Puget Sound Estuary Program
EVERETT HARBOR TOXICS
ACTION PROGRAM
REVIEW OF EXISTING
PLANS AND ACTIVITIES
PREPARED BY:
TETRA TECH, INC.
PREPARED FOR:
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON DEPARTMENT OF ECOLOGY
PROGRAM PARTICIPANTS:
City of Everett
City of MuKilteo
Everett Harbor Citizens Advisory Committee
National Oceanic and Atmospheric Administration
Port of Everett
Snohomish County Health District
Snohomish County Department of Planning and Community Development
Tulalip Tribes
U.S. Army Corps of Engineers
Washington Department of Fisheries
Washington Department of Natural Resources
Washington Department of Social and Health Services
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TC 3991-03
Final Report
EVERETT HARBOR ACTION PROGRAM:
REVIEW OF EXISTING PLANS AND ACTIVITIES
by
Tetra Tech, Inc.
for
U.S. Environmental Protection Agency
Region X - Office of Puget Sound
Seattle, WA
January, 1986
Tetra Tech, Inc.
11820 Northup Way, Suite 100
Bellevue, Washington 98005
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EXECUTIVE SUMMARY
Previous studies of Everett Harbor and the lower Snohomish River have
revealed extensive contamination by toxic metals, organic compounds (such
as petroleum products and PCBs), and bacterial contaminants. Some of these
substances may accumulate at high concentrations in tissues of marine organisms,
posing a hazard to the aquatic ecosystem. For example, toxic contamination
may decrease the abundance and diversity of benthic or bottom-dwelling
communities and increase the prevalence of tissue disorders such as liver
tumors in fish. The bacteriological contaminants may seriously restrict
commercial and recreational shellfish harvesting.
The U.S. Environmental Protection Agency and the Washington Department
of Ecology, working with the city of Everett and others, are developing
an Action Program to correct the toxic problem in the Everett Harbor system.
The Action Program 1) identifies existing problems of toxic contamination,
2) locates sources of toxic contaminants, 3) identifies corrective actions
to eliminate existing problems, 4) identifies appropriate agencies to implement
corrective actions, and 5) provides a schedule to implement corrective
actions.
This report outlines ongoing remedial activities and plans of agencies
presently involved in solving problems of toxic contamination in Everett
Harbor and the lower Snohomish River. This report also identifies gaps
in existing activities and plans, thus serving as a guide for improving
current regulatory and management activities. These improvements, plus
any new regulatory and management activities, will be developed by an Inter-
agency Work Group and summarized in an Interim Work Plan for the immediate
future (i.e., within 2 yr) and a Comprehensive Work Plan for subsequent
years.
Remedial activities and plans are divided into four categories related
to the following: 1) dredging and dredge spoil disposal, 2) municipal
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and industrial point sources, 3) agricultural and urban stormwater runoff
quality, and 4) accidental spills and releases.
In the following descriptions, ongoing activities are identified with
an asterisk. All other activities are either in the planning stages or
are not yet funded.
DREDGING AND DREDGE SPOIL DISPOSAL
Existing Plans and Activities
Puget Sound Dredged Disposal Analysis (PSDDA)*: The U.S. Army
Corps of Engineers, in cooperation with Washington Department
of Ecology, plans to identify procedures to: 1) assess
the acceptability of dredged material for open-water disposal,
and 2) locate acceptable sites for unconfined, open-water
disposal of dredged material.
Decision Criteria for Unconfined Disposal of Dredged Material
at the Port Gardner Site*: The U.S. EPA, City of Everett,
and Washington Department of Ecology require that dredged
materials be less contaminated than ambient central Puget
Sound sediments and sediments at the existing disposal site.
Dredging to Support Proposed Carrier Battle Group: An estimated
2.5 million cubic yards of marine sediments might be dredged,
including contaminated sediments in East Waterway, to support
berthing space and facilities for 13 U.S. Navy ships. An
additional 1 million cubic yards of material may be removed
from shoreline areas and used as fill to support land-based
activities.
t Port of Everett Expansion: Concurrent with planned U.S. Navy
activities, the Port of Everett has filed an application
to dredge 600,000 cubic yards of material for terminal and
industrial complex improvements. Contaminated material
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may account for 50,000 of the 600,000 yd3 removed. Five
hundred thousand cubic yards of removed material would be
used as fill.
Planning Gaps
t PSDDA is not intended to identify contaminated sediments
or to propose disposal or cleanup options.
t Interim disposal criteria for the Port Gardner site may
prevent the use of the site as a repository for some contaminated
sediments from Navy and Port Gardner related dredging.
No existing programs address management of contaminated
"hot spots."
WASTEWATER TREATMENT
Existing Plans and Activities
Section 201 Lower Snohomish Basin Facilities Plan: This
study, commissioned by U.S. EPA and Washington Department
of Ecology and completed in 1980, identified problems related
to wastewater treatment facilities within the Snohomish
Basin and provided recommendations for the correction or
improvement of the problems.
Everett Wastewater Treatment Plant Expansion: The City
of Everett's Wastewater treatment plant is currently overloaded
and is frequently in violation of permit standards. Expansion
will begin in 1986 and will occur in two phases. Phase 1
will involve the construction of a 100-acre oxidation pond,
a recirculation channel, and sludge transfer facilities.
Phase two construction will include the expansion of existing
aeration lagoons and the addition of new lagoons.
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City of Everett - Proposed Pretreatment Program: This program,
which is expected to begin in late 1985, involves seven
tasks: 1) conduct an industrial waste survey, 2) develop
discharge limitations, 3) review the City's legal authority,
4) develop a monitoring enforcement system, 5) provide public
participation, 6) evaluate equipment and facility needs,
and 7) evaluate funding.
City of Everett - Subregion Interceptor Sewers*: In 1980,
the city proposed to construct and operate interceptors
to transport sewage from the south end of Everett, north
to the treatment plant. Development and operation of the
southwest interceptor (1983 - 1985) eliminated raw sewage
outfalls and reduced flows to the north end combined sewers.
Lake Stevens Treatment Plant Upgrade*: The City of Lake
Stevens is in the process of upgrading their aerated lagoon
plant to an activated sludge process (1985-1987).
City of Mukilteo - Comprehensive Sewer Plan; Less than
half the population of Mukilteo is served by a primary-level
treatment plant that has consistently violated its permit
limitations for BODs and suspended solids. The city plans
to shut down its treatment plant in 1987 when its effluent
can be transferred to the nearby Olympus Terrace plant.
Planning Gaps
t There will be a need for additional construction of interceptor
sewers, especially in areas undergoing rapid development.
With the exception of Everett's proposed pretreatment program,
wastewater treatment plans do not address toxicants directly.
State pretreatment programs currently lack adequate funding
and staffing.
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t The Mukilteo treatment plant presently lacks an interim
plan for improving the quality of its effluent before diversion
to the Olympus Terrace system.
There is generally inadequate funding, planning, and interagency
coordination of wastewater treatment programs.
URBAN AND AGRICULTURAL RUNOFF
Existing Plans and Activities
t 208 Area-Wide Drainage Plan*: The plan, initiated in 1976,
resulted in several management tools still in use, including:
Farm Water Quality Management Manual describing best
management practices (BPMs) for various agricultural
activities
Ongoing development of permit requirements for manure
lagoons
Four comprehensive Basin Plans
Drainage ordinances and a drainage study for Mukilteo.
Watershed Management Activities*: As part of an overall
watershed management process, Snohomish County has developed
several programs that will lead to better source controls,
including: 1) a stream rehabilitation program to restore
stream habitats, 2) a retention/detention inventory of 500-600
facilities to assess their condition and usefulness, and
3) a cost sharing agreement between Snohomish County and
Marysville to install stormwater detention ponds in Allen
Creek.
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Shoreline Master Programs*: The Snohomish County Shoreline
Plan has several policies that are intended to reduce the
impacts of log storage.
Planning Gaps
Most runoff control programs depend on future development
as a primary source of funding
With the exception of Drainage Ordinances and other runoff-
related permit requirements, most runoff controls (for example,
best management practices) are voluntary
Current plans which could address runoff control (e.g.,
Shoreline Master Programs, drainage ordinances) do not focus
on controlling toxicants in stormwater, rather they are
primarily concerned with volume and velocity problems.
OTHER SOURCES
Existing Plans and Activities
Department of Defense Fuel Support Activities, Mukilteo*:
An investigation of groundwater (1980-1984) contamination
revealed a leaking fuel storage tank. The tank is no longer
in use.
t Everett Landfill Tire Fire*: A fire burned for five months
(9/84 to 1/85) in a pile of approximately one million tires
at the closed Everett landfill. Because of the possibility
of heavy metal contamination of nearby waterways, the following
actions were taken:
A soil berm was constructed to prevent contaminated
runoff from entering the Snohomish River
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The site was fenced, and warning signs were posted
Burlington Northern Railroad ditches will be cleaned
of contaminated sediments.
Cathcart leachate disposal*: The county is currently reviewing
options for the disposal of Cathcart Landfill leachate.
These include: 1) continued treatment by the Everett sewage
treatment plant, 2) treatment by the City of Snohomish treatment
plant, and 3) on-site treatment. Beginning in November,
1985, Snohomish County will begin aerating the leachate
in holding ponds, and treating it with nutrients to reduce
BOD5>
Tulalip Landfill Site Investigation and Landfill Capping:
The closed landfill is a potentially significant source
of inorganic chemicals. Plans to cover the landfill with
clay and develop the site are being reviewed by several
agencies.
Planning Gaps
t There are no anticipated cleanup activities planned for
the Department of Defense fuel storage facility, even though
data suggest there are significant quantities of jet fuel
(JP-4) in the groundwater and marine sediments of the area.
There is no county or city-sponsored public education program
for the use and disposal of hazardous materials.
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TABLE OF CONTENTS
Page
INTRODUCTION 1
1.0 IDENTIFICATION OF PROBLEM ISSUES 4
1.1 Identification and Control of Sources of Toxicant
and Pathogenic Contamination 4
1.2 Toxic Contamination and Cleanup of Everett Harbor
Sediments 6
1.3 Need for Cooperation and Commitment Among Agencies
Responsible for Water Quality 7
2.0 REMEDIAL ACTIONS AND PLANS 8
2.1 Dredging and Disposal of Contaminated Material 8
2.1.1 Puget Sound Dredged Disposal Analysis Study.. 8
2.1.2 Interim Decision Criteria for Unconfined
Disposal of Dredged Material at the Port
Gardner Open-Water Disposal Site 13
2.1.3 Proposed Homeport for a Carrier Battle
Group in the Port of Everett 17
2.1.4 Dredge and Fill Permit for Port of Everett's
Terminal/Industrial Complex Site Improvements 19
2.1.5 Detailed Chemical and Biological Analysis of
Selected Puget Sound Sediments 20
2.1.6 Evaluation of Dredging/Dredge Disposal
Programs 22
2.2 Treatment and Disposal of Municipal and Private
Wastewater 22
2.2.1 Sec. 201 Lower Snohomish Basin Facilities
Plan 23
2.2.2 National Industrial Pretreatment Program 25
2.2.3 State of Washington Senate Bill No. 3812 28
2.2.4 State of Washington Substitute House Bill
No. 815 (Section 1) 28
2.2.5 State of Washington Substitute House Bill
No. 815 (Section 2) 30
2.2.6 Treatment Lagoon and Trickling Filter
Standards 31
2.2.7 Miscellaneous Treatment Guidelines and
Criteria Revisions 31
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Table of Contents (Cont'd)
2.2.8 Everett Wastewater Treatment Plant
Expansion FEIS 32
2.2.9 City of Everett - Proposed Pretreatment
Program 33
2.2.10 City of Everett - Subregion Interceptor
Sewers 34
2.2.11 Lake Stevens - Treatment Plant Upgrade 35
2.2.12 City of Mukilteo - Comprehensive Sewer Plan.. 35
2.2.13 Evaluation of Municipal Wastewater
Treatment/Disposal Programs 36
2.3 Control of Urban and Agricultural Runoff 37
2.3.1 208 Area-Wide Drainage Plans 37
2.3.2 Watershed Management Activities 39
2.3.3 State of Washington Substitute House Bill
No. 814 40
2.3.4 Shoreline Master Programs 40
2.3.5 Evaluation of Runoff Control Programs 40
2.4 Control of Other Point Sources 41
2.4.1 Department of Defense Fuels Support
Activities, Mukilteo 41
2.4.2 Everett Landfill Tire Fire 42
2.4.3 Cathcart Leachate Disposal 43
2.4.4 Tulalip Landfill Site Investigation and
Landfill Capping 44
2.4.5 RCRA 3012 Preliminary Site Investigations 44
2.4.6 Hazardous Materials Response Program 45
2.4.7 Evaluation of Other Point Sources 45
REFERENCES 47
APPENDIX - Agency Staff Interviewed 50
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LIST OF TABLES
Table
Number Page
1 Plans and Activities Addressing Toxic and Pathogenic
Pollutant Problems Affecting the Everett Harbor Action
PI an Project Area 9
2 Lower Snohomish Basin 201 Study Recommendations and
Status 24
3 Regulated Industrial Categories Subject to EPA
Categorical Pretreatment Standards 26
4 EPA Region 10 Listing of Categorical Industries,
Everett, Washington 27
5 Active NPDES or State Waste Discharge Permits in the
Project Area 29
6 RCRA Section 3012 Preliminary Assessment Sites within
the Project Area 46
LIST OF FIGURES
Figure
Number Page
1 Everett Harbor Action Plan Project Area 2
2 Puget Sound Dredged Disposal Analysis 14
3 Decision Flow Chart for Proposed Port Gardner Interim
Dredged Materials Disposal Criteria 16
4 Preferred U.S. Navy Proposed Homeporting Disposal
Location and Bottom Profile of Confined Aquatic Disposal. 18
5 Port of Everett Proposed Site Improvements 21
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ACKNOWLEDGMENTS
This document was prepared by Tetra Tech, Inc., under the direction
of Dr. Robert A. Pastorok, for the U.S. Environmental Protection Agency
in partial fulfillment of Contract No. 68-03-1977. Mr. John Underwood
and Ms. Martha Burke of U.S. EPA were the Project Officers, and Dr. Thomas
C. Ginn of Tetra Tech was the Program Manager.
The primary author of this report was Ms. Patricia O'Flaherty of JRB
Associates (a Company of Science Applications International Corporation).
Mr. Pieter N. Booth, Dr. Robert A. Pastorok, and Ms. Marcy B. Brooks-McAuliffe
of Tetra Tech contributed to the writing and editing. Initial drafts of
the report were produced for Tetra Tech by JRB Associates under the direction
of Mr. Richard W. Greiling. Ms. Martha Burke and Mr. John Underwood of
U.S. EPA reviewed the draft report. Review comments were also provided
by members of the Everett Harbor Interagency Work Group and the Citizens
Advisory Committee. Special assistance in compiling information on existing
plans and activities was provided by the agency representatives interviewed
during the project (Appendix 1).
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INTRODUCTION
Increasing public concern has been expressed regarding the water quality of
Puget Sound, particularly within its urban embayments. In Everett Harbor,
toxic chemicals and pathogenic contamination have been identified as a signifi-
cant problem. This report summarizes the major issues of concern identified
by representatives of key government agencies responsible for water quality
issues within the Everett Harbor area. It also identifies and evaluates exist-
ing agency plans and corrective actions relating to toxicant and pathogenic
contamination of Everett Harbor. The Everett Harbor Action Program area encom-
passes Possession Sound south and east of Tulalip Bay, the lower Snohomish
River upstream to Interstate 5, and Port Gardner north and west of Mukilteo
and west of Everett (see Figure 1).
This report has been prepared following an extensive information-gathering
effort including a review of relevant planning documents, proposed and
existing ordinances, environmental impact statements, and permit applications
for projects within or affecting water quality within the study area. Inter-
views were conducted during June and July 1985 with agency officials directly
responsible for planning and/or implementing water quality plans and programs.
Organizations at local, state, and federal levels of government were contacted
during this effort, including:
U.S. Army Corps of Engineers (COE)
t U.S. Environmental Protection Agency (EPA)
t U.S. Navy Homeporting Information Office
Washington Department of Ecology (WDOE)
Washington Department of of Transportation (WDOT)
Washington Department of Social and Health Services (DSHS)
0 Washington Department of Fisheries (WDF)
Tulalip Tribes
Snohomish County Planning Division
Snohomish County Solid Waste Division
Snohomish County Health District
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Marysville
Possession Sound
Slough
Steamboat
Slough
Snohomish
River
Figure 1
EVERETT HARBOR ACTION PLAN PROJECT AREA
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City of Everett
City of Mukilteo
City of Marysville
City of Snohomish
City of Lake Stevens
Port of Everett
A list of individuals interviewed appears in the Appendix of this report,
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1.0 IDENTIFICATION OF PROBLEM ISSUES
A review of planning documents and programs, and interviews with 43 agency
representatives, revealed activities and plans ranging from area-wide compre-
hensive planning for water quality improvements (e.g., basin studies) to
implementation of site-specific programs (e.g., stormwater detention facili-
ties). Planning efforts include technical engineering designs of wastewater
treatment plants and storm and sewer systems, monitoring designs, and regula-
tions and ordinances. Currently, only federal and state agencies have devel-
oped plans or programs to deal with toxicant and/or pathogenic contamination.
Many of these plans are a result of efforts to clean-up or protect Puget Sound
in general and thus do not necessarily focus specifically on the Everett
Harbor area. Nevertheless, Everett Harbor would benefit from these programs.
With few exceptions, local programs do not specifically address abatement of
toxicant and pathogenic contamination in Port Gardner and the lower Snohomish
River. There are, however, three major issues which should not be overlooked
by plans or remedial programs of relevant organizations. These issues include:
t Identification and control of sources of toxicant and pathogenic
contamination.
Toxic contamination and cleanup of Everett Harbor sediments.
The need for cooperation and commitment among agencies responsible
for water quality.
The following sections provide a brief description of each issue.
1.1 IDENTIFICATION AND CONTROL OF SOURCES OF TOXICANT AND PATHOGENIC
CONTAMINATION
Recent studies of sediments in Everett Harbor have shown the presence of toxic
contaminants including heavy metals and organic chemicals in concentrations
more than one order of magnitude (ten times) higher than those found in the
non-urban reference bays. Fish and shellfish abnormalities have been observed
in areas with elevated toxicants.
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Monitoring of water and sediment quality by the National Oceanic and Atmos-
pheric Administration (NOAA), Municipality of Metropolitan Seattle (Metro),
Washington Department of Ecology (WDOE), and the Environmental Protection
Agency (EPA) have indicated several sources of toxicant contamination entering
into Puget Sound, particularly in urban embayments including Commencement Bay,
Elliott Bay. and Everett Harbor.
In 1977, the SNOMET/King County 208 Water Quality Management Plan identified
nonpoint pollution of the estuarine segments of both the Snohomish River and
the Stillaguamish River as the major water quality problem in the area. Two
major sources of these problems were cited: (1) nonpoint pollutants carried
into the harbor by the Snohomish River from upstream agricultural activities
and (2) point source discharges of municipal and industrial wastewater.
Another significant nonpoint source problem attributed to urban and suburban
land use activities was severe stream degradation caused by flooding, erosion,
sedimentation, and toxicant runoff. Due to the number of discharges from
sewage treatment plants, industrial communities, and nonpoint sources, the
Washington Department of Social and Health Services (DSHS) has categorically
classified the entire eastern shore of Puget Sound, from the Tacoma Narrows to
Everett (including Everett Harbor) as uncertifiable for commercial shellfish-
ing. Very little information exists concerning actual bacterial or toxic
contamination of shellfish in Everett Harbor.
There are few contaminant data (either historical or current) for specific
sources such as groundwater, surface water, or combined sewer overflows
(CSOs). Two major Everett industries, the Weyerhaeuser Company and Scott
Paper, Inc., sampled priority pollutants in their discharges only for the
NPDES permit application process, and do not routinely sample for priority
pollutants. Everett's treatment plant effluent was sampled twice for priority
pollutants: once during dry weather and once during a rainy period. Monitor-
ing programs regulated under state or NPDES discharge permits do not include
testing for potentially toxic organic compounds. Finally, there is little
mass loading data for these sources. Based on these data gaps, it is difficult
to rank most of these sources according to their relative pollutant contribu-
tion, their environmental impacts, or their risk to public health.
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1.2 TOXIC CONTAMINATION AND CLEANUP OF EVERETT HARBOR SEDIMENTS
Public concern about toxic contamination of Puget Sound marine sediments
resulted in the temporary closure of the Port Gardner Disposal Site for
dredged material. Chemical analyses of sediments in East Waterway undertaken
for the U.S. Navy's proposed Homeport project revealed areas with elevated
levels of heavy metals, polynuclear aromatic hydrocarbons, and polychlorinated
biphenyls (U.S. Navy FEIS 1985). The U.S. Navy's proposed homeporting facil-
ity in the East Waterway would require the dredging and subsequent disposal of
an estimated 2.5 million cubic yards of marine sediments for navigation pur-
poses. Removed material includes contaminated sediments in the East Waterway.
This proposed action has generated concern regarding the immediate and long-
term impacts on human health as well as to the marine environment. Surface
sediments in the East Waterway cannot be classified as "extremely hazardous
waste" according to the state of Washington's Dangerous Waste Regulations (RCW
173-303), and the determination of "dangerous waste" status must be made
before any permit is issued. However, unconfined disposal of much of this
material would violate the Port Gardner Chemistry Criteria for dredged spoils
disposal. This criterion is an interim dredged materials disposal standard
developed by EPA and WDOE in response to public concern regarding dredge
spoils disposal in the Port Gardner area.
Management of dredged materials is complicated by the following factors:
t Lack of sediment quality criteria.
Incomplete knowledge about toxicant loading and transport charac-
teristics.
t Incomplete knowledge about bioaccumulation and biomagnification
effects.
Inadequate evaluation of alternative dredging and disposal opera-
tions.
0 Inadequate evaluation of alternative disposal locations.
Further complicating the controversy over dredged materials disposal is the
ongoing need for routine maintenance dredging of navigation channels. The
major agencies concerned with the management of dredging and dredged material
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disposal are the COE, EPA, WDOE, AND DNR. A more detailed discussion of
policies and programs relating to dredging are presented in Section 2.0 of
-this report.
1.3 NEED FOR COOPERATION AND COMMITMENT AMONG AGENCIES RESPONSIBLE FOR
WATER QUALITY
The identification and elimination of toxic and pathogenic contamination in
the lower Snohomish River and Port Gardner depends largely on the abilities of
the involved agencies to coordinate their plans and actions. Coordination is
effective because it allows each agency to more efficiently use its limited
resources. Discussions with agency representatives indicate that cooperation
is needed among all agencies in order to fulfill their individual and collec-
tive responsibilities. It was suggested by several local agencies that they
be permitted the opportunity to work with state and federal agencies in order
to develop plans, regulations, and permits that are compatible with or assist
local program goals. Local agencies would like to "co-review" projects with
state and federal agencies in order that their concerns or issues are promptly
identified.
The goals and schedules of each agency should reflect the constraints of all
affected agencies and/or their programs. Agreement among agencies on problem
identification and priorities for action would provide a good starting place
for the growth of extensive cooperative efforts. Overall, agency representa-
tives interviewed for this study emphasized that communication among all
levels of government regarding planned activities is the most essential factor
in implementing and coordinating efficient programs and actions to correct
water and sediment quality problems.
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2.0 REMEDIAL ACTIONS AND PLANS
A variety of remedial actions and plans have been developed by the involved
agencies to deal with the issues discussed in Section 1.0 of this report.
These action programs are directed towards four major categories of problems:
Dredging and disposal of contaminated material.
Treatment and disposal of municipal and private wastewater.
Controls of urban and agricultural runoff.
Control of other point sources
For each of the four problems above, Table 1 identifies relevant programs or
plans, identifies agencies with principal responsibilities, and describes the
program or plan and its implementation status.
2.1 DREDGING AND DISPOSAL OF CONTAMINATED MATERIAL
The following programs were developed to identify impacts of contaminated sedi-
ments on the marine environment and human health, identify acceptable disposal
locations and management strategies, and/or limit current and future toxicant
contributions to the Port Gardner Area and throughout Puget Sound.
2.1.1 Puget Sound Dredged Disposal Analysis Study (PSDDA)
Lead Agency: Corps of Engineers
Cooperating Agencies: Washington Department of Natural Resources; Washington
Department of Ecology; EPA Region 10
Time Frame: Phase I (includes Everett Harbor) - (April, 1985 - April, 1987)
Phase II (April, 1986 - April, 1988)
The Puget Sound Dredged Disposal Analysis is a three-year study of unconfined,
open-water disposal of dredged material in Puget Sound. The study is being
undertaken to provide a decision-making approach for unconfined, open-water
disposal of dredged material. It is being undertaken as a cooperative effort
by the above state and federal agencies with regulatory responsibility for
dredged spoils disposal and it is also a part of the Puget Sound Estuary
Program.
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Table 1
PLANS AND ACTIVITIES ADDRESSING TOXIC AND PATHOGENIC
POLLUTANT PROBLEMS AFFECTING THE EVERETT HARBOR ACTION PLAN PROJECT AREA
PROBLEM: DREDGING AND DISPOSAL OF CONTAMINATED MATERIAL
PROGRAM
Puget Sound Dredged Disposal
Analysis (PSDDA)
Interim Dredgod Disposal
Criteria for Port Gardner
Proposed U.S. Navy Homportlng
of Carrier Battle Group (CBG)
at Norton & Pacific Terminals
in the Port of Everett*
Port of Everett Expansion*
Detailed Chemical and Bio-
logical Analyses of Selected
Puget Sound Sediments
LEAD AGENCY
COE
EPA/C1ty of Everett
U.S. Navy
Port of Everett
EPA (Battelle)
TIME FRAME
1985-1988
1985
1987-1990
Concurrent
with Navy CBG
Homeport
Construction
1984, 1985
ACTION
Develop long-term procedures for disposal of dredged sediments; locate
acceptable open-water disposal sites and establish site management plans.
Formulation of Interim criteria for unconfined, open-water dredged sedi-
ment disposal. This action would permit acceptable dredging activities
in Port Gardner until PSDDA Is completed.
Preferred CBG homeportlng alternative as identified 1n the 1985 FEIS
Includes open-water disposal of estimated 2.5 million cubic yards of
bottom sediments, some contaminated, to develop berthing for facility.
Port's Dredge and Fill Application to COE for proposed terminal /Industrial
complex site Improvements; application to dredge over 600,000 cubic yards
(August 6, 1985).
Physical and chemical analyses of Puget Sound surface sediments. Program
compares sediments from urban areas (Port Gardner Included) and reference
areas. The purpose of this project Is to gather scientific data. It 1s
not a regulatory or remedial action.
*These programs/actions are currently only In their planning stages and were not Implemented at the time of this writing.
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Table 1 (cont'd)
PROBLEM: TREATMENT AND DISPOSAL OF MUNICIPAL AND PRIVATE WASTEWATER
PROGRAM
201 Lower Snohomish Basin
Facilities Plan
National Industrial Pretreat-
ment Program
Washington House Bill No.
3812
Washington Substitute House
Bill No. 815
Citizens Advisory Comnittee
Review of Standards for Trick-
ling Filters and Lagoon Treat-
ment Facilities
Miscellaneous Treatment Guide-
lines and Criteria Revisions
Everett Proposed Wastewater
Treatment Plant Expansion*
Everett Proposed Pretreatment
Program*
Everett Subregion Interceptor
Sewers Plan**
Lake Stevens Treatment Plant
Upgrade
Mukilteo Comprehensive Sewer
Plan*
LEAD AGENCY
Snohomish Basin
Sewer Districts
& Municipalities
EPA/DOE
DOE
DOE/PSWQA
DOE
DOE
City of Everett
City of Everett
City of Everett
Lake Stevens,
DOE, CERB
City of Mukilteo
TIME FRAME
1976-1980
1978-Ongoing
1985-1986
1985-1988
1985
1985-1986
Begin Construc-
tion in 1987
1985
1980-Ongolng
1985
1985-1987
ACTION
Identified municipal vastewater problems and recommended capital Improve-
ments to areawide sewer facilities and systems. This action represented
a study and review only, it Is not a specific regulatory or remedial action.
Increased monitoring and enforcement of categorical pretreatment standards;
updated survey of Industrial facilities.
Sec. (1) - Report all enforcement actions regarding Puget Sound protection,
hold public hearings on report, and prepare summary for legislature.
Sec. (2) - Establishes new, stricter penalties for waste discharge permit
violators.
Sec. (1) - Requires review of existing pretreatment standards for industrial
wastewater discharged Into sewage facilities that discharge Into Puget
Sound.
Sec. (2) - Requires plans and compliance schedules for greatest reasonable
reduction of CSOs. These actions represent studies and review only,
they are not specific regulatory actions.
Review of new federal 30/45 standards; recommending (1) whether state
should promulgate secondary treatment standards, and (2) how federal stan-
dards would Impact existing and proposed Washington facilities. This action
represents a review of existing standards and is not a regulatory action.
(1) Revise sewage works design criteria. (2) revise dilution zone criteria
standards, (3) review chlorine disinfection guidelines. These actions
represent a review and are not regulatory actions.
FEIS to upgrade treatment lagoon (Alternative 2) (see Table 2).
Undertake an Industrial waste survey and develop discharge limitations to
ensure program compliance.
Southwest Interceptor completed; extends treatment plant service area and
reduces CSO flows in the north end.
Plant upgraded to activated sludge treatment; extended diffuser 200 feet
in Ebey Slough.
Tie-In Mukilteo1 s waste water to Olympus Terrace sewer district; dismantle
primary treatment plant.
*These programs/actions are currently only In their planning stages and were not Implemented at the time of this writing.
**This program is currently in effect but is Implemented In stages.
-------
Table 1 (cont'd)
PROBLEM: CONTROL OF URBAN AND AGRICULTURAL RUNOFF
PROGRAM
Areawide Drainage Plans and
Regulations: SNOMET/King
County 208 Plan**
South Everett Drainage Basin
Plan**
Snohomish/Lake Stevens Basin
Plan
Storm and Sanitary Sewer Study
Marysville Comprehensive
Basin Plan*
Hukilteo Storm Drainage Study*
Everett EMC Drainage Code
No. 670-80-514-78**
Snohomish County Title 24
Drainage Ordinance**
Revised Lagoon Guidelines
Watershed Management Activi-
ties
House Bill 814
Shoreline Master Program (SMP)
LEAD AGENCY
Snohomish County,
King County
City of Everett
City of Snohomish,
City of Lake Stevens
Paine Field
City of Marysville
City of Mukilteo
City of Everett
Snohomish County
Snohomish County,
SCS
Snohomish County
County Legislatures
City of Everett,
Snohomish County
TIME FRAME
1976-Ongoing
1982
1979
1981
1983
1985
1980
1980
1984-1985
I980-0ngo1ng
1985
1974-Ongoing
ACTION
Identifies problems and designates agencies for corrective programs. This
action represents a comprehensive planning study, it is not a specific
remedial or regulatory action.
FEIS Identifies structural improvements and policy/ordinance revisions.
This action represents a comprehensive planning study, it is not a specific
remedial or regulatory action.
Basin plan with resource protection goals. This action represents a com-
prehensive planning study, it is not a specific remedial or regulatory
action.
Identified structural improvements to accomodate future expansion and
development; performed improvements to Japanese Gulch retention pond.
Designates stream corridors and recommends development of stream setbacks.
FEIS includes proposed structural improvements and new drainage policies.
Requires a drainage plan and runoff controls for development projects.
Uses permit fees to Implement drainage controls.
Requires a detailed drainage plan for development projects In designated
critical areas and requires runoff controls. Regulations In this Ordinance
were revised in September, 1985. Uses permit fees to implement drainage
controls.
Provide design guidelines of manure holding ponds for dairy land agriculture.
Programs Include stream rehabilitation projects and retention facility
Inventory.
Provides for county legislatures to establish shellfish protection zones
and regulatory measures to eliminate or decrease pollutants in stormwater.
Shoreline use controls through shoreline planning and a master use permit
process to help control runoff from agricultural areas.
*These programs/actions are currently only in their planning"stages and were not implemented at the time of this writing.
**These programs are currently in effect, but they are implemented in stages.
-------
Table 1 (cont'd)
ro
PROBLEM: CONTROL OF OTHER POINT SOURCES
PROGRAM
DoD Fuels Support Facilities,
MuMlteo Groundwater Monitor-
Ing
Everett T1re F1re Investiga-
tion
Cathcart/Lake Stevens Leach-
ate Disposal Problems
Tulalip Landfill Site Investi-
gation
Tulalip Landfill Capping
RCRA Section 3012 Investiga-
tion
Hazardous Materials Response
Team
LEAD AGENCY
DoD, EPA
City of Everett
Snohomlsh County,
City of Everett
WDOE, EPA
Tulalip Tribes
WDOE
City of Everett
Fire Department
TIME FRAME
1983-1984
1984-1985
1985
1984-Ongolng
1985
1984-1985
1985
ACTION
Groundwater Investigation of DFSP terminal; results Indicate contamination ,
from JP-4 and associated organ ics. At present, no remedial actions have
occurred at this site.
Site Investigation completed, protective and remedial actions Implemented
on-slte. More comprehensive remedial actions are expected In 1986.
County reviewed options to treat landfill leachate possibly on-slte or
transferring to Snohomlsh wastewater treatment plant. The county will
Increase pretreatment of leachate on-slte in November, 1985.
RCRA site Inspection of closed landfill to assess environmental and health
risks.
Proposed barge loading facility to accept fill material (from 1-90 construc-
tion) to cover Tulalip Landfill on Steamboat Slough.
Preliminary assessments of potential hazardous waste locations statewide.
This action represents a review only; It Is not a regulatory or remedial
action.
Fire fighters trained to recognize and handle hazardous materials.
-------
The objectives of the study are:
Identify acceptable sites for unconfined, open-water disposal of
dredged material in Puget Sound.
Identify procedures to assess the acceptability of dredged material
for open-water unconfined disposal, and for alternatives to uncon-
fined disposal.
Formulate plans to manage confined, open-water disposal sites in
Puget Sound.
Generate an Environmental Impact Statement (EIS) for the study's two
phases.
The EIS will be prepared in order to assess the potential impacts of several
alternatives and to obtain public input for these assessments. Six public
meetings were held in May 1985 to discuss the proposed scope of the study and
to receive public comment on it. The EIS will address alternatives to uncon-
fined, open-water disposal; identify chemical and biological evaluation pro-
cedures for testing dredged materials; and define monitoring and management
needs for disposal sites. Phase I, initiated in April 1985, includes the
Central Sound (including Everett Harbor) and will take approximately two years
to complete; Phase II will include the remainder of Puget Sound (and other
marine inland waters of Washington) and will start in April 1986. The boun-
daries of the study areas are presented in Figure 2.
2.1.2 Interim Decision Criteria for Unconfined Disposal of Dredged Material
at the Port Gardner Open-Water Disposal Site
Lead Agencies: EPA; City of Everett; WDOE
Time Frame: Final Draft Criteria developed in the fall of 1985.
The major open-water disposal site for dredge material from Everett Harbor and
the lower Snohomish River channel and delta is a 58-acre site located in Port
Gardner, approximately 1,000 yards from Howarth Rock in water 250 to 400 feet
deep. In July 1984, a conditional use permit (No. SMA #2-84) was granted to
WDNR by the City of Everett to allow continued operation of the disposal site.
Condition No. 7 of the permit states that the operation or use of the site
"... shall be contingent upon EPA using disposal criteria which shall be
developed and approved by the City Planning Department prior to any additional
13
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CANADA
WASHINGTON
Foulweather
Bluff
Everett
Double Bluff
Legend .
Phase I Study Area
Phase II Study Area
Existing Disposal Sites
Seattle
-N-
Tacoma
Narrows Bridge
Shelton <
Olympia
Source: COE, PSDDA, 1985
Figure 2
PUGET SOUND DREDGED DISPOSAL ANALYSIS
14
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disposal activity on the subject property." (City of Everett 1984). According
to the planning department, it was not the city's intent to ban disposal
activities, but to encourage the development of adequate standards that
consider contamination levels (B. Landles, City of Everett, pers. comm., July,
1985). EPA Region 10 was requested to develop standards as they had accom-
plished with WDOE for the Fourmile Rock Disposal Site in Elliott Bay near
Seattle.
EPA agreed that until the PSDDA EIS was completed, an interim management
approach was needed to control open-water disposal of dredged material in
areas such as Port Gardner. Draft interim decision criteria for the Port
Gardner site were developed in May 1985 and revised in September 1985. These
criteria require that dredged materials be less contaminated than both ambient
central Puget Sound sediments and sediments at the Port Gardner disposal site.
Applications to dispose of dredged material at this location will be reviewed
according to the decision flow chart presented in Figure 3.
A public hearing will be scheduled by the city to allow for review and comment
on the revised criteria. Approval by the city's planning department and the
city council is necessary prior to criteria implementation. It should be
emphasized that when approved, these criteria will be a temporary solution
(one to two years), until information and management decisions from the PSDDA
program are available. Furthermore, these criteria pertain only to uncon-
fined, open-water disposal and do not address alternative disposal strategies.
The City of Everett would like to move the present Port Gardner deep water
disposal site to a new location approximately two miles northwest of the
Howarth Park Shoreline (122° 16' 35" longitude, 47° 59' 10" latitude). The
city prefers this location over the present one for two principal reasons:
t The present location is only one-half mile from the city's only
improved saltwater beach.
The preferred site has an average depth of 420 feet as compared to
the existing site depth of 318 feet. The city has asked that this
preferred site be evaluated in the PSDDA process.
15
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Where is Location
of Dredging?
Low
Concern Area!
In-Water Disposal
Not Approved
Yes
In-Water Disposal
Not Approved
Yes
Chemical Testing
Conventional
Heavy Metals
Are Heavy Metals
Concentrations Greater
Than Ambient Levels
in Central Puget
Sound and the Port
Gardner Disposal Site?
No
Are Oil and Grease
Concentrations
Greater Than 0.1%?
Yes
No
Chemical Testing
Base/Neutral
Priority Pollutants
Are Base /Neutral
Priority Pollutant Con-
centrations Greater
Than Ambient Levels
in Central Puget
Sound and the Port
Gardner Disposal Site?
jModerafe and High
Concern Areas
Chemical Testing
Conventional
Heavy Metals
Priority Pollutants
Are Heavy Metals
and Priority Pollutants
Concentrations Greater
Than Ambient Levels
in Central Puget Sound
and the Port Gardner
Disposal Site?
Yes _
In-Water Disposal
Not Approved
fiO
Amphipod Bioassay
Sediment Test
Is the Mean Survival
Rate Greater Than or
Equal to 16.0%?
No _
In-Water Disposal
Not Approved
Yes
In-Water Disposal Approved
Source: EPA (Sept. 1985)
Figure 3
DECISION FLOW CHART FOR PROPOSED PORT GARDNER
INTERIM DREDGED MATERIALS DISPOSAL CRITERIA
16
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2.1.3 Proposed Homeport for a Carrier Battle Group in the Port of Everett
Lead Agency: U.S. Navy
Time Frame: FEIS submitted in the summer of 1985; proposed construc-
tion period is from 1987-1990.
The U.S. Navy proposes to construct and operate a Carrier Battle Group (CBG)
Homeport at the Norton Avenue Terminal in Everett. The CBG would accommodate
13 ships including one aircraft carrier. New facilities, including berthing
space for the 13 ships, would be constructed and this would require the dredg-
ing and disposal of an estimated 2.5 million cubic yards of marine sediments,
some of which are contaminated. The preferred disposal location is the deep
delta site (Figure 4a). The preferred disposal method is covering contami-
nated sediments with clean materials (i.e., native marine sediments and
dredged material from the shoreline, Figure 4b) called "capping". Navy plans
also call for the removal of one million cubic yards of beach, shoreline, and
upland material to accommodate land-based uses. Most of this material would
probably be used as fill elsewhere on the site.
As part of the U.S. Navy's EIS process, several environmental studies were
undertaken. These studies do not specifically address water quality or
pollutant issues, but provide baseline characterizations of the Port Gardner
environment. These studies include:
Seabird and Marine Mammal Survey - Weekly censuses from September
1984 until May 1985 to document existing use of the project area and
surroundings by seabirds, waterfowl, marine mammals, and, particu-
larly, threatened or endangered species.
Juvenile Salmonid Stomach Content Analysis - This study, undertaken
during the spring and summer of 1984, was designed to identify the
food types and quantities consumed by juvenile salmonids found in
the project area.
Benthic and Epibenthic Analyses - Forty-five benthic sediment sam-
ples and 41 epibenthic samples were collected in July 1984 to char-
acterize the structure of the project area benthic community and to
predict impacts from CBG construction. The epibenthic analyses were
conducted to characterize the existing community, predict impacts,
and correlate data to the salmonid study described above.
Demersal Fish Analysis - Conducted in the East Waterway in October
1984, this study documented occurrence and relative abundance of
demersal species. The study was also used to evaluate impacts from
the proposed action.
17
-------
A
CLEAN CAP AND
LATERAL
CONTAINMENT
Source: U.S. Navy FEIS, 1985
Figure 4
PREFERRED U.S. NAVY PROPOSED HOMEPORTING
DISPOSAL LOCATION (A) AND BOTTOM PROFILE OF
CONFINED AQUATIC DISPOSAL (B)
18
-------
Investigations for 1985 and 1986 will test preferred dredge disposal methods.
These studies are:
Site analysis using geotechnical borings and evaluation of slope
stability.
t Determination of optimum cap size; leachate and settlement tests.
Equipment evaluation and selection.
Development of a construction monitoring plan.
t Other design considerations such as defining lateral containment
needs and a navigation/positioning plan for accurate sediment
placement.
The City of Everett and WDOE have lead SEPA responsibilities for EIS review.
On October 16, 1985, they jointly decided that the FEIS met SEPA requirements
under the condition that a supplemental EIS be prepared to address several key
issues.
WDOE is responsible for preparing the supplemental EIS which will address the
following water and sediment quality related issues:
Dredged material disposal - More detailed review of existing
emplacement technologies, including capping; and alternatives to
open-water disposal.
Ship "grey-water" disposal - Some Navy ships lack hookups for
proper disposal of water from kitchens, showers, sinks, etc.
Organotin anti-fouling paint - More detailed assessment of water
quality impacts from leaching and flaking of organotin paint.
Oil transfer and storage - More detailed assessment of water quality
impacts.
2.1.4 Dredge and Fill Permit for Port of Everett's Terminal/Industrial
Complex Site Improvements
Lead Agency: Port of Everett
Time Frame: Application submitted to COE in June 1985; proposed project
construction period will coincide with U.S. Navy's Homeport-
ing construction (1987-1990).
The U.S. Navy's decision to homeport a Carrier Battle Group (CBG) within the
Everett Harbor area will necessitate an expansion of the existing Port
19
-------
facility. The permit application describes construction of 3,600 feet of new
docking space including the construction of new berthing for water-based log
loading, creation of an upland area of approximately 53 acres, and development
of a 10-acre public park and a 200-foot public fishing pier.
The proposed Port expansion will occur at the site of the old Weyerhaeuser
sulfite pulp mill and the Hewitt terminal (Figure 5). Based on a 404 (dredge
and fill) permit application filed by the Port on August 6, 1985, three
conclusions can be gathered: (1) over 400,000 cubic yards of material is to
be dredged from the Weyerhaeuser site; (2) 210,000 cubic yards from the Hewitt
Terminal; and (3) over 500,000 cubic yards of dredged material is proposed to
be utilized as fill for the project. In a letter to the Washington Public
Ports Association (April 1, 1985), the Port has estimated that 50,000 cubic
yards of dredged materials may be contaminated (Port of Everett, 1985).
The Port's dredging plans are currently (as of November 1985), under revision.
Proposed activity includes: removal of 210,000 cubic yards of subtidal
material north of Pier 3, the use of 40,000 cubic yards of material for upland
and intertidal fill at the same site, subtidal removal of 260,000 cubic yards
south of Pier 1, and use of 400,000 cubic yards as fill for 14 acres at the
Pier 1 site. It is not known what portion of the sediments may be contaminated.
2.1.5 Detailed Chemical and Biological Analyses of Selected Puget Sound
Sediments
Lead Agency: U.S. Environmental Protection Agency
Time Frame: Draft Final Report undergoing peer review
In order to characterize surface sediments in marine waters, EPA has contracted
for physical and chemical analyses of over 100 surface sediments obtained from
four reference embayments (relatively undeveloped) and four urban embayments
including Everett Harbor. Screening and selection of the above samples re-
sulted in detailed chemical, physical, and biological analyses of 60 samples.
Shellfish and fish pathological data were also collected and synthesized by
the National Marine Fisheries Service (NMFS). The sampling and analyses
occurred in 1984.
20
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PROPOSED LOO
HANDLING PCR
GRAPHIC SCALE
P
o too' 1000
PROPOSED ORE
TO -40 MLLWUlOftttS CY)
MER UXI8TMQ)
^T /
ROPO8ED 1.8 ACME) |
BEHIND BULKHEAD
NSION Ut.000 CY)
PROPOSED MARGINAL WHARF
WITH CONNECTING STRUCTURE TO PER
PROPOSED DREDGE
TO -40 MLLW U9.OOOCY)
OUTER HARBOR LINE
EXISTING CONCRETE
DOCK TO MEMAM
EXISTING 860 SO TIMBER PCR
STRUCTURE TO BE REMOVED
PROPOSED 18.1 ACME PILL BEHIND
KETABONG WALL TO *18 MLLW
(888.000CV)
PROPOSED DREDGE TO -40MLLW
(I80.000CY)
PROPOSED MARGINAL WHARF
PROPOSED T.S ACRE FILL BEHIND
"RETAINING WALL TO +18 MLLW (MOAOOCY)
PROPOSED 110 ACRE PILL BEHIND AND
ADJACENT TO DRIFT BILLS, PROM
'+0 TO 418 MLLW (188.000CY PLUS
S8.000CV BEACH AGGREGATE)
PROPOSED
CONCRETE
HUBBLE
NEEF
I PROPOSED DRIFT
BILLS (1.BOOCY
AND I.SOOCY.
RESPECTIVELY)
^PROPOSED PUBLIC
FISHING PIER
PURPOSE: DOCKING AND CARGO HANDLING
DATUM: MLLW
ADJACENT PROPERTY OWNERS:
£> CTTYOF EVERETT
SCOTT PAPER Co.
Source: Port of Everett Dredge and Fill Permit Application, August 6, 1985
Figure 5
PORT OF EVERETT PROPOSED SITE IMPROVEMENTS
21
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2.1.6 Evaluation of Dredging/Dredge Disposal Programs
The most significant program that addresses the disposal of dredged spoils is
PSDDA. The PSDDA study is limited in that it does not identify the most
contaminated sediments or propose disposal or cleanup options, but rather it
identifies unconfined, open-water disposal guidelines. PSDDA does not make
recommendations for the disposal of dredged material that is too contaminated
for placement in Puget Sound. This study will also consider alternatives to
unconfined disposal (i.e., upland, capped, etc.) which could be important when
the U.S. Navy and the Port of Everett proceed with their dredging plans.
However, these alternatives will not be evaluated on a site-specific basis,
but rather in a more general nature.
The Interim Decision Criteria currently being developed by EPA for the Port
Gardner disposal site are limited to unconfined, open-water disposal. As a
stop-gap measure to assist the City of Everett's planning department, this
interim solution is satisfactory. However, these criteria will require that
the Port of Everett and the U.S. Navy find an alternate site to dispose of
some contaminated material. Furthermore, there are no plans or programs to
develop criteria for disposing of contaminated material in alternate sites
(i.e., other than unconfined, open-water sites). New design criteria for
dredged material disposal, such as capping, must be carefully monitored and
evaluated by agencies with responsibility to protect water quality. Finally,
an obvious gap in the current repertoire of dredging-related projects is that
there are none designed specifically to remove and/or treat existing contami-
nated "hot spots."
2.2 TREATMENT AND DISPOSAL OF MUNICIPAL AND PRIVATE WASTEWATER
The following programs include legislative or regulatory actions aimed at
eliminating or controlling the input of toxicants and/or pathogens to the
Everett Harbor, Lower Snohomish River area.
22
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2.2.1 Sec. 201 Lower Snohoirn'sh Basin Facilities Plan
Lead Agencies: EPA; WDOE; Lower Snohomish Basin Municipal Wastewater
Treatment Facilities
Time Frame: 1976-1980
In 1980 the lower Snohomish Basin 201 Facilities Plan, a comprehensive study
commissioned by EPA and WDOE, identified two wastewater problems consistent
throughout the lower basin study area. These problems were:
1. Failure of existing treatment facilities to meet effluent stan-
dards.
2. Soil conditions not conducive to on-site (septic) treatment.
The 201 study pointed out wastewater treatment facility problems within
Snohomish Basin and provided recommendations for their correction or improve-
ment. Table 2 summarizes the study's recommendations by subregion and presents
their current (1985) status. This study did not specifically identify problems
related to toxicant contamination.
The primary goal of each facility is to implement improvements to meet current
NPDES effluent limitations. With the exception of selected metals, these
permits do not presently establish limitations for priority pollutants. The
City of Everett is the major processor of industrial discharges and is develop-
ing an industrial pretreatment program that should provide significant addi-
tional information about contaminant loading to the city's facility (see
Section 2.2.9 of this report). The program should also help reduce toxicant
levels in both treatment plant influent and effluent.
While the 201 study identified unsuitable soil conditions for on-site or
septic systems, a discussion with the Snohomish County Health District indi-
cated that there were no significant county-wide septic system problems. The
health district responds to complaints and examines proposed septic systems as
part of their on-site sewage disposal program. Pathogenic contamination
within Everett Harbor was identified as a major water quality problem by the
SNOMET/King County 208 Water Quality Management Plan (1977) but the major
source of this problem was identified as agricultural land use activities (see
Section 2.3 of this report) rather than on-site sewage treatment. However,
23
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Table 2
LOWER SNOHOMISH BASIN 201 STUDY RECOMMENDATIONS AND STATUS
201 SUBRECION
1980 STUDY RECOMMENDATIONS
CURRENT STATUS (1985)
EVERETT
Includes: Silver Lake Hater
District, Mukllteo Hater
District, a portion of
Alderwood Hater District, and
the City of Everett
1. Upgrade treatment facility.
2. Construct south and southwest Inter-
ceptors and pump stations.
FEI5 for treatment plant expansion submitted 6/85 and Includes
two proposed stages: Stage 1 - Construction of oxidation pond,
redrculatlon channel, and sludge transfer facilities; Stage 2 -
to be Instituted when 1990 population projections have been
reached and will Involve expansion of existing aeration lagoon.
Southwest Interceptor project Including the expansion of Pump
Station No. 1 and bypass of Pump Station No. 14 operational In
1985. Designing enlargement for Pump Station No. 9. No construc-
tion or plans for recommended South Interceptor. Flows to Pump
Station No. 2 (and overflows) reduced by adding Pump Station No. 1.
MARYSVILLE
Includes: City of Marysvllle,
Arlington Airport, Island
crossing to the north and
Priest Point to the west.
1. Upgrading existing treatment lagoon
and pump stations.
2. Replace or construct Interceptors.
1. Enlarged the lagoon plant by 40 acres (1983), added second cell
aerator, and chlorine contact chamber. Expansion will accomodate
a projected population of 90,000.
2. Main carrying Petunia Sewer District flows south to Marysvllle
wastewater treatment plant.
SNOHOMISH
Includes: City of Snohomlsh
and adjacent areas to the
north, south and west.
1. Upgrading existing treatment lagoon
and pump station.
2. Construct Interceptors.
1. No known upgrades, reestablished chlorlnatlon contact chamber.
More chlorlnatlon work will be undertaken In five-year comprehen-
sive plan.
2. Need for Interceptor for additional services In the north, but Is
not designed or scheduled until a funding source Is secured.
LAKE STEVENS
Includes: City of Lake
Stevens and Lake Stevens
Sewer District.
1. Treatment lagoon and pump station
Improvements.
2. Interceptor extension.
1. Converted aeration lagoons to activated sludge (8/85). Extended
main outfall 200 feet Into Ebey Slough to achieve better dispersion
2. One Interceptor Installed; two more are needed, but as yet are
not scheduled until funding Is secured.
TULALIP TRIBES
No recommendations; plant achieves
secondary treatment.
Plant reportedly near or at treatment capacity.
Sources: Washington Department of Ecology; City of Everett Utilities & Planning Divisions; City of Marysvllle Utilities Department; City of
Snohomlsh Public Horks Department; Lake Stevens Sewer District; City of Mukllteo.
-------
health district officials also reported areas in which there are recreational
developments (i.e., campgrounds) which may have overloaded septic systems. In
addition, older private systems may not be adequately maintained or may have
exceeded their maximum age for effective treatment. The Health District iden-
tified no specific locations or incidents of chronic contamination by septic
systems.
2.2.2 National Industrial Pretreatment Program
Lead Agencies: EPA; WDOE
Time Frame: Ongoing since 1978
To achieve the control of industrial toxicants into publicly-owned treatment
works (POTWs), the EPA promulgated General Pretreatment Regulations (40CFR
403). Three major objectives of these regulations are:
Prevent toxicant interference with POTW operations.
Prevent toxicants from passing through POTWs and entering into
receiving waters.
Improve feasibility of municipal sludge recycling and reuse.
EPA, the state of Washington, and some local treatment facilities are develop-
ing programs to meet these objectives. These programs establish pretreatment
effluent standards for several types of industries according to the nature of
their process wastewaters (see Table 3). These programs also develop stan-
dards that will control or prohibit discharges of materials that create
hazards, obstruct flows, or cause structural damage to the sewer systems.
In the fall of 1984, EPA Region 10 updated its inventory of industrial users
within all municipalities served by wastewater treatment plants. At the time
of this writing, the Cities of Everett, Mukilteo, and Snohomish have responded
to EPA's survey. The City of Everett is expected to begin a pretreatment
program in 1985. The Cities of Mukilteo and Snohomish report that they
receive no industrial wastes that would be subject to pretreatment standards.
(The City of Lake Stevens does not have a formal pretreatment program but it
does receive pretreated industrial wastewaters from Hewlett-Packard.) Table 4
identifies categories of industries that discharge to the Everett system.
25
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Table 3
REGULATED INDUSTRIAL CATEGORIES SUBJECT TO
EPA CATEGORICAL PRETREATMENT STANDARDS
Industrial Categories
with Promulgated Regulations
Aluminum Forming
Battery Manufacturing
Coil Coating I
Coil Coating II (Canmaking)
Copper Forming
Electrical Components I
Electrical Components II
Electroplating
Inorganic Chemicals I
Inorganic Chemicals II
Iron and Steel
Leather Tanning
Metal Finishing
Nonferrous Metals I
Petroleum Refining
Pharmaceuticals
Plastics Molding and Forming
Porcelain Enameling
Pulp, Paper, Paperboard
Steam Electric
Timber Products
Textile Mills
Industrial Categories with
Regulations Not Yet Promulgated
Metal Molding and Casting (Foundries)
Nonferrous Metals II
Nonferrous Metals Forming
Organic Chemicals
Pesticides
26
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Table 4
EPA REGION 10 LISTING OF CATEGORICAL INDUSTRIES
EVERETT, WASHINGTON (effective November 1984)
Electroplating
Western Gear Corporation
Washington Stove
Everett Sound Machine Works
Boeing Company
Collins Casket Company
Sound Casket Manufacturing Co.
K4K Metal Fab.
CDR Engineering
Olympic Manufacturing Co.
Everett Engineering, Inc.
MEB Manufacturing Co.
Motor Service, Inc.
Royell Manufacturing, Inc.
Sather Manufacturing Co., Inc.
Panama Machinery & Equipment
All Fab, Inc.
Eckstrom Industries, Inc.
H&R Mechanical Systems
Meiers Iron Works
Pacific Plating, Inc.
Everett Metal Products
Electrical Components
John Fluke Manufacturing
Organic Chemicals
Kohkoku USA, Inc.
Timber Products
CA Crukshank Lumber Co.
Canyon Lumber Co., Inc.
Eclipse Lumber Co.
Everett Lumber Division (Weyerhaeuser)
Smith Street Mill, Inc.
William Hulbert Mill Co.
Double AA Shake Co.
Ironwood Northwest, Inc.
Kermitt Kompelien
Tiz's Door Sales, Inc.
EA Nord Co.
Scott Paper Company
Weyerhaeuser Company
Other
Black Clawson, Inc. (now Acrowood, Inc.)
Eldec Corporation
Centrecon, Inc.
27
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As part of a continuing effort to strengthen the Industrial Pretreatment
Program, EPA Region 10 has developed an enforcement compliance program which
should be implemented in the forthcoming fiscal year (R. Robichaud, EPA Region
10, pers. comm., August, 1985). This program will include an increased empha-
sis on inspections and monitoring by EPA or local authorities, a potential
expansion in compliance staff, and strict enforcement of regulations. EPA is
also considering its own permitting mechanisms to regulate industries if the
state of Washington does not use their permitting program as authorized under
RCW 90.48.160. There may be numerous industries in the vicinity of Paine
Field that are either not identified or not permitted, and these may be a
source of toxic contaminants. It is likely that these industries are pri-
marily affiliated with airplane manufacturing, repair, and metal fabrication
or plating. Table 5 lists the active NPDES and state waste discharge permits
within the general project area.
2.2.3 State of Washington Senate Bill No. 3812 (Sections 1 and 2)
Lead Agency: WDOE
Time Frame: 1985-1986
This bill requires WDOE to report to the legislature by January 1986 "... all
enforcement actions initiated from 1983 through November 1985 regarding the
protection of Puget Sound water quality" (Section 1). Furthermore, it
requires WDOE to hold public hearings on its enforcement measures in December
1985, to receive public comment on the adequacy of its actions, and to prepare
a summary report of the proceedings for the legislature. Section 2 of the
bill increases monetary penalties for violators of waste discharge permits
and/or industrial operations that operate without a discharge permit.
2.2.4 State of Washington Substitute House Bill No. 815 (Section 1)
Lead Agencies: WDOE; PSWQA
Time Frame: 1985-1987
House Bill 815, passed by the House and Senate in April 1985, requires that
WDOE in cooperation with the Puget Sound Water Quality Authority (PSWQA),
"... shall review existing standards for pretreatment of industrial wastewater
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Table 5
ACTIVE NPDES OR STATE WASTE DISCHARGE PERMITS IN THE PROJECT AREA
(Source: WDOE Northwest Regional Office)
Permittee
City of Snohomish STP
Centrecon
City of Lake Stevens STP
City of Mulkilteo STP
Snohomish County, Cathcart Landfill1
Associated Sand and Gravel
Production Plating
City of Everett STP
Boeing Company
El dec Corporation
Hewlett-Packard
City of Marysvilie STP
DoD Fuel Support Facility
Blue Streak Finishers
Kohkoku USA, Inc.
John Fluke Manufacturing
John Fluke Manufacturing
Western Gear (cooling water only)
Scott Paper Company
Weyerhaeuser Co. Kraft Mill
Tulalip STP (draft permit 9/13/85)
Permit
Number9
WA-002954-8
5142
WA-002089-3
WA-002329-0
WA-003048-1
WA-000112-1
5195
WA-002449-0
5152
WA-002899-1
7258
WA-002249-7
WA-002523-2
5187
5175
5147
5183
WA-000341-7
WA-000062-1
WA-000300-0
WA-002480-5
Expiration
Date
9/14/87
8/30/90
3/2/88
6/23/82
6/14/82
9/4/85
7/6/87
6/19/82
9/15/87
8/12/87
2/1/90
7/1/88
4/11/82
7/1/86
5/31/89
12/17/84
6/8/86
3/14/88
6/24/90
6/25/90
N/A
^Permit numbers prefaced by "WA" are NPDES.
°STP - Sewage Treatment Plant
Outside study area, but leachate transferred to Everett STP.
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that is discharged into sewage treatment facilities that discharge into Puget
Sound. Standards for treatment by industrial facilities that discharge
directly into Puget Sound or into waters that flow into Puget Sound shall also
be reviewed." (Section 1 [l].Wa. H.B.815; April, 1985).
Review and promulgation of standards is currently the responsibility of EPA.
According to the Water Quality Planning and Management Section of WDOE, the
state is considering assuming authority for the industrial pretreatment
program from EPA. One criticism the state has of the federal program is that
several industries (e.g., photo developers, print shops, radiator cleaners)
are presently excluded from the categorical classification even though they
can be a source of toxicants.
2.2.5 State of Washington Substitute House Bill No. 815 (Section 2)
Lead Agency: WDOE
Time Frame: 1985-1988
The legislature has required WDOE to work with local governments to develop
plans and compliance schedules for "... the greatest reasonable reduction of
combined sewer overflows" (Section 2.[1]) The plans should include storage
tanks and/or separation of sewage and storm water conduits. These plans and
schedules are required by January 1988, and a compliance schedule is a condi-
tion of any waste discharge permit issued or renewed after that date. In
September 1987, WDOE must report to the legislature any statutory changes
required to implement the plans and schedules. The report must recommend a
date by which POTWs will achieve "... the greatest reduction of combined sewer
overflows." The report must also provide an assessment of the cost, distribu-
tion, and availability of funding at all government levels.
It is believed that the regional operations offices of WDOE will issue the
orders, review plans and compliance schedules, and prduce the legislative
report. According to WDOE, there is a problem in fulfilling this assignment
with existing staff and budget since no funding was appropriated by the legis-
lature. A supplemental budget allowing WDOE to perform the required work was
submitted to the legislature in November 1985 by WDOE (M. Palko, WDOE, pers.
comm., August 1985).
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2.2.6 Treatment Lagoon and Trickling Filter Standards
Lead Agency: WDOE
Time Frame: 1985
In October 1984, EPA regulations on secondary treatment were relaxed for
facilities in which a trickling filter or waste stabilization pond (treatment
lagoon) is used as the principal treatment process. The relaxed limitations
allow an increase in BODr from 30 mg/1 to 45 mg/1 (30-day average) and an
increase in settleable solids (SS) from 30 mg/1 to 45 mg/1 (30-day average;
40CFR Sec 133.105 [a][l] and [b][l]). In the state of Washington, WDOE was
concerned about backsliding as a response to this relaxation, particularly
since existing facilities with this equipment were meeting the more stringent
effluent standards. Following the EPA action, the Director of WDOE responded
to this concern by appointing a nonbinding citizens advisory committee (CAC)
to review the current standards and recommend how they would affect wastewater
treatment facilities in Washington. The CAC is composed of 13 members repre-
senting community organizations, sewer districts, environmental and public
health interests, and civic and business interests. They are reviewing two
general concerns:
1. Whether the state should regulate secondary treatment.
2. Whether the state needs regulations that would clarify its posi-
tion on what levels of treatment can be achieved as well as how to
regulate design standards for new or expanding facilities.
The committee met twice and provided their recommendations to WDOE in the fall
of 1985. This issue is of particular importance within the project area due
to the number of treatment facilities (Cities of Everett, Snohomish, and
Marysville) that use treatment lagoons.
2.2.7 Miscellaneous Treatment Guidelines and Criteria Revisions
Lead Agency: WDOE
Time Frame: 1985-1986
According to WDOE's Water Quality Planning and Management Section, there are
several ongoing studies that when implemented will improve wastewater treat-
ment standards and ultimately will improve receiving waters, including those
in the project area. These studies include:
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Revised Sewage Works Design Criteria - Upgrading and improving the
instruction and design manual for wastewater treatment plant opera-
tors. Available in 1985.
Revision of Dilution Zone Criteria Standards - Eliminates current,
broad-based 20:1 dilution ratio of wastewater treatment plant dis-
charge and substitutes a dilution criteria based on characteristics
of a facility's effluent (considers toxicant load) and takes into
account available and superior technologies that improve dilution
ratios. Target completion date: February 1986.
Review of Disinfection Guidelines - WDOE is reconsidering the use of
chlorination as a means of disinfecting effluent. The state may
develop new guidelines or recommendations for alternative technolo-
gies. Target date of study: October 1985.
2.2.8 Everett Wastewater Treatment Plant Expansion FEIS
Lead Agency: City of Everett
Time Frame: Proposed construction to begin in 1987
The City of Everett's wastewater treatment plant is currently overloaded and
must be expanded or upgraded to provide service for anticipated community
growth. The current NPDES water discharge permit limits are 30 mg/1 BODj- and
55 mg/1 suspended solids (SS) as monthly averages. Frequent violations of
these standards leave the city with no choice but to expand or upgrade its
plant so that adequate treatment can be provided for present and forecasted
loadings. Sludge accumulations in the aeration lagoon have added to the
treatment burden of the plant. Leachate from Snohomish County's Lake Stevens/
Cathcart Landfills adds substantial BOD,- burden to the treatment plant (see
Section 2.4.3 of this report). It was recommended that expansion of the
facility occur in two stages:
Stage 1 - Construction of a new 100-acre oxidation pond east of the
facility's existing ponds, a recirculation channel with berm, and
sludge transfer facilities.
Stage 2 - Construction of additional aerated lagoon treatment by
expanding the existing pond and adding additional aerators. This
action will be undertaken when population levels reach 90,000.
(The city could not give a date for the initiation of Stage 2.)
Because the proposed treatment plant expansion would impact wetland habitats,
a Habitat Evaluation Procedure (HEP) was required. This analysis was
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performed by EPA, U.S. Fish and Wildlife Service (FWS), Washington Department
of Game (WDG), and the city. The HEP discussed impacts on habitat values and
wildlife and the mitigation measures required for each of the proposed alter-
natives. It has been reported that the mitigation measures are not finalized
at this point, although the Substantial Development permit under the Shoreline
Master Program has been approved based on the city's EIS. However, if the
mitigation requirements include extensive wetland protection measures, a new
Substantial Development Permit would be necessary. WDOE had approved the pre-
ferred alternative for the initial program expansion proposal but it is cur-
rently re-reviewing the FEIS based on the inclusion of the HEP analysis
(D. Wright, WDOE, pens, comm., July 1985).
In September, 1985 EPA and WDOE ordered the City of Everett to remove sludge
from the treatment lagoon and clean industrial pollutants from the sewage
discharged to the lagoon. These agencies maintain that these actions are
necessary because the overloaded lagoon is limiting treatment effectiveness
resulting in unacceptable pollutant discharges to the Snohomish River. EPA
gave the city until November 1, 1985 to respond to its order. As a result of
these enforcement actions, the city may have to delay plans for treatment
plant expansion (B. Landles, City of Everett, pers. comm., Sept. 1985).
2.2.9 City of Everett - Proposed Pretreatment Program
Lead Agency: City of Everett
Time Frame: Proposed to start in 1985
The City of Everett proposes to develop a pretreatment program in compliance
with EPA and state environmental regulations to meet the objectives of the
National Pretreatment Program. The proposed program consists of seven tasks:
1. Perform an Industrial Waste Survey - Make a complete and accurate
inventory and appraisal of all nondomestic wastes entering the
sewer system.
2. Develop Discharge Limitations - Collect and evaluate technical
information which will be used to identify problems in the opera-
tion of the city's wastewater treatment plant and sludge disposal
resulting from industrial wastes in order to develop discharge
limitations that will meet national and state pretreatment objec-
tives.
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3. Review City's Legal Authority - Facilitate enforcement of the pro-
gram (Note:Resolution No. 2511 passed in February 1985 estab-
lished a surcharge for users who exceed the limits identified by
Everett Municipal Code [EMC] 14.08.050 and EMC 14.08.300 based on
the cost of collection and treatment of wastewater=)
4. Develop a Monitoring Enforcement System - Ensure compliance with
the city's program.
5. Provide Public Participation - Involve general public and affected
industries.
6. Evaluate Equipment and Facility Needs - Include laboratory, sam-
pling equipment, and disposal facilities.
7. Evaluate Funding
This proposed program was submitted to EPA and WDOE for their review in July
1985.
2.2.10 City of Everett - Subregion Interceptor Sewers
Lead Agency: City of Everett
Time Frame: 1980-Ongoing
In 1980 the City of Everett proposed to construct and operate interceptor sys-
tem facilities to transport sewage from the south end of Everett and unincor-
porated areas north to the Everett treatment plant. Sanitary sewer extensions
in the developing south end of the city increased the amount of sewage flowing
to the north end of the city's sewage system. The older north end system was
composed of a combined sanitary-storm sewer network. During heavy rainfalls
the system was overloaded and the combined sanitary-storm effluent was shunted
directly into the Snohomish River or into Possession Sound. The development
and operation of the southwest interceptor (1983-1985) resulted in the elimi-
nation of raw sewage discharges to the Snohomish River and reduced combined
sewer overflows to the river. Continuing construction and improvement of
interceptor sewers occurs on an as-needed basis and is predominantly funded
through fees charged to developers. It is possible, however, that supple-
mental funding may have to come from other sources as many existing and new
residential areas become sewered. The city's Department of Public Works
estimate the next major improvement will occur in approximately 5 to 7 years.
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2.2.11 Lake Stevens - Treatment Plant Upgrade
Lead Agencies: City of Lake Stevens; WDOE; Community Economic Revitalization
Board (CERB)
Time Frame: 1985-1987
The city of Lake Stevens is in the process of upgrading its aerated lagoon
treatment system and converting to an activated sludge plant. The new facility
will be fully operational in 1985. With the help of grant funds, the city was
able to allow the Hewlett Packard facility (the only industrial source to the
plant) to discharge to the system after its process wastewaters are pretreated.
The plant also extended its outfall 200 feet across Ebey Slough to achieve
better dispersion. The next project goal is to install an east/west inter-
ceptor to collect wastewaters from areas not currently served by the plant.
There are no funds identified to date for construction of the interceptor.
2.2.12 City of Mukilteo - Comprehensive Sewer Plan
Lead Agency: City of Mukilteo
Time Frame: 1985-1987
The city of Mukilteo's treatment plant is currently providing primary treatment
at its design capacity. This sewer system serves less than half of Mukilteo.
The current NPDES waste discharge permit requires 45 mg/1 BODc and 45 mg/1
suspended solids as monthly averages; however, the plant has consistently
failed to achieve these limitations.
In order to accommodate existing and projected population levels for its sewer
service area, the city filed for a Section 301(h) waiver to discharge waste-
waters that have not undergone secondary treatment. In late 1984 EPA Region
10 denied the request citing the discharge would not comply with state law.
The city of Mukilteo then undertook a comprehensive sewer plan to identify
alternatives and to recommend an acceptable wastewater management system. As
a result of the plan, the city has opted to tie into the Olympus Terrace Sewer
System and discontinue treating wastewater at its own plant. Recent negotia-
tions have been completed with Olympus Terrace officials. It is not expected,
however, that this transfer will be operational until at least 1987.
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In June 1985, WDOE issued a Notice of Violation and a Compliance Order (No.
DE 84-718) to the city of Mukilteo requiring the city to install some new
equipment and maintain a record of its sludge volumes. The order also
requires the city to submit a report describing the status of these require-
ments and submit a schedule for the provision of secondary treatment.
The city is installing some of the required equipment, but maintains that all
of the order's requirements are not cost-effective based on their ultimate
plan to close the plant. They assert that the plant is currently operating as
well as can be expected, and they do not believe the requirements will substan-
tially improve the quality of the plant's effluent. Based on this assertion,
they are appealing the order. The WDOE will review monitoring data but main-
tains that these interim upgrades are necessary (D. Wright, WDOE, pers. comm.
August, 1985).
2.2.13 Evaluation of Municipal Wastewater Treatment/Disposal Programs
While some improvements to municipal wastewater treatment facilities have been
implemented, it appears that most systems (with the exception of Lake Stevens)
are currently at treatment capacity. Current efforts within Snohomish County
and the City of Everett to attract industry and expand its economic base make
adequate wastewater treatment a critical issue. The proposal to upgrade the
City of Everett's treatment lagoons (the major treatment facility within the
project area) is a significant action. Combined with its proposed pretreat-
ment program, the City of Everett could significantly reduce the input of
toxicants to the lower Snohomish River. The city of Mukilteo may have solved
its wastewater problems in the long-term, but it will still have to provide
treatment until at least 1987. The city's reluctance to commit to major
capital expenditures is understandable, but water quality impacts from the
existing facility's discharge should be considered. The lack of a plan to
implement interim improvements to the Mukilteo treatment plant is a signifi-
cant gap in present waste disposal programs.
The 201 study recommended that several interceptors be constructed throughout
the lower Snohomish basin. Many of these interceptors will be installed in
response to increased demand (development pressures) and increased availa-
bility of funding. Construction of interceptor sewers, particularly in areas
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that are undergoing rapid development, would facilitate treatment and proper
disposal of commercial, industrial, and residential wastes. Overall, the
facilities plans for collecting and treating municipal wastewaters are limited
by the growth pressures and the availability of local revenue and state
grants. Treatment methods could be improved if they dealt with a wider range
of wastes, for example toxicants. With the exception of Everett's proposed
pretreatment program, there is little likelihood that wastewater treatment
methods will consider toxicants.
Pretreatment plans and objectives need to be resolved by WDOE and EPA. State
pretreatment programs need to be adequately funded and staffed to be effec-
tive. In fact, all water quality efforts are only effective if (1) there are
available resources to meet the objectives of the program or plan, and (2)
there is program continuity to ensure that the objectives, schedules, or
regulations are carried out. It is apparent that there is inadequate funding,
planning, and interagency coordination of wastewater treatment programs at the
present time.
2.3 CONTROL OF URBAN AND AGRICULTURAL RUNOFF
The following programs include basin plans or drainage ordinances which are
designed to identify or control surface runoff problems from both urbanized
and rural areas.
2.3.1 208 Area-Wide Drainage Plans
Lead Agencies: SNOMET-King County; Everett; Mukilteo; Snohomish-Lake Stevens;
Marysville; Paine Field
Time Frame: 1976-Ongoing
In November 1976, the Snohomish County Metropolitan Municipal Corporation
Council (SNOMET) and King County issued the SNOMET/King County 208 Water
Quality Plan which included the Snohomish and Stillaguamish Basins. The plan
identified major water quality problems (nonpoint pollution of estuaries and
degradation of local streams) and designated agencies with technical capa-
bility, legal authority, financial resources, and political acceptance to deal
with these problems. No lead agency was designated because of the complexity
of the problems. A county-wide storm water utility was recommended as the
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best financial solution. A utility was organized and a fee schedule was
proposed. However, the utility was voted down by the county council in
August, 1984.
The agricultural waste management program identified in the plan is designed
to eliminate contamination in surface runoff from agricultural lands. The
program is largely dependent on the voluntary efforts of farmers. One product
of the program, the Farm Water Quality Management Manual, describes Best
Management Practices (BMPs) for various agricultural activities (i.e., feed
lots, manure application, fertilizing, etc.).
Local conservation districts, the Soil Conservation Service (SCS), and
Snohomish County provided dedicated staff to work with local farmers. This
program is still active today. Currently the Snohomish County Planning
Department, Snohomish Conservation District, and the SCS are working together
to provide permit guidelines for manure lagoons. The Shoreline Master Program
was recently revised to permit the placement of these lagoons within shoreline
areas. The manure lagoons are holding ponds that are designed to stabilize
organic matter prior to its disposal on pastures in floodplains. These guide-
lines are primarily intended to prevent discharge of animal wastes during
periods of rainfall when the wastes are most likely to reach surface waters.
The guidelines were adopted by the county council in the fall of 1985.
For both agricultural and urban areas, source controls and drainage basin
planning were identified in this 208 plan as the most effective means of
correcting surface water runoff problems. Since the 208 document was issued,
there have been several drainage basin studies, plans, or regulations imple-
mented within the lower Snohomish Basin area including:
South Everett Drainage Basin Plan (1982 FEIS) - Includes nonstruc-
tural components such as ordinance revisions and policies and
structural components to reduce stream degradation and property
damage.
Snohomish/Lake Stevens Area Comprehensive Plan (1979) - Emphasizes
natural resource protection goals and recommendations but provides
no specific regulations.
Paine Field Area Comprehensive Plan (1983) - Emphasizes natural
resource protection goals and recommendations but provides no
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specific regulations. Recommends 25-50 feet of setback (a setback
is a buffer between the surface water and sources of erosion or
pollutants).
Paine Field Storm and Sanitary Sewer Study (1981) - Identified
structural improvements to accommodate future expansion and
development; improved Japanese Gulch retention pond.
Marysville Area Comprehensive Plan (1983) - Requires greenbelt
(setback) of 25-50 feet, designates stream corridor, and recognizes
that further ordinances may be required to meet goals.
Mukilteo Storm Drainage Study (1985 EIS) - Identifies structural
improvements to control and regulate flows and recommends enactment
of new policies to minimize adverse impacts of development.
City of Everett Drainage Ordinance No. 670-80 (1980) - Requires pre-
liminary drainage review and/or a detailed drainage plan and other
approvals necessary for development.
Snohomish County Title 24.24 Drainage Ordinance (1980) - Requires
a detailed drainage plan in conjunction with other approvals neces-
sary for development.
2.3.2 Watershed Management Activities
Lead Agency: Snohomish County
Time Frame: 1980-Ongoing
As part of an overall watershed management planning process, Snohomish County
has developed several programs that will lead to better source controls:
Stream Rehabilitation Program (1984-1985) - The Snohomish County
Stream Rehabilitation Program designed and implemented several
projects to restore stream habitats (e.g., correcting problems
associated with unrestricted livestock access to streams, building
fish ladders, and revegetating stream banks).
Retention Facility/Detention Pond Inventory (1985) - Approximately
500 to 600 detention facilities exist within Snohomish County.
These facilities were recently inventoried and inspected by county
employees to assess their condition and utility. Results of the
field investigations indicate that many of the facilities are poorly
maintained and thus offer little or no flow regulation or adequate
drainage detention. County employees are convinced that regional
facilities offer the best means of storm water controls.
Snohomish County/Marysville Cooperative Cost-Sharing Agreement - The
county and city have recently agreed to installstorm water deten-
tion ponds on Allen Creek (1985).
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2.3.3 State of Washington Substitute House Bill No. 814
Lead Agency: County legislative authorities
Time Frame: 1985-Ongoing
Section 3 of House Bill No. 814 authorizes counties to establish shellfish
protection districts in areas where nonpoint pollution threatens commercial
and recreational shellfish culture and harvesting. Counties can establish
programs to require the elimination or decrease of pollutants in storm water,
ensure the proper operation and maintenance of septic systems, and provide the
public with educational programs on nonpoint pollution.
2.3.4 Shoreline Master Programs
Lead Agencies: Snohomish County; Cities of Everett, Marysville, and Snohomish
Time Frame: 1974-Ongoing
The Washington State Shoreline Management Act of 1971 provides for the develop-
ment of local Shoreline Master programs. In the project area there are at
least four shoreline programs: cities of Everett, Marysville, and Snohomish
and Snohomish County. The Snohomish County Shoreline Plan has several
policies and regulations that reduce the impacts of log storage, a known water
quality problem, by encouraging dry, lined land storage. Where logs are
stored in water, the regulations require collecting and disposing of both
floating and submerged bark and debris. There are no similar regulations in
local shoreline programs for reducing impacts from toxicant and pathogenic
contaminants.
2.3.5 Evaluation of Runoff Control Programs
One of the major problems with the implementation of most of the runoff con-
trol plans and programs discussed above is that they are often contingent upon
contributions from future development which is highly uncertain. This
approach for managing runoff problems is basically an opportunistic one which
does little to address current problems. Another reason for the difficulty in
controlling runoff at its source is that many programs provide controls that
are only voluntary (e.g., agricultural runoff programs). Regional runoff
problems implicate many jurisdictions which often have inconsistent regula-
tions and standards. This predicament often results in ineffective source
controls.
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Drainage ordinances for both Snohomish County and the City of Everett could
become major means of controlling toxic contamination in runoff from indus-
trial and urban areas. The City of Everett's ordinance states that whenever a
violation of [the ordinance] is "...creating an unsanitary, dangerous, or
other condition...", the city may suspend or revoke any permit for which the
approval of a drainage plan is required or terminate operations immediately
(Section 13.4). The discharge of toxicants and other pollutants would seem-
ingly apply to this regulation. The city's Drainage Ordinances are currently
being enforced. For example, the ordinances have required new construction
retention/detention facilities at new construction and redevelopment sites.
Drainage ordinances are mainly concerned with volume and velocity of storm
water as these factors are related to erosion. Drainage ordinances, therefore
currently apply to the control of contaminants only to the extent that they
may be present in storm water or water-borne sediment.
If Shoreline Master Program regulations were extended beyond 200 feet shore-
ward, or if they identified controls specific to more waterfront activities
such as industrial lots and cargo storage/handling areas, better toxicant
source controls would be realized. The effectiveness of shoreline programs
may be of critical importance in the near future since the city and the port
are vigorously marketing waterfront development. Current plans for runoff
control do not specifically address toxicant inputs and as a result, represent
major planning gaps.
2.4 CONTROL OF OTHER POINT SOURCES
The following actions relate to site specific investigations or remedial
actions. Some of these sites have had documented releases of hazardous sub-
stances. Finally, this section includes local emergency response activities
that may minimize or eliminate the impacts of spills or improper disposal
activities.
2.4.1 Department of Defense Fuels Support Activities, Mukilteo
Lead Agencies: DoD; EPA
Time Frame: 1980-1984
An investigation (by the U.S. Army Environmental Hygiene Agency [AEHA] in
1982) of groundwater contamination at the DoD Fuels Facility in Mukilteo
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involved the installation of 11 monitoring wells, surveys of biota, and
sampling of water and sediments. The report concluded that JP-4 (jet
propulsion fuel) and associated organic compounds (benzene, ethyl benzene, and
toluene) were contaminating local groundwater supplies. A contaminated plume
was traced to a leaking fuel storage tank which was emptied and is no longer
used. High levels (200,000 mg/1) of JP-4 were reported in monitoring Well No.
4 which is northeast of the abandoned fuel tank No. 10. It is unknown whether
subsequent samples reflected such a considerable concentration or whether this
sample was unique. In the summary of the groundwater study, AEHA recommended
recovery of the JP-4. There was no recovery of JP-4 from groundwater in the
area.
In 1984, EPA Region 10 analyzed several water samples from Japanese Gulch.
Samples were taken where the gulch drains Paine Field, where it flows north
towards the DoD Facility, where it recharges the groundwater between Fuel
Tanks No. 7 and 8, and finally where it resurfaces on the beach as a spring.
Sample results did not indicate the presence of PNAs although the sampling
team reported fuel odors (M. Matta, EPA, pers. comm., 8/85). At this time EPA
has no plans for remedial actions, although they would like to sample offshore
sediments and water.
2.4.2 Everett Landfill Tire Fire
Lead Agency: City of Everett
Time Frame: 1984-1985
In September 1984, a fire started in a pile of aproximately one million tires
stored at the closed Everett landfill located south of 36th Street between
Interstate 5 and the Snohomish River. Attempts to control and extinguish the
fire proved unsuccessful and the fire burned for five months. Generation of
pyrolytic oils during the fire was almost immediate and small amounts of these
oils were released to the Snohomish River. Heavy metal contaminants from the
tire fire residue were tested by EPA/WDOE and were found to be extremely toxic
to fish. The City of Everett, the major landowner, undertook an investigation
to assess the presence and distribution of contaminants and to identify
remedial measures. The final report of this investigation was completed in
August, 1985. In accordance with some of the study's recommendations, the
city has undertaken the following remedial measures:
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1. Completed construction of a soil berm to prevent runoff of contam-
inated material into the Snohomish River.
2. Completed fencing and posting of the site to prevent public
access.
3. Removal of contaminated sediments from railroad ditches (under-
taken by Burlington Northern Railroad in cooperation with the
city.)
2.4.3 Cathcart Leachate Disposal
Lead Agency: Snohomish County
Time Frame: 1985
At this time, leachate generated at the Snohomish County's Cathcart and Lake
Stevens Landfills is transported to the Everett wastewater treatment plant for
treatment and disposal (Cathcart's leachate is first aerated at the landfill
site). In addition, leachate from the Bryant Landfill (which will be closed
in 1986) and the new Snohomish County Regional Sanitary Landfill adjacent to
Cathcart (projected to open in 1990) will also need to be considered for some
type of treatment. The City of Everett would prefer not to accept the leach-
ate from any landfill, maintaining that leachate is not a typical component of
municipal sewage. The city is also concerned about the additional BODc load
imposed on their already heavily burdened treatment system. The county is
currently reviewing their disposal options which include continued disposal at
the Everett STP, transferring the leachate to the city of Snohomish STP (this
action may require the county's contribution towards an upgrade of the
Snohomish system and construction of a pipeline from Cathcart to the Snohomish
treatment lagoons), or implementation of on-site treament. No final decision
has been made regarding ultimate leachate treatment and disposal. As a miti-
gating measure, the county began pretreating Cathcart's leachate in special
holding ponds with nitrogen and phosphorus in order to reduce BOD,- in November
1985. BODg levels are expected to be reduced by 60 percent as a result of
pretreatment (K. Nakhjiri, Snohomish County, pers. comm., August 1985). Addi-
tional aeration, which will also be implemented this year, will provide
further BOD& reduction.
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2-4.4 Tulalip Landfill Site Investigation and Landfill Capping
Lead Agencies: EPA; WDOE; Tulalip Tribes
Time Frame: 1984
In September 1984, a preliminary site inspection of the Tulalip Landfill was
performed for EPA Region 10. Historical information describing this site
indicated the potential for contamination due to the unknown nature of wastes
and its proximity to ground and surface waters.
Water samples obtained on-site by EPA and WDOE indicated that inorganic chemi-
cals including arsenic and zinc may be a cause for concern particularly to
surrounding estuaries. The preliminary site investigation recommended that
additional sampling be undertaken to confirm the extent of suspected contami-
nation.
In an effort to cover and ultimately develop the site of the closed landfill,
the Tulalip Tribes have requested a dredge and fill permit from the COE to
install a barge-loading facility on Ebey Slough. A barge is proposed to carry
clean clay fill from the 1-90 highway construction project to the landfill
location. Approximately nine feet of clay soils will be used to cap the land-
fill. The proposal is being reviewed by the COE. It is also undergoing a
review by WDF/WDG through their hydraulic permit authority (RCW 75.20.100).
Concern has been expressed by WDF regarding compaction and subsequent leachate
generation as a result of the proposed capping action (P. Kauzloric, WDF;
pens, comm., July, 1985).
2.4.5 RCRA 3012 Preliminary Site Investigations
Lead Agencies: WDOE; EPA
Time Frame: 1984-1985
Under Section 3012 of the Resource Conservation and Recovery Act, each state
is required to identify and inventory sites at which hazardous wastes have
been stored or disposed. Following the discovery of a site, the need for
further investigations and remedial actions is assessed. Preliminary asses-
sments are performed at each site using available records and contacts with
knowledgeable officials to confirm the site's history and/or current status.
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Out of 22 sites identified in Snohomish County, seven are within the Everett
Harbor Action Plan project area. Sites that are ranked from medium to high
will undergo a site inspection which may be followed by remedial actions if
they are determined to be necessary. Table 6 lists these sites by their
preliminary assessment ranking.
2.4.6 Hazardous Materials Response Program
Lead Agency: City of Everett Fire Department
Time Frame: 1985
Beginning in the fall of 1985, the Everett Fire Department will provide train-
ing to 140 firefighters for the recognition and handling of hazardous
materials. The fire department has modified a used delivery van to carry
emergency equipment and to transfer small quantities of hazardous materials.
2.4.7 Evaluation of Other Point Sources
With the exception of the DoD fuels facility, it appears that all known
sources in this section are undergoing investigation and will be subjected to
some degree of remedial action. In the case of the DoD fuels facility, the
cleanup of fuel-saturated soils is not anticipated by AEHA. The analytical
information would suggest that there are significant quantities of JP-4 in
ground and marine waters. Further sampling to confirm this level of contami-
nation should be conducted and, based on the results, reclamation of fuels or
in-situ soils treatment should be considered. If the spring that discharges
to Port Gardner is carrying significant quantities of JP-4, the installation
of an an oil/water separator is recommended.
The City of Everett's hazardous material response program is a new and innova-
tive program that will provide emergency spill response throughout Snohomish
County. The emergency response program should be coordinated with existing
response plans of several agencies (e.g., U.S. EPA and the U.S. Coast Guard).
It would be useful for the county and/or city to start a public education
program for the careful use and proper disposal of hazardous materials.
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Table 6
RCRA SECTION 3012 PRELIMINARY ASSESSMENT SITES WITHIN PROJECT AREA
Preliminary
Assessment
Site Name Rank*
Boeing Co., Everett Low
Boeing Tulalip Test Site Low
Everett Landfill Low (rank assigned
before tire fire)
Simpson Lee Co., Pulp and Final assessment not
Deinking Plant completed at the time
this report was
prepared
Scott Paper Co. Low
Tulalip Landfill Medium
Weyerhaeuser Sulfite Pulp Mill Final assessment not
completed at the time
this report was
prepared
*An assessment of the need for further site investigation is
made based on the findings of the information/records search
following criteria set forth by WDOE. These four ranking
stages are:
HIGH A site is highly suspected to present an imminent
health or major environmental threat.
MEDIUM A site is highly suspected to present a potential
problem. Evidence exists from sampling, direct
observation by a regulatory agency, or an existing
history of problems at the site.
LOW A site presents an unresolved problem, but is not
highly suspected to present a risk to the environment
or population. Evidence consists of an alleged
problem resulting from a tip from an employee or
member of the public, or it is unknown how the
facility disposes of a suspected hazardous waste.
NONE There is no evidence to suggest that the site poses a
problem, or no evidence to suggest that there are
hazardous wastes present or not fully contained at
the site.
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REFERENCES
Batelle Marine Research Laboratory. 1985. Detailed chemical and biological
analyses of selected sediments from Puget Sound, Draft Final Report. U.S.
Environmental Protection Agency Region 10, Seattle, Washington. 300 p.
City of Everett and CH2M Hill, Inc. 1980. Final environmental impact state-
ment for the Everett subregion interceptor sewers. July 1980, 109 p. plus
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City of Everett Planning Department and Brown and Caldwell. 1982. Draft envi-
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City of Everett. 1984. Approval of permit application No. SMA 2-84. Sub-
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Washington. February 1984, 10 p.
City of Everett et al. 1985. Final environmental impact statement for the
Everett wastewater treatment plant expansion. Everett, Washington. 77 p.
City of Everett et al. 1985. Technical appendix to EIS wastewater treatment
plant expansion. Everett, Washington. 184 p.
City of Everett. 1985. Plan of study, pretreatment program for the City of
Everett, Washington. 7 p. plus appendix.
City of Mukilteo and Brown and Caldwell. 1985. Draft environmental impact
statement for the Mukilteo storm drainage study. Mukilteo, Washington.
April 1985, Unpaged.
City of Mukilteo and Brown and Caldwell. 1985. Final environmental impact
statement for the Mukilteo storm drainage study. Mukilteo, Washington.
June 1985, 46 p. plus appendices.
City of Mukilteo. 1985. Letter to R. Greiling, JRB Associates, dated May 12,
1985. Re: Response to EPA Region 10 industrial facilities inventory.
Dolan, W., Paine Field. 1985. Letter to A. Giffen, City of Mukilteo, dated
June 7, 1985. Re: Draft storm drainage EIS, Everett, Washington.
Ecology and Environment, Inc. 1984. Preliminary site inspection report of
Tulalip Landfill. Proposed for U.S. EPA Region 10, Field Operations and
Technical Support Branch. Seattle, Washington. 54 p.
Heydon, T.C., City of Snohomish Public Works Director. 1985. Letter to R.
Greiling, JRB Associates, dated May 14, 1985. Re: Response to EPA Region
10 industrial facilities inventory. May 14, 1985, 1 p.
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JRB Associates. 1981. State-wide industrial inventory of POTW systems with
sewerage treatment with design flows equal to or less than 5 MGD: State
of Washington. Prepared for EPA Region 10. Seattle, Washington. 9 p .
plus appendices.
Mclntosh, L.V. 1983. Letter to W. Randall, Defense Fuel Supply Center,
Mukilteo, Washington, dated June 24, 1983. Re: Groundwater monitoring,
DPS, Mukilteo, Washington. June 24, 1983, 3 p.
Miller, P., WDOE. 1985. Letter to J. Corbett, City of Mukilteo, dated
January 2, 1985. Re: Compliance Order No. DE 84-718. June 6, 1985, 1 p.
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Port of Everett and Dames and Moore. 1985. Application for Section 10/404
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R.W. Beck and Associates. 1985. City of Mukilteo comprehensive sewer plan.
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Snohomish County Metropolitan Municipal Corporation (SNOMET) et al. 1977.
SNOMET/King County 208 Water Quality Management Plan. Summary Report.
Everett, Washington. 70 p.
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Facilities Plan. Technical Appendix F - Sewer System Evaluation Survey
for the City of Everett. 84 p. plus appendices.
Snohomish County Planning Department and R.W. Beck and Associates. 1980.
Lower Snohomish Basin 201 Facilities Plan. Volume I, II, III, Summary
Report, and Generic Environmental Assessment. WDOE Grant C-530575-01-1.
Snohomish County Office of Community Planning. 1984. Snohomish County
Shoreline Management Master Program (Update). 139 p. plus maps.
Snohomish County. No Date. Summary of Drainage Plans and Regulations in
Snohomish County. 2 p.
Thetford, T., City of Everett Public Works Department. 1985. Letter to R.
Greiling, JRB Associates, dated May 12, 1985. Re: Response to EPA Region
10 industrial facilities inventory. 4 p.
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0203-83 Defense Fuel Support Point Mukilteo, Washington. Aberdeen Proving
Ground, Maryland. 18 p.
48
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U-S. Army Corps of Engineers. 1985. Plan of study for the Puget Sound
Dredged Disposal Analysis, open-water unconfined disposal sites. Seattle,
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U.S. EPA Region 10. 1985. Draft interim decision criteria for unconfined
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APPENDIX
AGENCY STAFF INTERVIEWED
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AGENCY STAFF INTERVIEWED
U.S. Army Corps of Engineers
John Malek, Environmental Planner
City of Everett
Al Theal, Director of Public Works
Clair Olivers, Utilities Engineer
Dennis Gregoire, Asst. Planning Director
Bob Landles, Environmental Coordinator
Dan Mathias, Associate Engineer
Walt Cooper, Fire Chief, Everett Fire Department
Gene Kent, Deputy Chief of Training, Everett Fire Department
Thomas Thetford, Utilities Engineer
U.S. Navy
Ed Lukjanowicz, Navy Homeporting Coordinator
Port of Everett
Harry Winder, Executive Director
Ed Paskovskis, Director of Operations
Lorraine Jefferson, Assistant Director
Snohomish County
Tom Niemann, Senior Planner, Planning Division
Tom Murdoch, Water Resources Coordinator, Public Works Division
Karen Nakhjiri, Director, Solid Waste Division
Snohomish County Health District
David Peterson, Assistant Director
Charles Magnum, Environmental Health
Richland Sarver, Water Systems
Washington Department of Ecology
Dave Wright, District Supervisor, Northwest Regional Office
Chuck Carelli, Water Quality Engineer, Municipal Division
Hunter MacDonald, Administrative Assistant to Director of NW Regional Office
David Jansen, Water Quality Engineer, Water Quality Planning & Mgmt. Section
Mike Palko, Division Supervisor
Washington Department of Fisheries
Phil Kauzlorik, Regional Habitat Manager
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Washington Department of Social and Health Services
Carl Sagerser, Toxic Substance Coordinator
Jack Lilja, Superintendent of Shellfish Program
Washington Department of Transportation
R.F. Johnson, District Design Engineer, Washington Dept. of Transportation
Tulalip Tribes
Dave Somers, Fisheries Biologist
Terry Williams, Fisheries Director
City of Snohomish
Tom Heydon, Public Works Director
City of Mukilteo
Allen Giffen, Planner/Code Enforcer
Brent Leslie, City Engineer
Lake Stevens Sewer District
Darwin Smith, Superintendent
Defense Fuels Support Command - Mukilteo
Jim Reynolds, Assistant Superintendent
City of Marysville
Robert Kissenger, Utilities Superintendent
U.S. EPA Region 10
Debra Flood, Environmental Protection Specialist, Superfund Branch
Carl Kassebaum, Water Resources Assessment Section, Environmental Evalua-
tion Branch
Martha Burke, Community Involvement Coordinator, Office of Puget Sound
John Osborne, Environmental Engineer, Field Operations & Technical Support
Branch
Mike Matta, Environmental Engineer, Field Operations & Technical Support
Branch
Robert Robichaud, Regional Pretreatment Coordinator
John Underwood, Director, Office of Puget Sound
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