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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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. ------- 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. ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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). ------- 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 ------- Marysville Possession Sound Slough Steamboat Slough Snohomish River Figure 1 EVERETT HARBOR ACTION PLAN PROJECT AREA ------- 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, ------- 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. ------- 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. ------- 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 ------- 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. ------- 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. ------- 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. ------- Table 1 (cont'd) PROBLEM: TREATMENT AND DISPOSAL OF MUNICIPAL AND PRIVATE WASTEWATER PROGRAM 201 Lower Snohomish Basin Facilities Plan National Industrial Pretreat- ment Program Washington House Bill No. 3812 Washington Substitute House Bill No. 815 Citizens Advisory Comnittee Review of Standards for Trick- ling Filters and Lagoon Treat- ment Facilities Miscellaneous Treatment Guide- lines and Criteria Revisions Everett Proposed Wastewater Treatment Plant Expansion* Everett Proposed Pretreatment Program* Everett Subregion Interceptor Sewers Plan** Lake Stevens Treatment Plant Upgrade Mukilteo Comprehensive Sewer Plan* LEAD AGENCY Snohomish Basin Sewer Districts & Municipalities EPA/DOE DOE DOE/PSWQA DOE DOE City of Everett City of Everett City of Everett Lake Stevens, DOE, CERB City of Mukilteo TIME FRAME 1976-1980 1978-Ongoing 1985-1986 1985-1988 1985 1985-1986 Begin Construc- tion in 1987 1985 1980-Ongolng 1985 1985-1987 ACTION Identified municipal vastewater problems and recommended capital Improve- ments to areawide sewer facilities and systems. This action represented a study and review only, it Is not a specific regulatory or remedial action. Increased monitoring and enforcement of categorical pretreatment standards; updated survey of Industrial facilities. Sec. (1) - Report all enforcement actions regarding Puget Sound protection, hold public hearings on report, and prepare summary for legislature. Sec. (2) - Establishes new, stricter penalties for waste discharge permit violators. Sec. (1) - Requires review of existing pretreatment standards for industrial wastewater discharged Into sewage facilities that discharge Into Puget Sound. Sec. (2) - Requires plans and compliance schedules for greatest reasonable reduction of CSOs. These actions represent studies and review only, they are not specific regulatory actions. Review of new federal 30/45 standards; recommending (1) whether state should promulgate secondary treatment standards, and (2) how federal stan- dards would Impact existing and proposed Washington facilities. This action represents a review of existing standards and is not a regulatory action. (1) Revise sewage works design criteria. (2) revise dilution zone criteria standards, (3) review chlorine disinfection guidelines. These actions represent a review and are not regulatory actions. FEIS to upgrade treatment lagoon (Alternative 2) (see Table 2). Undertake an Industrial waste survey and develop discharge limitations to ensure program compliance. Southwest Interceptor completed; extends treatment plant service area and reduces CSO flows in the north end. Plant upgraded to activated sludge treatment; extended diffuser 200 feet in Ebey Slough. Tie-In Mukilteo1 s waste water to Olympus Terrace sewer district; dismantle primary treatment plant. *These programs/actions are currently only In their planning stages and were not Implemented at the time of this writing. **This program is currently in effect but is Implemented In stages. ------- Table 1 (cont'd) PROBLEM: CONTROL OF URBAN AND AGRICULTURAL RUNOFF PROGRAM Areawide Drainage Plans and Regulations: SNOMET/King County 208 Plan** South Everett Drainage Basin Plan** Snohomish/Lake Stevens Basin Plan Storm and Sanitary Sewer Study Marysville Comprehensive Basin Plan* Hukilteo Storm Drainage Study* Everett EMC Drainage Code No. 670-80-514-78** Snohomish County Title 24 Drainage Ordinance** Revised Lagoon Guidelines Watershed Management Activi- ties House Bill 814 Shoreline Master Program (SMP) LEAD AGENCY Snohomish County, King County City of Everett City of Snohomish, City of Lake Stevens Paine Field City of Marysville City of Mukilteo City of Everett Snohomish County Snohomish County, SCS Snohomish County County Legislatures City of Everett, Snohomish County TIME FRAME 1976-Ongoing 1982 1979 1981 1983 1985 1980 1980 1984-1985 I980-0ngo1ng 1985 1974-Ongoing ACTION Identifies problems and designates agencies for corrective programs. This action represents a comprehensive planning study, it is not a specific remedial or regulatory action. FEIS Identifies structural improvements and policy/ordinance revisions. This action represents a comprehensive planning study, it is not a specific remedial or regulatory action. Basin plan with resource protection goals. This action represents a com- prehensive planning study, it is not a specific remedial or regulatory action. Identified structural improvements to accomodate future expansion and development; performed improvements to Japanese Gulch retention pond. Designates stream corridors and recommends development of stream setbacks. FEIS includes proposed structural improvements and new drainage policies. Requires a drainage plan and runoff controls for development projects. Uses permit fees to Implement drainage controls. Requires a detailed drainage plan for development projects In designated critical areas and requires runoff controls. Regulations In this Ordinance were revised in September, 1985. Uses permit fees to implement drainage controls. Provide design guidelines of manure holding ponds for dairy land agriculture. Programs Include stream rehabilitation projects and retention facility Inventory. Provides for county legislatures to establish shellfish protection zones and regulatory measures to eliminate or decrease pollutants in stormwater. Shoreline use controls through shoreline planning and a master use permit process to help control runoff from agricultural areas. *These programs/actions are currently only in their planning"stages and were not implemented at the time of this writing. **These programs are currently in effect, but they are implemented in stages. ------- Table 1 (cont'd) ro PROBLEM: CONTROL OF OTHER POINT SOURCES PROGRAM DoD Fuels Support Facilities, MuMlteo Groundwater Monitor- Ing Everett T1re F1re Investiga- tion Cathcart/Lake Stevens Leach- ate Disposal Problems Tulalip Landfill Site Investi- gation Tulalip Landfill Capping RCRA Section 3012 Investiga- tion Hazardous Materials Response Team LEAD AGENCY DoD, EPA City of Everett Snohomlsh County, City of Everett WDOE, EPA Tulalip Tribes WDOE City of Everett Fire Department TIME FRAME 1983-1984 1984-1985 1985 1984-Ongolng 1985 1984-1985 1985 ACTION Groundwater Investigation of DFSP terminal; results Indicate contamination , from JP-4 and associated organ ics. At present, no remedial actions have occurred at this site. Site Investigation completed, protective and remedial actions Implemented on-slte. More comprehensive remedial actions are expected In 1986. County reviewed options to treat landfill leachate possibly on-slte or transferring to Snohomlsh wastewater treatment plant. The county will Increase pretreatment of leachate on-slte in November, 1985. RCRA site Inspection of closed landfill to assess environmental and health risks. Proposed barge loading facility to accept fill material (from 1-90 construc- tion) to cover Tulalip Landfill on Steamboat Slough. Preliminary assessments of potential hazardous waste locations statewide. This action represents a review only; It Is not a regulatory or remedial action. Fire fighters trained to recognize and handle hazardous materials. ------- The objectives of the study are: Identify acceptable sites for unconfined, open-water disposal of dredged material in Puget Sound. Identify procedures to assess the acceptability of dredged material for open-water unconfined disposal, and for alternatives to uncon- fined disposal. Formulate plans to manage confined, open-water disposal sites in Puget Sound. Generate an Environmental Impact Statement (EIS) for the study's two phases. The EIS will be prepared in order to assess the potential impacts of several alternatives and to obtain public input for these assessments. Six public meetings were held in May 1985 to discuss the proposed scope of the study and to receive public comment on it. The EIS will address alternatives to uncon- fined, open-water disposal; identify chemical and biological evaluation pro- cedures for testing dredged materials; and define monitoring and management needs for disposal sites. Phase I, initiated in April 1985, includes the Central Sound (including Everett Harbor) and will take approximately two years to complete; Phase II will include the remainder of Puget Sound (and other marine inland waters of Washington) and will start in April 1986. The boun- daries of the study areas are presented in Figure 2. 2.1.2 Interim Decision Criteria for Unconfined Disposal of Dredged Material at the Port Gardner Open-Water Disposal Site Lead Agencies: EPA; City of Everett; WDOE Time Frame: Final Draft Criteria developed in the fall of 1985. The major open-water disposal site for dredge material from Everett Harbor and the lower Snohomish River channel and delta is a 58-acre site located in Port Gardner, approximately 1,000 yards from Howarth Rock in water 250 to 400 feet deep. In July 1984, a conditional use permit (No. SMA #2-84) was granted to WDNR by the City of Everett to allow continued operation of the disposal site. Condition No. 7 of the permit states that the operation or use of the site "... shall be contingent upon EPA using disposal criteria which shall be developed and approved by the City Planning Department prior to any additional 13 ------- 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 ------- 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 ------- 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 ------- 2.1.3 Proposed Homeport for a Carrier Battle Group in the Port of Everett Lead Agency: U.S. Navy Time Frame: FEIS submitted in the summer of 1985; proposed construc- tion period is from 1987-1990. The U.S. Navy proposes to construct and operate a Carrier Battle Group (CBG) Homeport at the Norton Avenue Terminal in Everett. The CBG would accommodate 13 ships including one aircraft carrier. New facilities, including berthing space for the 13 ships, would be constructed and this would require the dredg- ing and disposal of an estimated 2.5 million cubic yards of marine sediments, some of which are contaminated. The preferred disposal location is the deep delta site (Figure 4a). The preferred disposal method is covering contami- nated sediments with clean materials (i.e., native marine sediments and dredged material from the shoreline, Figure 4b) called "capping". Navy plans also call for the removal of one million cubic yards of beach, shoreline, and upland material to accommodate land-based uses. Most of this material would probably be used as fill elsewhere on the site. As part of the U.S. Navy's EIS process, several environmental studies were undertaken. These studies do not specifically address water quality or pollutant issues, but provide baseline characterizations of the Port Gardner environment. These studies include: Seabird and Marine Mammal Survey - Weekly censuses from September 1984 until May 1985 to document existing use of the project area and surroundings by seabirds, waterfowl, marine mammals, and, particu- larly, threatened or endangered species. Juvenile Salmonid Stomach Content Analysis - This study, undertaken during the spring and summer of 1984, was designed to identify the food types and quantities consumed by juvenile salmonids found in the project area. Benthic and Epibenthic Analyses - Forty-five benthic sediment sam- ples and 41 epibenthic samples were collected in July 1984 to char- acterize the structure of the project area benthic community and to predict impacts from CBG construction. The epibenthic analyses were conducted to characterize the existing community, predict impacts, and correlate data to the salmonid study described above. Demersal Fish Analysis - Conducted in the East Waterway in October 1984, this study documented occurrence and relative abundance of demersal species. The study was also used to evaluate impacts from the proposed action. 17 ------- A CLEAN CAP AND LATERAL CONTAINMENT Source: U.S. Navy FEIS, 1985 Figure 4 PREFERRED U.S. NAVY PROPOSED HOMEPORTING DISPOSAL LOCATION (A) AND BOTTOM PROFILE OF CONFINED AQUATIC DISPOSAL (B) 18 ------- Investigations for 1985 and 1986 will test preferred dredge disposal methods. These studies are: Site analysis using geotechnical borings and evaluation of slope stability. t Determination of optimum cap size; leachate and settlement tests. Equipment evaluation and selection. Development of a construction monitoring plan. t Other design considerations such as defining lateral containment needs and a navigation/positioning plan for accurate sediment placement. The City of Everett and WDOE have lead SEPA responsibilities for EIS review. On October 16, 1985, they jointly decided that the FEIS met SEPA requirements under the condition that a supplemental EIS be prepared to address several key issues. WDOE is responsible for preparing the supplemental EIS which will address the following water and sediment quality related issues: Dredged material disposal - More detailed review of existing emplacement technologies, including capping; and alternatives to open-water disposal. Ship "grey-water" disposal - Some Navy ships lack hookups for proper disposal of water from kitchens, showers, sinks, etc. Organotin anti-fouling paint - More detailed assessment of water quality impacts from leaching and flaking of organotin paint. Oil transfer and storage - More detailed assessment of water quality impacts. 2.1.4 Dredge and Fill Permit for Port of Everett's Terminal/Industrial Complex Site Improvements Lead Agency: Port of Everett Time Frame: Application submitted to COE in June 1985; proposed project construction period will coincide with U.S. Navy's Homeport- ing construction (1987-1990). The U.S. Navy's decision to homeport a Carrier Battle Group (CBG) within the Everett Harbor area will necessitate an expansion of the existing Port 19 ------- facility. The permit application describes construction of 3,600 feet of new docking space including the construction of new berthing for water-based log loading, creation of an upland area of approximately 53 acres, and development of a 10-acre public park and a 200-foot public fishing pier. The proposed Port expansion will occur at the site of the old Weyerhaeuser sulfite pulp mill and the Hewitt terminal (Figure 5). Based on a 404 (dredge and fill) permit application filed by the Port on August 6, 1985, three conclusions can be gathered: (1) over 400,000 cubic yards of material is to be dredged from the Weyerhaeuser site; (2) 210,000 cubic yards from the Hewitt Terminal; and (3) over 500,000 cubic yards of dredged material is proposed to be utilized as fill for the project. In a letter to the Washington Public Ports Association (April 1, 1985), the Port has estimated that 50,000 cubic yards of dredged materials may be contaminated (Port of Everett, 1985). The Port's dredging plans are currently (as of November 1985), under revision. Proposed activity includes: removal of 210,000 cubic yards of subtidal material north of Pier 3, the use of 40,000 cubic yards of material for upland and intertidal fill at the same site, subtidal removal of 260,000 cubic yards south of Pier 1, and use of 400,000 cubic yards as fill for 14 acres at the Pier 1 site. It is not known what portion of the sediments may be contaminated. 2.1.5 Detailed Chemical and Biological Analyses of Selected Puget Sound Sediments Lead Agency: U.S. Environmental Protection Agency Time Frame: Draft Final Report undergoing peer review In order to characterize surface sediments in marine waters, EPA has contracted for physical and chemical analyses of over 100 surface sediments obtained from four reference embayments (relatively undeveloped) and four urban embayments including Everett Harbor. Screening and selection of the above samples re- sulted in detailed chemical, physical, and biological analyses of 60 samples. Shellfish and fish pathological data were also collected and synthesized by the National Marine Fisheries Service (NMFS). The sampling and analyses occurred in 1984. 20 ------- 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 ------- 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 ------- 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 ------- Table 2 LOWER SNOHOMISH BASIN 201 STUDY RECOMMENDATIONS AND STATUS 201 SUBRECION 1980 STUDY RECOMMENDATIONS CURRENT STATUS (1985) EVERETT Includes: Silver Lake Hater District, Mukllteo Hater District, a portion of Alderwood Hater District, and the City of Everett 1. Upgrade treatment facility. 2. Construct south and southwest Inter- ceptors and pump stations. FEI5 for treatment plant expansion submitted 6/85 and Includes two proposed stages: Stage 1 - Construction of oxidation pond, redrculatlon channel, and sludge transfer facilities; Stage 2 - to be Instituted when 1990 population projections have been reached and will Involve expansion of existing aeration lagoon. Southwest Interceptor project Including the expansion of Pump Station No. 1 and bypass of Pump Station No. 14 operational In 1985. Designing enlargement for Pump Station No. 9. No construc- tion or plans for recommended South Interceptor. Flows to Pump Station No. 2 (and overflows) reduced by adding Pump Station No. 1. MARYSVILLE Includes: City of Marysvllle, Arlington Airport, Island crossing to the north and Priest Point to the west. 1. Upgrading existing treatment lagoon and pump stations. 2. Replace or construct Interceptors. 1. Enlarged the lagoon plant by 40 acres (1983), added second cell aerator, and chlorine contact chamber. Expansion will accomodate a projected population of 90,000. 2. Main carrying Petunia Sewer District flows south to Marysvllle wastewater treatment plant. SNOHOMISH Includes: City of Snohomlsh and adjacent areas to the north, south and west. 1. Upgrading existing treatment lagoon and pump station. 2. Construct Interceptors. 1. No known upgrades, reestablished chlorlnatlon contact chamber. More chlorlnatlon work will be undertaken In five-year comprehen- sive plan. 2. Need for Interceptor for additional services In the north, but Is not designed or scheduled until a funding source Is secured. LAKE STEVENS Includes: City of Lake Stevens and Lake Stevens Sewer District. 1. Treatment lagoon and pump station Improvements. 2. Interceptor extension. 1. Converted aeration lagoons to activated sludge (8/85). Extended main outfall 200 feet Into Ebey Slough to achieve better dispersion 2. One Interceptor Installed; two more are needed, but as yet are not scheduled until funding Is secured. TULALIP TRIBES No recommendations; plant achieves secondary treatment. Plant reportedly near or at treatment capacity. Sources: Washington Department of Ecology; City of Everett Utilities & Planning Divisions; City of Marysvllle Utilities Department; City of Snohomlsh Public Horks Department; Lake Stevens Sewer District; City of Mukllteo. ------- health district officials also reported areas in which there are recreational developments (i.e., campgrounds) which may have overloaded septic systems. In addition, older private systems may not be adequately maintained or may have exceeded their maximum age for effective treatment. The Health District iden- tified no specific locations or incidents of chronic contamination by septic systems. 2.2.2 National Industrial Pretreatment Program Lead Agencies: EPA; WDOE Time Frame: Ongoing since 1978 To achieve the control of industrial toxicants into publicly-owned treatment works (POTWs), the EPA promulgated General Pretreatment Regulations (40CFR 403). Three major objectives of these regulations are: Prevent toxicant interference with POTW operations. Prevent toxicants from passing through POTWs and entering into receiving waters. Improve feasibility of municipal sludge recycling and reuse. EPA, the state of Washington, and some local treatment facilities are develop- ing programs to meet these objectives. These programs establish pretreatment effluent standards for several types of industries according to the nature of their process wastewaters (see Table 3). These programs also develop stan- dards that will control or prohibit discharges of materials that create hazards, obstruct flows, or cause structural damage to the sewer systems. In the fall of 1984, EPA Region 10 updated its inventory of industrial users within all municipalities served by wastewater treatment plants. At the time of this writing, the Cities of Everett, Mukilteo, and Snohomish have responded to EPA's survey. The City of Everett is expected to begin a pretreatment program in 1985. The Cities of Mukilteo and Snohomish report that they receive no industrial wastes that would be subject to pretreatment standards. (The City of Lake Stevens does not have a formal pretreatment program but it does receive pretreated industrial wastewaters from Hewlett-Packard.) Table 4 identifies categories of industries that discharge to the Everett system. 25 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. 34 ------- 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. 35 ------- 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 36 ------- 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 ------- 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 38 ------- 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). 39 ------- 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. 40 ------- 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 ------- 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: 42 ------- 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. 43 ------- 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. 44 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- APPENDIX AGENCY STAFF INTERVIEWED ------- 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 ------- 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 ------- |