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.

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                                                        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.

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                                                      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.

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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

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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

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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

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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.

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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
                                      28

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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.
                                29

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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).
                                     30

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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:

                                     31

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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
                                     32

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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.
                                      33

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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
                                     37

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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

                                      41

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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.
                                     45

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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.
                              46

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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
    appendices.

City of Everett Planning Department and Brown and Caldwell.  1982.  Draft  envi-
    ronmental  impact  statement  for  the  south  Everett  drainage  basins  plan.
    Everett, Washington.  357 p. plus appendices.

City of  Everett.    1984.   Approval of  permit  application  No. SMA 2-84.   Sub-
    stantial  development/conditional  use for Washington Department  of Natural
    Resources, Division  of Marine  Lands  to  renew  permit  for deep-water  dis-
    posal in Port Gardner Bay.  2 p. plus Attachment "A".

City of Everett.   1984.  "Everett  economic  development  priorities".   Everett,
    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.
                                     47

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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.
    plus Notice of Violation.   4 p.

Port  of  Everett  and  Dames and Moore.   1985.   Application for  Section  10/404
    Permit  to U.S. Army Corps of Engineers Seattle  District.   2 p.  plus
    attachments.

R.W.  Beck and  Associates.   1985.   City of Mukilteo  comprehensive sewer  plan.
    Prepared for City  of  Mukilteo.  24 p.  plus appendices and maps.

Robichaud, R.R.   1984.   Letters to  Superintendents  of Washington  POTWs,  dated
    November,  1984 and May,   1985.   Re:   Updating  EPA Region 10  industrial
    facilities  inventory.  Seattle, Washington.  3 p. each plus attachments.

Science  Applications  International  Corporation.    1985.   Preliminary  problem
    assessment of the Everett landfill  tire  fire.  A report  prepared for  the
    City of  Everett, Washington.   91 p. plus appendices.

Snohomish County  Metropolitan Municipal  Corporation  (SNOMET) et  al.    1977.
    SNOMET/King  County 208 Water  Quality Management Plan.   Summary  Report.
    Everett, Washington.   70 p.

Snohomish County  and CH2M Hill,  Inc.   1980.   Lower Snohomish  Basin  201
    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.

U.S. Army Environmental Hygiene Agency.   1982.  Geohydrologic study  No.  38-26-
    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,
    Washington.  27 p.  plus  exhibits.

U.S.  EPA  Region 10.   1985.  Draft  interim  decision criteria  for  unconfined
    disposal  of dredged material  at  the Port  Gardner  open-water disposal site.
    Dated May 5 and September  16, 1985.  Seattle, Washington.  15  p,
u



.S. Navy. 1984. Draft EIS Carrier Battlegroup (CBG) Homeporting in the
Puget Sound Area, Washington State. Prepared for U.S. Department of the
Navy Western Division, Naval Facilities Engineering Command. San Bruno,
California.
U.S.  Navy.   1985.   Final  EIS  Carrier  Battlegroup  (CBG)  Homeporting  in the
    Puget Sound  Area,  Washington  State.   Prepared for U.S. Department of the
    Navy Western  Division, Naval  Facilities  Engineering  Command.   San Bruno,
    California.

Washington  Department  of  Ecology,  Northwest  Region.   1984.  District II
    Compliance Inspection Schedule 1985.   1 p.

Winder,  H.A.  1985.   Letter  to D. Moos, Washington  Public Ports Association,
    dated April  1,  1985.   Re:   Estimated port dredging quantities.  Everett,
    Washington.   1 p.
                                    49

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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
                                      50

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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
                                      51

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