget Sound.
PTI Environmental Services, Bellevue, W A.
PTI and Tetra Tech. 1988b. Everett Harbor action program: analysis of toxic problem areas.
Final report. Prepared for the U.s. Environmental Procection Agency Region 10, Office of Puget
Sound. Tetra Tech, Inc., Bellevue, W A.
PTI. 1988. Commencement Bay nearshore/tideflats integrated action plan. Public Review Draft. .
Prepared for Tetra Tech, Inc.. and the Washington Department of Ecology. PTI Environmental
Services. Bellevue. W A.
PTI. 1989. Commencement Bay Nearshore/Tideflats Feasibility Study: Development of Sediment
Cleanup Goals. Final Report. Prepared for the Washington Depanment of Ecology and U.S.
Environmental Protection Agency. PTI Environmental Services. Bellevue, W A.
Rygg. B. 1985. Effect of sediment copper on benthic fauna. Mar. Ecol. Prog. Ser. 25:83-89.

Rygg. B. 1986. Heavy-metal pollution and log-normal distribution of individuals among species
in benthic communities. Mar. Pollut. Bull. 17:31-36.
Tetra Tech. 1985. Commencement Bay nearshore/tidetlats remedial investigation. Final report.
EPA-910/9-85-134b. Prepared for the Washington Depamnent of Ecology and U.S. Environmenml
Protection Agency Region 10, Office of Puget Sound. Tetra Tech, [nc., BeUevue, W A.
Tetra Tech. 1986. Development of sediment quality values for Puget Sound. Prepared for
Resource Planning Associates/Puget Sound Dredged Disposal Analysis and Puget Sound EstUary
P:-ogram. Seattle. W A. Tetra Tech. Inc., Bellevue. W A. !:9 pp. + appendices.
Tetra Tech. 1988. Guidance manual for assessing human health risks from chemically
.;ontaminated fish and. sheJIfish. Final Report. Prepared r'or U.S. Environmental ?rotecuon
Agency, Office of Water, Washington, DC. PTI Environmentai Services, BeHevue. W A.
U.S. EPA. Technical support document for water quality-based t~xies control. EPA -140/4-,35-
032. U.S. Environmentai Protection Agency, Office of Water. Washington. DC. 75 ;Jp. ....
appendices.
~J.S. :?A. : 988. gr1efin~ ~eoort 1m tne';oparent Effects Threshold :lDproach. .)uominea:o :l1e
EPA Science Aavisory Board by U.S. Environmentai Protection Agency Region 10, Office or" Puget
Sound. PTI Environmental Services, BeUevue, W A. 57 pp.
Versar. 1985. Assessment of human health risk from ingesting 1ISh and crab from Commencement
Bay. . EPA 910/9-85-129. Prepared for the Washington Department of Ecology under contract to
the U.S. Environmental Protection Agency, Washington, DC. Versar, [nc., Springfield, VA.
-------
Williams, L.G., P.M. Chapman, and T.C. Ginn. 1986. A comparative evaluation of sediment
toxicity using bacterial luminescence, oyster embryo, and amp hi pod sediment bioassays. Mar.
Environ. Res. 19:225-249.
COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD
AOL Express, Inc. 1989. AOL Express' comments on Commencement Bay nearshore/tide flats
feasibility study.
ASARCO.
study.

ASARCO. 1989. ASARCO Tacoma smelter remedial investigation.
1989. ASARCO's comments on Commencement Bay nearshore/tideflats feasibility
American Savings Bank. 1989. American Savings Bank's comments on Commencement Bay
nearshore/tideflats feasibility study.
Buffelen Woodworking Company. 1989. Buffelen Woodworking Company's comments on
Commencement Bay nearshore/tideflats feasibility study.

Champion International 1989. Champion International Corporation's comments on Commencement
Bay nearshore/tideflats feasibility study.
Citizen Letters. 1989. Comments from the general public on Commencement Bay nearshore/ .
tideflats feasibility study.
City of Tacoma. 1989. City of Tacoma's comments on Commencement Bay nearshorejtideflats
feasibility study.
Commencement Bay Group. 1989. Commencement Bay Group's comments on Commencement Bay
nearshore/tideflats feasibility study.
DNR. 1989. Washington Department of Natural Resources' comments on Commencement Bay
nearshore/tideflats feasibility study.
DOT. 1989. Washington Department of Transportation's comments on Commencement Bay
nearshorejtideflats feasibility study.
Dunlap Towing Company. 1989. Dunlap Towing Company's comments on Cummenc~ment Bay
:1earshore/tideflats feasibility study.
~oss \1aritime Company. 1989. Foss \1aritime Company's ;;omments 1m Commencement Bav
:1earshoreitideflats feasibiiity stUdy.
G~neral Yfetals.
teasibiiity study.
!989.
General Metals' comments on Commencement Bay nearshore/tidetlats
Griffin Galbraith Fuel. 1989. Griffin Galbraith Fuel's comments ,)n Commencement gay
1e:ushore/tideflats feasibility study.
Jones ChemiQis, (nc. 1989. Jones Chemicals, [nc.'s comments on Commencement Bay nearshorel
tide flats feasibility study.
Kaiser Aluminum and Chemical Corporation. 1989. Kaiser Aluminum and Chemic:1l Corporation's
comments on Commencement Bay nearshorejtideflats feasibility study.
-------
. .
Louisiana-Pacific Corporation. 1989. Louisiana-Pacific Corporation's commentS on Commencement
Bay nearshore/tidefIatS feasibility study.
Manke Lumber Company. 1989. Manke Lumber Company's comments on Commencement Bay
neanhore/tideflaa feasibility study.

MartiDac Shipbuilding. 1989. Martinac Shipbuilding Corporation's comments on Commencement
Bay nearshore/tideflats feasibility study.
NOAA. 1989. National Oceanic and Atmospheric Administration/Ocean Assessments Division's
comments on Commencement Bay nearshore/tidefIats feasibility study.

Occidental Chemical Corporation. 1989. Occidental Chemical Corporation's comments on
Commencement Bay nearshore/tideflats feasibility study.
Pennwalt Corporation. 1989. Pennwalt Corporation's comments on Commencement Bay nearshore/
tideflats feasibility study. .
Pickering Industries Inc. 1989. Pickering Industries' comments on Commencement Bay nearshore/
tide flats feasibility study.
Port of Tacoma. 1989. Port of Tacoma's comments on Commencement Bay nearshore/tidefIats
feasibility study.
Premier Industries Inc. 1989. Premier Industries, Inc. 's comments on Commencement Bay
nearshore/tideflats feasibility study.
PSWQA. 1989. Puget Sound Water Quality Authority's comments on Commencement Bay
nearshore/tideflats feasibility study.

Puget Sound Plywood, Inc. 1989. Puget Sound Plywood, Inc.'s comments on Commencement Bay
nearshore/tideflatS feasibility study.
Puyallup Tribe of Indians. 1989. Puyallup Tribe of Indians' comments on Commencement Bay
nearshore/tide fIats feasibility study.
Sierra Club. 1989. Sierra Club's commentS on Commencement Bay nearshore/tidefIats feasibility
study. .
Simpson Tacoma Kraft Company. 1989. Simpson Tacoma Kraft Company's comments on
Commencement Bay ne:lrshore/tidefl:ltS feasibility study.
Superior Oil Company. 1989. Superior Oil Cumpany'<;.:omments .un Commenc2mem aay
nearshore/tideflatS feasibility study.
Tacoma-Pierce. County Chamber of Commerce. 1989. Tacoma-Pierce County Chamber of
Commerce's comments on Commencement Bay nearshore/tidetlatS feasibility study.
Tacoma- Pierce County S\.Jperfund Citizens .Advisory Committee. 1989. Tacoma- ?ierce County
Superiund Citizens Advisory Committee's ..;omments on Cummencement Bay nearshore! tideilats
feasibility study.
TPCHD. 1989. Tacoma-Pierce COUnty Heaith Department's ..;ommentS on Commencement day
nearshore/tideflatS feasibility study.
U.S. Army Corps of Engineers. 1989. U.S. Army Corps of Engineers, Seattle District's comments
on Commencement Bay nearshore/tidefIatS feasibility study.
-------
usa Interiors, Inc. 1989. USG Interiors, Inc. 's comments on Commencement Bay nearshorel
~idetlats feasibility study.

Washington Public Ports Association. 1989. Washington Public Ports Association's comments on
Commencement Bay neanhore/tidetlats feasibility study.
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A1TACHMENT TO APPENDIX B
-------
.
Community relations activities have been conducted by Ecology and EPA with assistance from
TPCHD. This list refers specific:a11y to Nearshore/Tideflacs and A.reawide activities. It does not
include .activities specific to ASARCO. Tar Pits. and South Tacoma Channel sites. Community
relations activities include the following:
Prepared the initial community relations plan (1983)

Established and provided staff support for Citizens Advisory Committee [started
in September 1983 with regular meetings ongoing through spring (1989)]

Established and maintained information repositorIes (1983-present)

Developed and maintained mailing list of interested individuals (1983-present)

Periodically briefed Tacoma-Pierce County Board of Health and city/county
government officials

Provided information for working sessions with Pierce County Medical Society (1983)

Gave presentations to elementary and high school students, to workshops for teachers
(winter 1986), and to schools and community groups (1983-1986)

Held press conference and gave tours of Commencement Bay (June 1984)

Gave tours of Commencement Bay to the Citizens Advisory Committee (1984,
August 1988) and student groups (June 1986)

Distributed periodic Commencement Bay Superfund updates to the community
(September 1986, April 1987, August 1987, March 1988, May 1988, April 1989,
September 1989)
.
.
.
.
.
.
.
.
.
.
Gave 27 community interviews for revised community relations plan (September
1987)

Published notice and analysis ot proposed plan in Tacoma News Tribune (24
February 1989)
.
.
.
Distributed proposed plan fact sheet to over 2,500 individuals (24 February 1989)
Presented public workshops, meetings, and hearings:
.
NOAA report, TPCHD fish advisory
CIe:mup plans
Progress report
Remedial investigation study plan
Commencement Bay dredging disposal
Remedial investigation resuits
Remedial investigation resultS and commentS
Status report
Tideflats businesses (business 1 iabiiity)
?roposed plan
Proposed plan :md public comments
.-\ pril 198 1
June 1983
March 198.1
\Jovember ! 98.1
September 1985
June 1985
July 1985
November 1985
.-\ pril 1989
: J March 1989
6 June 1989
.)
-------
o
APPENDIX C
Implementation Schedules for Source Control
-------
CONTENTS
UST OF FIGURES
IMPLEMENTATION SCHEDULES FOR SOURCE CONTROL AND SEDIMENT
REMEDIAL AcnON
HEAD OF HYLEBOS WATERWAY
MOUTH OF HYLEBOS WATERWAY
SITCUM WATERWAY
ST. PAUL WATERWAY
MIDDLE WATERWAY
HEAD OF CITY WATERWAY
WHEELER-OSGOOD WATERWAY
MOUTH OF CITY WATERWAY
REFERENCES
C-ii
fm
C-lli
C.l
C-l
C.6
C-6
C-IO
'C-IO
C.1S
C.t8
C-1S
-------
Figure C-1.
Figure C-2.
Figure C-3.
Figure C-4.
Figure C-S.
Figure C-6.
Figure C-7.
Figure C-8.
Figure C-9.
UST OF FIGURES
Recent, ongoing, and planned activities at the Head of Hylebos Waterway
Hylebos Waterway - Existing industries and businesses
~
C-2
C-3
Recent, ongoing, and planned activities at the Mouth of Hylebos Waterway C-7
Sitcum Waterway.: Existing industries, businesses, and discharges
Recent, ongoing, and planned activities in Sitcum Waterway
Sl Paul Waterway - Existing industries, businesses, and discharges
Recent, ongoing, and planned activities in Sl Paul Waterway
Middle Waterway - Existing industries, businesses, and discharges
Recent, ongoing, and planned activities in Middle Waterway
Figure C-lO. City Waterway - Existing industries, businesses, and discharges
Figure C-ll. Recent, ongoing, and planned activities at the Head of City Waterway
Figure C-l2. Recent, ongoing, and planned activities in Wheeler-Osgood Waterway
Figure C-l3. Recent, ongoing, and planned activities at the Mouth of City Waterway
C-iii
C-8
C-9
C-ll
C-12,
C-l3
C-14
C-l6
C-l7
C-19
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.
IMPLEMENTATION SCHEDULES FOR SOURCE. CONTROL
AND SEDIMENT REMEDIAL AcrION
In this appendix, recent, ongoing, and planned activities are summarized for the major
problem areas of the Commencement Bay Nearshore/Tideflats (CB/NT) Superfund site. Timelines
depict major actions pertaining to the characterization and remediation of sources and adjacent
sediments from 1987 to 1995. Details of source-related actions are provided in the supporting text.
The information contained in this section, particularly regarding the nature and timing of
future actions, is tentative and was developed for planning purposes. The timing of source control
actions is highly dependent upon the availability of agency staff and imancial resources, the success
of negotiations with potentially responsible parties (PRPs), and source control and investigation
results.
Identification of additional sources will be supported by Urban Bay Action Team (UBA T)
activities. The 1989 Puget Sound Water Quality Authority plan (PSWQA 1988) requires that action
teams carry out various source control and investigative KUons. including searches for unpermitted
discharges. investigations of storm drain and groundwater conrnmination, and regulatory
enforcement. The timing of sediment remedial actions is dependent upon the priority ranking .of
the problem area. the successful implementation of source control actions, negotiations with PRPs,
the successful completion of the remedial design phase, and necessary coordination of remedial
action with activities conducted in other problem areas. Because of these complicating factors, the
timing of sediment remedial activities is subject to the greatest uncertainties. The schedules for
source control and remedial activities reflect the status of those activities as of July 1989.
Remedial activities associated with storm drains in each of the problem areas will be regulated
by the new National Pollutant Discharge Elimination System (NPDES) permit regulations to be
adopted early in 1990. NPDES permit applications for industrial storm drains will be due I year
later. NPDES permit applications for municipal storm drains will be due 4 February 1992. [n
addition, the 1989 PSWQA plan (PSWQA 1988) requires that local governments begin developing
stormwater programs by 31 December 1989 and demonstrate significant progress on the programs
by 31 December 1991. By the year 2000 the stormwater programs must be implemented.
HEAD OF HYLEBOS WATERWAY
Remedial activities at the Head ot" Hylebos Waterway are summarized in Figure C - l.
~umerous sources have been JSsociated with sediment contamin:nion .:It the head Ot' rhe warerway.
inc!uding Pennwalt Chemical Curpor:nion: Kaiser Aluminum and Cllemical Curporation: Gcn~r:.ll
\1etals. [nc.; several log sorting yards: and the landfills in rhe Hylebos CreeK drainage basin. The
;ocations of existing industries in Hylebos Waterway are shown in Figure C-2.
In the last several years. Kaiser Aluminum has implemented several remedial actions. These
lctions include re-routing of in-plant wastewater streams. instaHation of a settling basin between
1n 01PDES-permitted discharge and Kaiser Ditch. :.md instatlation of 1 tide gate in K:liser Ditch.
K.emaining :;crubber sludges 00 rhe western portion or ~he sice ~re :J.ddressed in :he ::31ud~e
Management Closure Plan. submitted to the Washington Department of Ecology l Ecology) tn
Seorember ! 987..vhich proDosed in-place c:Dpin~ :lS rhe preferred remeaial :~ction. ::coio!?y ':as
.equired additional srounawater monieonng :lnd soil resting, as weil J.S .1 risk .lssessment :0
determine whether the remaining scrubber brushes will need to be removed or if rhey can be
disposed of onsite. A consent decree is in the draft/negotiation stage and should be completed in
January 1990. It is anticipated that site stabili2ation activities will be performed during the summer
of 1990 and require less than 6 months to complete. The effluent from Kaiser Aluminum is
monitored under an NPDES permit. which is due for renewal in Noyember 1989.
-------
...--..--
.~._---
1987
FacIllUe~/~ourct:::i
. Kai~er Alumillum
PeMita
Groundwater Soil
Pennwalt CllclllllCi.d
General '.klal:>
3009 TaykH Way log Sortiug Yards
Wasser Wu lie. s log Sorting Yafds
louisian.! Paci'ic log Sorting YaH.Js
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Tacoma U0i.i!
. Storm Dr uiliS
Addilion...1 ~OUfCtl hJanliliCalioli
----
----
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1992
1990
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-------
Remedial activities at Penn walt Chemical Corporation are regulated by both a consent decree
signed in July 1987 and a stipulated agreement issued in March 1989. The decree requires the
following:
.
Characterization of the Pewte area (sludge, soil, and shallow groundwater)

Characterization of the Wypenn area (soil and groundwater)

Surfa.:o impoundment sampling and analysis

Surface water quality sampling and analysis

Following completion of characterization of the Pennite area, preparation of
recommendations for mitigating arsenic contamination in the upper aquifer and
implementation of the approved alternative.
.
.
.
.
Soil sampling and analysis plans for the Wypenn and Pennite areas were submitted in December
1987, and soil sampling at the Pewte area was completed in early 1988. The Wypenn soil
sampling plan was approved in May 1989. The surface water quality and impoundment sampling
plans were submitted to Ecology in August 1987. These plans were revised in May 1989 and will
be completed by October 1989. A groundwater characterization report and an engineering
evaluation work plan to mitigate arsenic contami"ation in the upper aquifer in the vicinity of the
Penniee area were submitted in December 1987. The arsenic remel'fiqtion feasibility study/remedial
design work plan was approved in May 1989....anda completed feasibility study/remedial design for'
the Pewte area is expected in February 1990. Remeqia1 action should begin in spring 1990 and
require 1 year to complete. Construction on a new caustic tank farm facility began in January
1989 and will be finished in October 1989.
An administrative order issued in February 1988 addresses the extreme pH variations in the
Pennwalt effluent. The order requires that Pennwalt either comply with dangerous waste permit-
by-rule regulations or meet the exemption requirementS. The admjni~trative order has been
superseded by a stipulated agreement signed in March 1989. Under the stipulated agreement,
Pennwalt must meet the following requirementS:
.
Pay penalties for pH exceedance in the outfall
Make interim and final upgrades to the pH neutralization system.
.
The interim neutralization system has been in place and oper:lting effe<:tively since June 1989.
The final neutralization system must be operable prior to an NPDES permit renewal in August
1990.
"ia ongoing sources of polychlorinated biphenyls (PCBs) were identifi~d :n :he CB, "iT
remedial investigation at General Merals. Inc. However. a subsequent PCB reconnaissance ~Uf','e~!
;;ompleted in July 1986 found elevated levels of PCBs (Stinson et:l1. 1987). ,-\ctiviries:1t the sire
~re r,eing conducted. under :m Ecolo~y administrarive order issued in Augusr ! 987 :har ,equires
Genera! Metals to remove inactive PCB .ransformers :lnd submit a worK pian for complete sire
characterization. Cn February 1988. a work plan for site characterization and interim remedial
1ction was submitted. :lnd the order was :lmended to require that :1 conceptual site draina~e pian
oe ~ubmirted and that source control remedial action be initiated. The preliminary ,emedial
investigation was conducted between March and Juiy 1988 and the continuing remedial investig:l-
tion was submitted to Ecology in June 1989. A site stabilization plan was submirted to Ecology in
Seotemoer i 9&8. 'lnd ::cology :tmended the ')rder :0 ,eQuire :mplemenrarion ,;r" ,he Jlan :nd
preparation of a source control feasibility study. The source control feasibility study began in
December 1988 and was completed in July 1989. Further source control activities after December
1989 will be enforced by an agreement or order which should be signed in October 1989. Various
types of site stabilization activities began in March 1988 and continued until June 1989.
-------
Remedial actions at the 3009 Taylor Way log sorting yard are regulated by a consent order
signed in June 1987 betWeen Ecology and th~ Pennwalt Chemical Corpontion (the property owner).
The order requires Pennwalt to prepare an engineering evaluation (surface water investigation) and
conduct a remedial investigation/feasibility study at the site. Work plans for an engineering
evaluation and a remedial investigation/feasibility study were submitted to Ecology in July and
August 1987. respectively. Between July 1987 and January 1988 the surf~ water investigation
was completed. A focused feasibility study submitted in March 1988 indicated that interim
remedial action would not be required. Ecology has concurred with this conclusion and determined
that remedial action will await the results of the remedial investigation/feasibility study. The
remedial investigation work plan was approved in December 1987. and the remedial investigation
began in February 1988. Between February and March 1988, the hazardous substances and
hydrogeological investigations were completed. Wet weather sampling was completed in the spring
of 1988. The submittal date of the final feasibility study is a negotiated item under the 1987
consent order. The remedial design/remedial action phase will be handled by either an amended
or a new consent decree. The new consent decree will be consistent with the applicable or relevant
and appropriate requirements (ARARs) of the Model Toxies Control Act and should be signed
during the summer of 1990.

Activities at the Wasser Winten log $Orong yard are repJated by a consent order. signed in
March 1987. between Ecology and the Port of Tacoma (the property owner). A preliminary site
characterization was completed in April 1987. In AugUSt 1987, a proposal by the Port of Tacoma
to mitigate soils slag and wood waste onsite was submitted to Ecology and rejected. In January,
1988, the Port of Tacoma agreed' to prepare a proposal for an alternative remedial design
incorporating mitigation of both surface water and groundwater con~mination. This remedial
design should be finished by February 1990. Remedial action should begin in March 1990 and be
completed by December 1990.
Ecology issued an administrative order in June 1987 that requires Louisiana-Pacific log sorting
yard to perform a site investigation and feasibility study. A surface water drainage study was
completed in October 1987. A work plan for groundwater characterization was submitted by the
PRP in November 1988. Groundwater characterization, which began in September 1988. includes
installation of three monitoring wells, one round of sampling, and a tidal study. Groundwater
sampling will be followed by groundwater monitoring. The feasibility study work plan was
submitted to Ecology in January 1988, the dmt feasibility study was submitted in September 1988.
and the final feasibility study was submitted in February 1989. An addendum to the feasibility
study was completed by Ecology in June 1989 to address several issues of concern not previously
addressed. Remedial action should begin in June 1990 and be completed by October 19,90.
Remedial action at Cascade Timber Yard #2 is regulated by the Puyallup Tribe settlement
19reement. It is anticipated that this agreement will become effective in February 1990. C'nder
the 19reement. the Port of Tacoma must perform an environmental Judit Jnd prepare 1 de:muo
plan. The environmental audit began in April 1989. lnd .he sampling pian section or' :his ludit
wiil begin in October 1989. The Port of Tacoma has 3 years from .he effective date 0f [he
'.lI~reement to complete the cleanup.
Remedial action at B&L Landfill is driven by a consent decree completed in February 1989.
The :;onsent decree requires a remedial investigation/feasibility stUdy/remedial design by May 1990.
;he r"inal remedial investigation should be completed in early 1990. Under Jn extension currently
being negotiated, [he final remedial action/remedial design will be compieted in June 1990. The
remedial action will require an amended or new consent decree. Of the nine PRP that have been
:dentified. one ?RP (Murray Pacific) has J.~reed m;omolete the remedial lction ~f 20 ?ercent
;natching ;)uolic rOunds J.re provided.
Remedial activities at Tacoma Boatbuilding Company are driven by the Shipyard Education
Program and the related NPDES permitS being issued by Ecology and an administrative order
effective July 1989. The Shipyard Education Prognm. currently underway. is designed to provide
shipyard opentors with information on appropriate best management practices. The NPDES permit
-------
will be issued in December 1989. The NPDES pennit and the administrative order will require that
best management practices be implemented, monitored, and documented. Best management
practices will include routine cleaning of the yard area; appropriate storage of paints, solvents, and
other chemicals; the use of drip pans and containment SU'Uctures to minimi~ dispersion of
potentially hazardous solutions and. dust; constraintS on bilge and ballast water discharge; and
explicit limitations on the discharge of all oil or hazardous material to the waterway. .

USG Landiill has been associated with contamination in sediments at the Head of Hylebos
Waterway but is not specifically included in the schedules because of a lack of recent activity.
Remedial actions at USG Landiill are mainly historical and include excavation and removal of
waste and capping of the site. Groundwater at the site is currently monitored, and no additional
remedial activities are scheduled.
MOUTH OF HYLEBOS WATERWAY
The locations of existing industries, businesses, and discharges in Hylebos Waterway are shown
in Figure C-2. Remedial activities at the Mouth of Hylebos Waterway are summarized in
Figure C-3. Occidental Chemical is the major identified source of problem chemicals in this
problem area. Several source control actions have been undertaken by Occidental Chemical in the
past several years. In-plant modifications include the installation of taller chloriDe stripping towers
along with modificatioDS in temperature regulation and modified waste handling practices.
Effluent from the facility is monitored under an NPDES. permit, which is due for renewal in
March 1990. Most of the soil charactenzation was conducted in 1979. More than 10,000 cubic
yards of soil contaminated with chlorinated organic compounds were removed from the site during
1981-1982, in accordance with a consent order.
Recent, ongoing, and planned activities at Occidental Chemical are driven by a Resource
Conservation and Recovery Act (RCRA) Part B permit that specifies sediment sampling and
sediment and groundwater remediation. The draft RCRA permit was completed in August 1988.
The permit was completed in November 1988. Groundwater monitoring is ongoing, and the
inst:a11ation of six additional shallow wells was completed in September 1988. A sediment sampling
plan approved by the U.s. Environmental Protection Agency (EPA) and Ecology in December 1987
is being implemented and a draft report will be completed by September 1989. Also expected in
September 1989 is a draft groundwater corrective action plan for a groundwater extr:lction and
treatment system. Construction on the extraction and treatment systems should begin early in 1991
and require a minimum of 8 months to complete.
SITCUM WATERWAY
The ioc:uions of existing industries. businesses. :lnd discharges in Siecum W:lCerway lre ,hown
in Figure C-4. Remedial activities in Siecum Waterway :lre airectea Jt Terminal i ore unlOading
~'aciiieies and Storm Drain SI-I72. two primary sources of metals I Figure C -5), Remedial ~lctions
lt Terminal 7 are limited to the implementauon oi best management practices. Spilled f)re. wnicn
was formerly swept into the waterway, is now collected and sold to smelters. A dosed conveyer
belt is now used for transferring :llumina are from ships ro storage areas. Best managem~nt
practices :lre subject ,0 routine. monitOring (0 ~nsure chat discharge oi are co the waterway is
:ninimized. Routine monitoring (conducted J.S I)i July 1989) indicates that best mana~ernent
practices are being followed.
.storm ;)rain ':;1- i 72 is one .)f i"ive $tOrm drains in ,he CB/NT :lre:l included in the ;JoiluclOn
control effort being implemented under the memorandum of agreement between Ecology. the city
of Tacoma. and the Tacoma-Pierce County Health Department (TPCHD). The storm dmin report
required by the agreement was completed in July 1989. BetWeen January 1987 and December 1988,
chemical loading from the drain was monitored quarterly during high- and low-flow conditions.
Also during this study period, business inspections were conducted to better charncterize activities
-------
.-....--.---- .-._.. --
1981
1988
1989
1990
1991
1992
fu(;IIUlcs/Sourc&;:~
uL~idtJntal Chem!cal
Additional Source
Id~nlitication
-----
----
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5110 Characi izalion
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Additional Sediment
CharactdrilaUon
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1993
1994
~ZJ Site Clldrdcttnilalion
~ Sile A£Hlledial Aclion
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NPOES Parmil

. RCRA Perrllit

Timing LJncurldility
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.. ~-..__._. --....
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-------
I
j' 51.'"

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Figure C-4. Sitcum Waterway - Existing industries. businesses. and discharges
-------
__0.-
..---- - .-----------
1987
1988
1989
1990
1991
1992
hjLIUUe~/Sources
Bosl Management PraClicas
(Prtlvtlnlion and Recovery 01 Spilled Ore)
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1990
1991
1992
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Sediment
Remedial
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--_.... ---'-~--_.__o.._-._----
-------
and implement appropriate corrective actions. Business inspections and storm drain monitoring
have been extended until April 1990.

Significant source controls in Sitcum Waterway have been implemented, but their effectiveness
has not yet verified.
At the time of this writing. the Port of Tacoma has plans to dredge over 40,000 cubic yards
of material for maintenance and extension of Pier 1. Habitat replacement at the head of the
waterway and a ilSh mitigation area are elements of the planned dredging. The navigational
channel in Sitcum Waterway i.! also subject to routine dredging. Where possible, these dredging
projects will be integrated into the implementation of the preferred sediment remedial alternative.
Re-evaluation of the dredging schedule and resource availability may necessitate modification of
the schedule for sediment remedial action.
ST. PAUL WATERWAY
The locanoDS of existing industries, businesses, and discharges in St. Paul Waterway are shown
in Figure C-6. Remedial activities are more advanced in St. Paul Waterway than in any other
problem area. Simpson Tacoma Kraft pulp mill, the waterway's single major source of problem
chemicals, has implemented numerous source control actions, including outfall relocation, process
modifications, and best management practices. Recent, ongoing, and scheduled activities associated
with the site are summarized in Figure - C- 7. Activities at the Simpson Tacoma Kraft pulp mill are
driven by an order issued by Ecology in December 1985 and a consent decree signed in December
1987. The relocation of the treatment plant outfall required by the December 1985 order was
completed in March 1988. Simpson also has initiated a remedial action and habitat restoration
program in an effort to remediate sediments previously contaminated by waste discharged from the
site. Under the December 1987 consent decree, Simpson has deposited sediments displaced during
relocation activities in a shallow depression near the original outfall location. Capping of this and'
other sediments contaminated by historical discharge from the plant was conducted betWeen July
and September 1988. A habitat restoration program designed to mitigate adverse biological impactS
was a key element of capping activities. The Simpson Tacoma Kraft Company is required under
the December 1987 decree to monitor the long-term effectiveness of the capping and habitat
restoration activities.
The effluent from the Simpson Tacoma Kraft pulp mill is monitored under an NPDES permit
that is scheduled for renewal in December 1989. At that time, the permit may be modified to
~xpand restrictions on toxic chemicals not previously covered in the permit :lnd to incorpor:lte
additional monitoring requirements.
\'nDDLE WATERWAY
7he !ocations of existin~ industries. businesses. 1nd discharges :n :--'1iddle Waterwav 1re :;hown
:n Figure C-3. Remedial activities in Middle Waterway have focused on ,wo potential sources of
metals. Marine Industries Northwest :lnd Cooks Marine Specialties (Figure C-9). Remedial
lctivities at these shipyards :ue driven by the Shipyard Education Program and related NPDES
permits ,hat :lre being implemented ay Ecology. The Shipyard Education Program i currently
underwa y) is designed to disseminate :lppropriate best management pracrices to snipv:ud operators.
~PDES permits to oe issued ro these sites in December 1989 will require chat best management
:Jractices he :molemented and documented bv ;noni(oring. 3est m:lOa~ement oracrices ,~o\'ered :n
:ne ;JermlC '.viil inctuae routine de:lOing 'J(' ,he ;::lra :.lrea: :lppropri:.lce srorage 'Jf '):1IOCS. ~OIVents.
and other chemicals; the use of drip pans and containment structures to minimize dispersion of
potentially hazardous solutions and dus~ and constraints on bilge :lnd ballast water discharge. The
permits will also include explicit limitations on the discharge of all oil and hazardous material to
the waterway.
-------
~401": ?1'CID8ftY ~ - lICIQIaDm8Ie.
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Figure C-6. St. Paul Waterway - Existing industries. businesses. and discharges
-------
---'-~ ."-_.~'.. -----"-'--
---'--       
 1985 1987 1988 1989 1990 1991 1992
Facllllle~i~our~e:i       
Simpson lacomiJ 1«(aU  Out/all Relocation    
.1:-   ---   
Storm 0, ulilS O"C 19115      [OJ
Additionol ~OlJr(;d  ---- ----  ---- ----- --~
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Timing UncCltai'lly
 1987 1988 1989 1990
Sediment cap~ng and Habilal  
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 ..   
.."-_.~-- .-----.--.--.. ---
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. . -----.-
. . --- .--- ".
_.__._~._....
-......-
-------
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, SIMPSON TACOMA KRAFT (S'T\JD MIUJ
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~W8J.WOOO
5 WASH..aTON BB.T & DRIVE
-3 'NESTCRN MAOtINE
. ?AC:FtC YACHT BASIN
3 i:'IFlE STATTON
, :OOWE~ SUSST A TTON
. J C::ASi CAAFT
.. =CSS ANO LAUNCH TUG
.: '.IAAINE ;NOUST~IES NORTI-IWEST
.) =":SS;OILJ..JNGHAM
. ~ :~KS MARINE SPECIAl. rtES
': "'JGc: S<:JL.:NO FIt '!'WOO 0
. ~ 5\:t.,;:jO ell. i
. - :.37;:E:: ::1I:~::IOlEUM FAC:UTTES
'.II..J\..~'?,-: .:WNERS)
1
17
10
\
\
\
\
, \
'.'" '.
" ......' ...:) . . '.
, "",,,,, -~. s.:g '.
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/\ ~~ /
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\9\~1 ,\
~I '. ".Io.,ocf
8 '- 6 )/
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leet
. '3fIOUIIDWA TCR SEEPS
A"_: Tetra Teen (1988): TPCHD (1984. 19861.
'jot.,: .~n:JD8nv oaunaa.- at8 aaaroalm8l.-
~ on ..... DnalCQ"" - d.-
':)v ,nSDeClIOnl.
meters
~'J
Figure C-8. Middle Waterway - Existing industries. businesses. and discharges
-------
--..--..-.-
FacUIt
------ .~--      
  1987 1988 1989 1990 1991 1992
'efi/Suurces       
    r Beli' Management Pracliooli f-~'
Mali/Ill Specidlti~s    
   I  
ImJustrios NOH' Iw~st   ,.... Beli' Managemenl Praclices ~~
  ('  --
Drdills       [a]
nal Source  '1----- ------ ----I t------ ----- r---~
icauon     
    I   
Cook.
MarilllJ
Ston II
Addiuu
Idenlil
()
I
~
- -.....-
C)
[==J
Moniloring
NPDES Permit
Timing Uncertainty
   1994 1995  1996
Sediment   Remedial Oeliign  
 ,-. -- - - -~
Remedial I  1111 1111  
Action  ~---- r-----~ 
 Negoliation. Remedial 
  Action 
~ Silt: Remedial Action
. ---.- --....-- ...-..-----.--....--
-------
Storm Drain MD-200 was identified as a probable source of lower priority organic chemicals
at the head of the waterway. Sediments in Storm Drain MD-200 were sampled in June 1987 and
analyzed for problem chemicals. Remedial activities associated with Storm Drain MD-200 and
other storm drains in Middle Waterway will be regulated by the new NPDES permit regulations that
should be-adopted in early 1990.
It is uncertain whether all major ongoing sources of conmminAtion to Middle Waterway have
been identified. The effectiveness of the best management practices implemented at the shipyards
has not been verified. Between October 1989 and June 1m, inspections are schedule for Foss
and Launch Tug Industries, Coast Craft, Paxport Mills, and Puget SOund Plywood. However, there
is currently no indication that any of these businesses is a source of poUution to Middle Waterway.
HEAD OF CITY WATERWAY
The locations of existing industries and businesses in City Waterway are shown in Figure
C-IO. Remedial actions are underway for several of the sources that have been associated with
problem chemicals in sediments at the Head of City Waterway (Figure C-II). City Waterway
~ Inc. and Martinac Shipbuilding have plans to dredge in the near future. The navigational
channel running the length of City Waterway is also subject to routine dredging. When possible,
remedial action implementation will be coordinated with planned dredging within the waterway.
Major sources of problem chemicals include: Storm Drains CS-237, CN-237, and CI-230 (e.g.,
metals and high molecular weight polycyclic aromatic hydrocarbons); Martinac Shipbuilding (metals
only); and American Plating (primarily nickel).
American Plating is no longer an -active facility. When active, the site was designated an
RCRA dangerous waste generator. After the site became inactive, Ecology negotiated consent
orders to mitigate contamination problems onsite. Emergency site stabilization at American Plating
was performed by the site owner under a November 1986 consent order and was completed in June
1987. A second consent order signed in September 1987 stipulates additional site characterization,
including I) the chemical and spatial characterization of remaining waste onsite, 2) determination
of the integrity of sumps, and 3) groundwater monitoring. In September 1987, EPA issued a
RCRA enforcement order.
Ongoing remedial action at the site is driven by the RCRA closure process :lnd the state
Superfund law. A remedial investigation work plan was submitted to Ecology and EPA in February
1988 :lnd was approved in April 1988. The draft remedial investigation report was submitted in
July 1988. However. a preliminary review revealed several data gaps. particularly in the
characterization of the vertical extent of soil contamination. An acceptable remedial investigation
report was received in May 1989. The RCRA ';orrective lction order is ~xpected by October [989-
A ;orrective measures study will begin once the corrective :lction order is finalized in Ocrober
: 989- The remedial Jction should begin Juring the summer of 1990 Jnd reauire 6 monrhs ~o
complete.
Remedial activities :It Martinac Shipbuiiding Jre driven by the Shipyard Education Program
and the related NPDES permits being implemented by Ecology. The Shipyard Education Program
(currently underway) is designed to disseminate Jppropriate best management practices ,0 shipyard
'Jperators. :--JPDES permit :lpplic:uions to be finalized in January 1990 will reQuire that i)est
:nanagement practices be implemented Jnd documented by monitoring. Sest management practices
covered in the permit wiH inetude routine cleaning of the yard area; :lppropriate storage OI' paints.
:oivents. :lod ,nher .:hemicals: ,he -lse ,)[ Jrio ?ans :lOd -.:onrainment ~rrucrures '0 :ninimize
JiSperSlOn of potenria1iy ;1azardous ~oiUIlOns :lnG \.lust: Jod ;;onsrrainrs on Jiige :lnG J:lil:lst.V:lrer
discharge. The permit will also include explicit limitations on the discharge of all oil and hazardous
material to the waterway.
-------
--'
. ',~t;:. r: F". = -:WNE=S, "J.. , '.
.',.\'~< ~-;.'.'.~~'
\
.
~-cc'"' S:I,,;~.C ~-"WOC::1
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~ .:. 3'7'===~ =ET=C:';:';M ~4C::';'7":S
i C:..:.~~ :~:.~
~ :~:< =::_~.:~V
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- :L YMPIC :i-'E.,'~C':'L
3 al.ose YAC""NE
; ;:I\jCiEj ~~O ..a,.:. r '7'=e. :':NG
': YA~INe iRON WC;:I(S
'~ WOOOWOFmo! & C::MPANY
'2 WESTERN O~YI(It.N
'J WESTERNS~a.'=""8~ICATO~S
'4 OLO ST. "'eGIS OOO~ MIll. : c:.oseol
, ~ I(LEe... 8I..4ST
'5 NO~n-tWEST CONTAINER
17 RAINIER P\. YWOOO
~e YA~TINAC $IoIlPetJlLOINQ
'9 CHEVRON
20 MYGAAOe FOOCS
21 fAR PITS Sm: !MULTlP\.E OWNERSI
ZZ WEST COAST ~ERY
23 f:'ACIFIC STORloGC
24 MA~INA FACIUTlES
25 EM~ ~TS
25 f:'ICKeRING INOUSTRIES
27 UNION PACIAC & SURUNGTON NOfmEJ=W ~1lAOAOS
28 f:'!CKS cove BOAT $ALES ANO REPAIRS
~!CKS cove ~INA
29 .wERIC.AN FlU TlNG
JO INQ\JSTRIAL RUee~ SUPPt., y
J 1 TOTEM MAlVNE
JZ COAST IRON MFa.
JJ USA SAI. 'TWA T~ BOA TS
30& CUSTo... MACHINE MFG.
15 WESTERN ASH
J8 OLD TACOMA UCiHT
J7 Ca.ONW, FRUIT & PROouce
~s J 0, ENGUSH STEEL. co. .
)9 JOHNNY'5 SE.AFOOO
~ CASCAOE OR'fWAU.
J 1 SC:::FIE!.O. rJ:lu...ux. N PAC:FIC Pt YWOOO tC:'CSEOI
J2 ;l4CIFIC C:::ASTCll
~ C;T'V WA TERWAY I,4ARINA
~ .;-1 ~LBRAIn-t co
.s -4~N FURNIT\.JRE
J6 ~ ACCMA SPUR SITE
~ef_rIC8: Terra Tecnp98&I; TPCHO(I9S4.1986I,
"01..: ~~ ~ a.. acaa-.
=-- on.- onaCICI~ ana a~
JV InsoecI_.
I
~
22
"-
\
~-
:00
leel
meters
~:O
Figure C-10. City Waterway - Existing industries. businesses. and discharges
-------
_. .._-. ...--_........_- .. .-
--'.""--"--- ,..----
H.lUfi
1987
1988
1989
FacIlHi~~/Source~
AI and Correctiv Measures Slud~
AmeriLlJlI Pldling
Silt!
SlalJilizauon
~ h"
MartinlJ<'; Sl1i~building
Storm lJl.Jin CS 237
Or al/lagtl Basin Char8ClerizalionlBusinesa Inspection
7.0
Storm 1)1 Jin CI~-237
Drainage Basin CharaclerizalionIBusineSl Inspection
r-.
Storm fj. ain Ct 230
Taconl<.l Spur ~ita
()
I
Groundwal8I Monitoring
Other ~Iuflll D,dins
----------
....,
AddiliGlidl SOUl cu
Identitkalion
-----
..._-
~
E7n
IWLZI
- -.....- Monitoring
O..!..;,IDucruo
o
[=J
511..: ClliJ...ILltHll dlian
NPDES Permit
Sediment
Remedial
Action
SII., Hurll..,Jlal ALiion
Timing Uncertainty
AI - HLljll;dj"lll\vc~liUaliul\
~-_._~------ - . . --..
-_.. --.- -.--.--- ---
1990
1991
1992
Sile ClosUle
---~
---~
Bes. Management Practices
~
~
~
-----
[OJ
- --..-
----
1993
1994
1995
-...-
~""~II..... H~C~'II. :"U':'H~ and planned aclivilies at !he Head of Cily Waterway
-------
Groundwater monitoring is currently being conducted at the Tacoma Spur site. Approximately
17,500 tons of contaminated soils were removed from the site during highway construction.
However, no additional remedial action is planned. .
Storm Drains C'S-237, CN-237, and CI-230 are three of the five CB/NT storm drains included
in the ponution colia-ol effort being implemented under a memorandum of agreement between
Ecology, the city of Tacoma, and the TPCHD. The storm drain report required by the agreement
was completed in July 1989. Between January 1987 and December 1988, chemica110ading from
the drain was measured quarterly for high- and low-flow conditions. Business inspections have
been conducted within the drainage basin during this study period to better characterize activities
and implement appropriate corrective actioDS. Monitoring activities have been extended to April
1990. The Tacoma sewer utility is evaluating the feasibility of sediment detection basins to conttOl
con~minant discharge into the waterway from Storm Drains CN-237 and CS-237, A report on the
sediment detention evaluation will be completed in October 1989.
WHEELER-OSGOOD WATERWAY
The locations of existing industties and businesses in Wheeler-Osgood Waterway are shown in
Figure C-IO. Remedial activities in Wheeler-Osgood Waterway are summarized in Figure C-12.
Storm Drain CW-2S4 has been identified as the waterway's major ongoing source of problem
chemicals. Storm Drain CW-254 is one of five storm drains included in the ponution conttOl effort
being implemented under a memorandum of agreement between Ecology, the city of Tacoma, and
the TPCHD. The storm drain report required by the agreement was completed in July 1989.
Between January 1987 and December 1988, chemical loading from the drain was monitored
quarterly for high-and low-flow conditioDS. Also during this study period, business inspections
are conducted within the drainage basin to better characterize activities and implement appropriate
corrective actions. Quarterly sampling of the drain has been. extended to April 1990.
A separate environmental audit was
facility between January and March 1989.
source of total. petroleum hydrocarbons.
Chevron is anticipated.
vOluntarily undertaken by Chevron at its bulk plant
The audit indicates that drill cuttings at the site are a
A voluntary full-scale investigation and cleanup by
MOUTH OF CITY WATERWAY
The locations of existing industries and businesses in City Waterway are shown in Figure
C -10. Remedial activities at the Mouth of City Waterway are. summarized in Figure C -13. The
D Street petroleum facilities are an identified source of LPAH in the sediments in chis problem
:lrea. A trench recovery system was installed 15 Jn interim remedial measure between 5eprember
i 987 :lnd January 1938. This system is expected to :lr'fec. mainly the surface :lQuir'er l1ear Giube
\1achine; itS ~ffect on property farther north is unknown. Discharged product is Jlso being
,ecovered from weBs on Globe Yfachine Jnd Yfobil ;Jroperties. A ,;onsent order issued ;0
~ovember 1988 requires I) inter:im remedial action at rhe site including floating product recovery
(already underway) and teak detection/prevention. 2) a remedial investigation of soil. groundwater.
surface water. ::md possibly sediment contamination. :lnd 3) Jdditional remedial 1ction '1S
'1ppropriate.
The remedial investigation report submitted in June 1989 included recommendations that the
:'oilowin~ tJsks Je 'lndertaken:
.
Floating product plume mapping
Dissolved contaminant sampling, analysis. and mapping
Design of an upgraded effluent treatment system.
.
.
-------
.---..-.--- . --.---.
......._..0__-
FacIlUle5/:)oUfces
1987 1988 1989 1990 1991 1992
Drainage Baliin Ch8lacterizalionl   
 Bu&I08II 1napec;lion   
/-   --~ 
.7>   
     [D]
---- ---- ----- ---- ----- --~
Stonl! Drain CW-254
Othu'- Storn. Drains
Addiliunal Source
Ideillilication
n
I
..0
t:'.7/j Site Characterization
~ Site Remedial Action
- - - ~ Monitoriflg
o NPOES Permit
I ~. = = ] Timiflg Uncertainty
1892
1993
f;!!!~~1i&!!.
1894
Sediment
Remedial
Action
[1--
Nego~iCW
--- .-.-.. ... -----
-------
-----~--
.. _.-..~
-- - -----      
 1987 1988 1989 1990 1991 1992
f~Glllth:s/S(Jurc~~   RVfS   
() Str~t3t Petroleum      =~
 Produci Recovery   ------
Olllt}r Storm Drains    [QJ
Additional Sourct} ----- ---- ----  ---- ---
IJdnlilication      
-.----
 1993 1994 1995
Sediment  Remedial Deiign 
[f-- "'-----";- =~~
Remedial  
Action --,------
Negohlii'  Remedial
  AdIon
()
I
N
o
j. OrdedDecrt.J~
(JUJU Remedial D~sign
fLLA Site CIICllact~,i2ation
~ Site Rullledidl Action
. -- -~ Monituring
() NPDES Pcrfllit
rl RCRA Pelluit
[~ q= = ~l
RllfS -
Timing Ullccl,lainty

Remedial Invustigationl
FeasiLility Study
.- .--..--.-.-...--- ----
----
---
-------
..J
Under the consent order the feasibility study will be completed by December 1989. and the
remedial design will be completed in November 1991 or 4 months after levels of free product
removal drop below 20 gallons per day for 1 complete month. The remedial action will be
conducted under an amended or a new consent order in compliance with the Model Toxies Conttol
Act.
-------
APPENDIX D
Revised Cost Estimate for
-------
CONTENTS
LIST OF TABLES
REVISED COST ESTIMATE FOR CONFINEMENT OmONS
CORE SAMPLING FOR REMEDIAL DESIGN
CHEMICAL ANALYSIS FOR REMEDIAL DESIGN
DESIGN/pERMITIING
EQUIPMENT MODIFICATIONS
SITE ACQUISmON
SITE PREPARATION
SITE LINER
EQUIPMENT MOBILIZATION
CONTAMINATED SEDIMENT DREDGING
MARINE TRANSPORTATION OF CONTAMINATED SEDIMENT
OVERlAND TRANSPORTATION OF CONTAMINATED SEDfMENT
BARGE UNLOADING TO DISPOSAL SITE
BARGE UNLOADING TO TRUCKS
CONFINED AQUATIC O£SPOSAL S£TE OREDG£NG
DISPOSAL COSTS AND FEES
CAPPING OF UPL\.ND/NE.4.RSHORE DISPOSAL SITE
CLEAN SEDIMENT DREDGING FOR CONTAMINATED SITE CAP
CLEAN SEDIMENT TRANSPORTATION FOR CONTAMINATED SITE CAP
C~NFTRMATICN SAMPLING
CONFIRMATION ANALYSIS
WELL CONSTRUcnON
D-ii
fm
D-iv
D-l
D-l
D-l
D-l
D-l
D-l
D-3
D-3
D-3
D-3
D-3
0-4
D-4
0-4
C'..~
..... .
J-..,.
D-!
0-5
~-5
)-~
0-5
-------
 Paie 
MONITORING SAMPLING OF DISPOSAL SITE D.5 
MONITORING SAMPLE ANALYSIS D-6 
ADMINISTRATION D-6 ,J
CONTINGENCY D-6 
.  
01HER FACTORS D-6 
REFERENCES D.7 
-------
.
UST OF TABLES
Table D-1. Cost categories applicable to each type of remedial action
~
D-2
-------
.
REVISED COST ESI'lMATE FOR
CONFINEMENT OPrIONS
)
Revised cost estimates for the Commencement Bay /Neanhore Tideflats problem areas were
prepared using principally the feasibility study (Tetra Tech 1988) as a source for unit costs and
other f~rs (e.g., dredged deployment costs, production rates, sample analysis costs). Information
presented by reviewers of the feasibility study suUested that some unit COS1S or other factors were
questionable or erroneous. In these cases, these estimates were examined and revised in accordance
with information presented by the reviewers or available from other sources. Each of the cost
categories shown in Table D-l is discussed below, including the value used, the rationale for its
selection, and any special features of its application.
CORE SAMPLING FOR REMEDIAL DESIGN
A collection cost of SI,5oo per core is used; this is the figure cited in the feasibility study
(Tetra Tech 1988). The number of cores is presumed to be one per 4,000 cubic yards of sediment;
this rate corresponds to the value used in the feasibility study and to PSDDA guidance for areas
with the highest connminlltion ranking (PSDDA 1988).
CHEMICAL ANALYSIS FOR REMEDIAL DESIGN
Sample analysis costs differ with the problem area., according to the costs estimated in the
feasibility study. These costs ranged from $800 to S1,5oo per sample. Analysis of three samples
from each core is presumed, in accordance with the feasibility study.
DESIGN/PERMITIING
The cost assigned to this category is $325,000 (Gershman, Brickner & Bratton 1989). The
feasibility study does not include this cost category. Confined Disposal o{ Concaminaled Sedimellls.
Documencalion o{ Standards Development (~rametrix 1989) recommends costs from $810,000 (for
confined aquatic disposal) to $1,860,000 (for aD upland mixed disposal site).
EQUIP~ENT ~[OD[FICATIONS
Equipment modifications for Commencement Bay sites ~onsist of :lHer:1tions to the damsheil
bucket to make' it watertight. The cost of S20.000 per clamshell. cited in the feasibility study, is
IlSed. Only one. dredge at each problem area is presumed to be practica.l. hence the COSt 01 !.>De such
modification is inciuded for each problem :uea.
SITE ACQUISITION
Upland disposai is presumed ro take place ::It one or" rhe sires identified in U.S. \rmv COE
: 1985). Land ~ostS in :l ~ommerciaj loc:ltion :u-e ~stimated :0 iJe 525.000 per :lcre. The ;ora1 ~cre:lge
required is computed as a function of the fill depth at the disposai site and rhe volume of materiai
to be disposed of (after swelling and compaction).
-------
TABLE D-l. COST CATEGORIES APPUCABLE TO EACH
TYPE OF REMEDIAL ACI10N .
    Qverdredging
,    Confined
    Aquatic
Cost Category Nearshore Upland Capping Disposal
Si tlnl aad CODStruCtiOD    
Core sampling for remedial design x x x x
Chemical analysis for remedial design x x x x
Design/permitting x x x x
EqwpmentmodUi~tiom x x  x
Site acquisition x x  
Site preparation (dikes, weirs) x x  
Site liner x x  
Operation    
Eqwpment 'mobilization x x x x
Contaminated sediment dredging x x  x
Marine transportation of contaminated    
sediment x x  
Overland transportation of contaminated'    
sediment  x  
Barge unloading to d~ site x   x
Barge unloading to trucks  x  
Conf'med aquatic disposal sice dr~ging    x
Disposal costs and fees x x  x
Capping of upland/disposal site x x  
Clean sediment dredging for contaminated    
site cap x x x 
Clean sediment transportation for contaminated    
site cap :<: :<: :<: 
Post Closure    
Confirmation sampling 'C :t  
Coniirmation analysis ,'( :<,  
Well construction ,'( :<:  
\1onitoring sampling of disposal site " x. '\ ,
Ytonitoring sample analysis ,'( :<: ,'( "
Administration ,'( :t '( ,
Contin~enc:y X :t :t '(
-------
o
SITE PREPARATION
Site preparation costs were assessed only for the upland disposal alternative. These were
estimated by using values from Table 5-4 of U.s. Army COE (1985), and applying an annual
inflation rate of S percent to adjust the 1984 costs to 1989 dollars. The resulting value is S1.30/
cubic yard of site capacity. Cost estimates were based on the assumption that all material from the
problem area could be cfisposed of in the upland site, thus this cost is computed as S1.30/cubic yard
of conmminated sediment after swelling and compaction.
-i
SITE LINER
)"
Liner costs also were assessed only for the upland disposal option. The liner is presumed to
be 3 feet of clay over the entire area of the disposal site. The unit cost is based on Table 5-6 of
U.S. Army COE (1985), and inflated from 1982 to 1989 dollars at a rate of 5 percent per year,
yielding a value of S22.92/cubic yard of liner. Total cost is computed as the product of site area,
liner depth. and the unit cost.

Use of other liner mate~ inclusion of a membrane, construction of a drainage system, and
other modifications of this simple scenario may substantially affect the costs.
EQUIPMENT MOBWZATION
The feasibility study lumps equipment mobilization with bonding and insurance, and
calculates this as a f"1xed percentage of other costs. The approach used here is to assign a fixed cost
to mobilization. The generic unit cost for a clamshell dredge used here is $150,000 per dredge
(Parametrix 1989).
For remedial alternatives that include capping of the dredging site, total mobilization costS
were based on the assumption that one dredge would be operating in the problem area and another
at the source of clean sediment (e.g., the Puyallup River). The mobilization cost of the Puyallup
River dredge was apportioned among the problem areas according to the fraction of 'total area to
be capped in each.
CONTAMINATED SEDIMENT DREDGING
The unit cost of dredging may vary considerably, as described above. and as shown in the
references. For this cost analysis :l value of 53.00/cubic yard is used. This is based on J brief
rev.iew of recent bids for dredging in Puget Sound (Sumeri. .-\.. 1989. personal -;ommunic:Hion J.
',vhich Jveraged Jpproximately 52.50/cubic y:ud: Jnd the -;ostS ~stimated by CJrtert "lnd KJSseb:lUm
, 1989), which ranged from :52.50/cubic yard to 51 :.OO/cubic yard.
YfARINE TRANSPORTATION OF CONTAMINATED SEDIMENT
Transportation of sediment by barge is estimated cO.COSt J.bout SO.30/cubic yard-mile. based
on rhe figure of SO.25icubic yard-mile cited in U.S. Army COE (1985), J.nd ::ldjusted ,"or inflation.
This is comparable [0 :he ';ost of .s0.25/cubic yard-miie cited in PSDDA (1988), Transportation
:;osts were based on the volume of sediment :1fter swelling.
-------
..
OVERIAND TRANSPORTATION OF CONTAMINATED SEDIMENT
Overland transportation of contaminated sediment is estimated to cost SO.SO/cubic yard-mile,
based on the marine transportation cost and the suggestion that trucking costs will exceed barging
costs by about SO.20/cubic yard-mile (U.S. Army COE 1985). Transportation costs were based on
the volume of sediment after swelling.
BARGE UNLOADING TO DISPOSAL SITE
~
A unit cost of S1.2S/cubic yard that was used in the feasibility study is used for this cost
analysis. Unloading costs were .based on the volume of the sediment after swelling.
BARGE UNLOADING TO TRUCKS
A unit cost of S2.50/cubic yard is used, based on an estimated cost of S500,000 for
200,000 cubic yards of sediment (Parametrix 1989). Note that PSDDA (1988) has used a cost of
Sl.SO/cubic yard.
CONFINED AQUATIC DISPOSAL SITE DREDGING
The cost of conimed aquatic disposal site dredging is presumed to be equivalent to that for
dredging of conrnminated sediment (i.e., S3.00/cubic yard). Because of the overdredging approach,
however, the sediment removed to create the confined aquatic disposal site will be deeper than the
contaminated material. This additional depth may increase the unit cost. For example, Corlett and
Kassebaum (1989) estimate that at the head of City Waterway problem area, removal of the first
five feet of V!ttiment will cost S2.S0/cubic yard, but removal of the underlying three feet will cost
S8.00/cubic yard.
The volume of material to be dredged for the confined aquatic d~posal site is computed as
the swollen and 'compacted contaminated volume plus the capping depth times the contaminated
area. No estimation was attempted of the excess volume that would have to be dredged due to
slumping of the excavation.
D[SPOSAL COSTS Al'1D FEES
The fee of 50AO;cubic yard proposed by the Washington Department of Natural Resources
(Corlett :lnd Kassebaum 1989) for disposal at PSDDA Phase r disposal sites is used here. [t::5
lDplied only to the ~xcess volume of dean sedimenc removed from rhe coniined ;lqu:ltic ji::iDos:1
5ite. This sediment is presumed .0 meet PSDDA guidelines for open-water uisposaL
CAPPING OF UPLAND/NEARSHORE D[SPOSAL SITE
The unit cost used is based on a cap of J feet of sand :lOd 3 feet of tOpsoil. [n-piace .:osrs
~'or these materiais are taken from Table 5-6 of U.S. Army COE (1985), :lOd inflated from il)82
to 1989 costS at a rate of 5 percent per year. The resulting average unit cost is 523.;)4/cubic :,'ara
.)1' '::lDpin~ material. The :orai volume of .:aopin~ material is comouted by multiolying ~l1e !:oland
jre :lrea :imes :he (leDth ')1 '.:~p i2 ::ardsl. A Slmliar :lpproach could ue' :JKen :0 .:stima[Jng '~:Dprng
costS for a nearshore disposal site. .
This generic cap may not be suitable for all sites; some may require a greater depth of.
material, different material (synthetic fabric, asphalt, concrete, or clay.), revegetation, or other
special measures taken for drainage or erosion control.
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CLEAN SEDIMENT DREDGING FOR CONTAl\1INATED SITE CAP
Dredging of clean sediment is presumed to have a cost equivalent to that of contaminated
sediment dred8in& (S3.oo/cubic yard).
CLEAN SEDIMENT TRANSPORTATION FOR CONTAMINATED SITE CAP
Tl'3DSJ)Ortation of clean sediment is presumed to have a cost equivalent to that of marine
transportation of conmminated sediment (SO.30/cubic yard-mile.).
CONFIRMATION SAMPLING
Conf'mnation sampling fOllowing removal of dredged material is presumed to be carried out
by the collection of a grab sample of the sediment surface rather than a core, following the
suuestion of the Commencement Bay Group (ENSR 1989). The cost of sample collection is
estimated to be SSOO per grab, producing one sample per grab. The number of samples is estimated
as in the feasibility study: two samples per acre, with a maximum of 20 samples at a site.
CONFIRMATION ANALYSIS
Samples taken to coiif"lrin the success of remedial dredging are presumed to be analyzed for
the same contaminants as the samples used to characterize the problem areas. Thus, the analysis
cost varies with the problem area as specified in the feasibility study.
WELL CONSTRUcnON
The costs of establishing groundwater monitoring weDs at. upland and ne:mhore sites are based
on drilling costs of S22.OO per foot, S600 for a screen (Deremer, R., 1989, personal communica-
tion), and an estimated S800 for a pump and equipment deployment. These unit costS were applied
to an estimated 20 wells (the. maximum number of sediment monitoring stations suggested by the
feasibility study) of an average depth of 35 feet (the depth of fill possible at Blair Waterway
Slip I).
MONITORING SAMPLING OF DISPOSAL SITE
Sampling of confined :lQuatic disposal :lnd capping sites is presumed to rake place ~y .;orin~.
JS specified in the feasibility study, with :l cost of S 1.500 per core. Frequency of sampling is tWO
cores per acre, with a maximum of :0 cores. Sampling is presumed [0 be conducted yeariy, :lna
three samples analyzed. from each' core. .
Sampling of groundwater monitoring weBs is estimated to cost $120 per well. based on two
hours of labor at $30 per hour (including sampling by a safety-certified specialist. dooument
control. quaHty :lSSurance. data management. :lnd reporting), 530 0" other direct costS per \vell. 1nd
'1 multiplier or' 1.5. Frequency oJ" sampling is presumed to be ~Quivalent ~o that :'or .;oring :u
.;oniined :lQuatic disposal :lnd capping si[es.
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MONITORING SAMPLE ANALYSIS
Analysis cosu for monitoring samples are presumed to be site-specific, as was assumed for
the analysis cosu for remedial design sampling and confirmation sampling. The site-specific costS
used are those listed in the feasibility study.
ADMINISrRATION
.'
Attmini~tion costs calculated in the feasibility study were as a percentage of all other costs.
A similar approach was taken for the spreadsheet cost analysis. The feasibility study estimate
included engineering costS, however, which were included in the design and permitting
classification in the revised cost analysis. The factor for administration cost was therefore revised
downward from the feasibility study value of 15 percent to 8 percent. The EPA. Remedial A.crion
Cosling Procedures Manutzl (U.s. EPA 1985) suggests a range of 7-15 percent of capital costS for
attmini!ltration, including design and monitoring. The typical cost suggested by the Multiuser
Confined Disposal Siles Program Sludy (Gershman, Brickner, and Bratton 1989) is 6 percent.
CONTINGENCY
A contingency cost of 20 percent of all other costs was applied. This is the same proportion
used for the feasibility study.
OTHER FACTORS
Two factors were used to estimate the effect of sediment swelling and compaction. The
swelling factor determines the increase in sediment volume after dredging and deposition iIi a barge;
and the compaction factor determines the decrease in volume after confinement and compaction
of the sedimenL The swelling factor used for the revised cost estimate is 0.75, meaning that
sediment would increase in volume by 75 percent upon dredging (Church 1981). As noted
previously, this factor may be highly variable, so a value at the upper range of reported swelling
factors was chosen. The compaction factor was chosen so that the net volume change from the
original sediment in place would be an increase of 20 percent; the value of this factor is therefore
selected to be 0.69 (i.e., 1.20/1.75).
The discount rate used for this revised cost catcut:ltion is 7 percent. which is a slightly tower
estimated rate than the current rate of return on 2-year Certific:ltes of Deposit.
The production rate for dredging was presumed to be :00 cubic yards/hour. :IS shown in
Tlble 5-2 of U.S. Army COE (1985) for J 5-.,;ubic yard cJamsheil dredge.
A. dred~ing tift depth of four feet. typical of darnsheU dredges (PSDDA 1988) is used for :his
:alcutation. The actual volume dredged is c:licutated based on che number or dredging iifcs ,hat
wouid compteteiy remove the contaminated ~ediment. Thus. contamination to 1 depth of ::. feet
would require one dredging lift (with overdredgingof 100 percenU. whereas. contamination to ::1
depth of 5 feet would require two dredging lifts (with overdredging of 60 percent I.
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REFERENCES
Church, H.K. 1981. Excavation handbook. McGraw-Hill, New York, NY. 750 pp.

Corlett, R.F., and C. Kassebaum. 1989. Comments on sediment remediation alternatives. Prepared
for the Commencement Bay Group. ENSR Consulting and Engineering. 52 pp.
1'\
l:.
Deremer, R. 1989. Personal Communication (private well drilling cost quote prepared for Mr.
DreaS Nielsen, PTI Environmental Services, Bellevue, W A). Northwest Pump, Inc. .

ENSR. 1989. Technical review and comments, Commencement Bay NearshorejTideflats remedial
investigation and feasibility study. Prepared for the Commencement Bay Group. ENSR Consulting
and Engineering.
Gershman, Brickner & Bratton. 1989. Multiuser confined disposal sites program study, cost
analysis issue paper. Prepared for PTI Environmental Services, Bellevue, W A and Washington
Department of Ecology, Olympia, W A. Gershman, Brickner & Bratton, Inc.
Parametrix. 1989. Conimed disposal of contaminated sediments documentation of standards
development. Draft Report.-P-repared for Washington Department of Ecology. Parametrix, Inc.;
Bellevue, W A.
PSDDA. 1988. Evaluation procedures technical appendix - Phase I (central Puget Sound). Public
Review Draft. Prepared by the Evaluation Procedures Work Group for Puget Sound Dredged
Disposal Analysis. U.S. Army Corps of Engineers, Seattle, W A.
Sumeri, A. 1989. Personal Communication (telephone conversation with Mr. Dreas Nielsen, m
Environmental Services, Bellevue, W A; discussion of recent bids for dredging in Puget Sound).
U.S. Army Corps of Engineers, Seattle District. Seattle. W A.
Tetra Tech. 1988. Commencement Bay nearshorejtideflatS feasibility study. Public Review Dr.lft.
Prepared for the Washington Department of Ecology. Tetra Tech. Inc. Bellevue, W A.
U.S. Army COE. 1985. Evaluation of alternative dredging methods :md equipment. disposal
methods and sites, :lnd site control and treatment' pr.lctices for contaminated sedimentS. U.S. Army
Corps of Engineers. Seattle District. Seattle. W A.
''':.5. EPA, ! 985. Remedial :lction costing proc~dures manual. OSWER Directive -:)355.;J.! O. C'.S.
c:wironmentaj Protection Agency. Office 'J( ReSe:lrCh :lnd Development. H:lzaraous WJsre
S:1~ineering R.esearch Laboratory. 59 pp.
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