Puget Sound Estuary Program
ELLIOTT BAY  TOXICS
ACTION PROGRAM

INTERIM WORK PLAN
PREPARED BY:
TETRA TECH, INC.

PREPARED FOR:
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON DEPARTMENT OF ECOLOGY
PROGRAM PARTICIPANTS:
City of Seattle
Elliott Bay Citizens Advisory Committee
King County
METRO
National Oceanic and Atmospheric Administration
Port of Seattle
U.S. Army Corps of Engineers
Washington Department of Natural Resources
Washington Department of Social and Health Services

-------
Final Report
TC 3991-01
ELLIOTT BAY TOXICS ACTION PROGRAM:
INTERIM WORK PLAN
by

Tetra Tech, Inc.
for

U.S. Environmental Protection Agency
Region X - Office of Puget Sound
Seattle, WA

Washington Department of Ecology
Olympia, WA
October, 1985
Tetra Tech, Inc.
11820 Northup Way, Suite 100
Bellevue, Washington  98005

-------
                            EXECUTIVE SUMMARY
     Previous  studies of Elliott  Bay and the  lower Duwamish River have
revealed extensive contamination by  toxic  metals such  as  copper,  lead,
zinc, and  arsenic, as well as organic compounds  such as petroleum products
and PCBs.   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 U.S.  Environmental Protection Agency and  the Washington Department
of Ecology,  working with the city of Seattle, METRO,  and  others, have  developed
an Action  Program to correct the toxic  problem  in the Elliott Bay system.
The Action  Program  1)  identifies existing  problems  of  toxic  contamination,
2) locates sources of toxics, 3) implements  corrective actions to  eliminate
existing problems, 4)  identifies appropriate agencies  for implementing
corrective actions,  and 5) provides a schedule  for implementing corrective
actions.  Corrective  actions include  source  controls and  the removal  of
contaminated sediments.   Source controls  can  include permit revisions to
reduce the  strength or volume of discharges  and management  activities  to
reduce the  contamination of  surface runoff.

     Priority problem  areas  were identified by analyzing data  on contamination
and biological  effects.  Areas received a  ranking  of high  priority if they
exhibited  a particularly  high level  of contamination  and/or biological
effects such as high  prevalence of liver tumors  among  bottom-dwelling  fish,
or a  very  low number of  bottom-dwelling species.  Actual  and  potential
contaminant sources were  identified  for  each priority  problem area,  and
for the study area  in  general.  This Work  Plan focuses on controlling  identified
sources and better  characterizing potential ones.

     The Work  Plan is unique in its approach to  controlling contamination,
in that it  brings many regulatory and  management  organizations  together
in an Interagency Work Group to take coordinated  action to address  particular
problem areas  and specific sources of contamination.  The Work Plan represents
the  input  of many agencies and local governments;  and citizen groups  and
users  (via a Citizen's Advisory Committee).  Business, industry, environmental,
and citizen groups were  represented  in  a  Citizen's Advisory Committee.
The Citizen's Advisory  Committee was  consulted  to  provide direct  input
into all stages of  program development.

     This  Work  Plan  is  being  carried out through the existing regulatory
and resource management mechanisms of  agencies and local  governments  and
by a  special Action  Team  for Elliott Bay.   The  five members of the  Action
Team are funded  by the Washington  Department of Ecology  and METRO with
the support and participation of the city  of  Seattle and U.S.  EPA.

     The regulating  and  management efforts of  the  Interim Work  Plan will
focus  on priority  problem areas.  Most of the high  priority areas are located
in the  lower Duwamish River  adjacent to Harbor Island.   Others include


                                    11

-------
the Denny  Way CSO area,  the  Seattle Waterfront near Madison Street, and
Slips 1-4 in the Duwamish River.  The Fourmile Rock  dredged material disposal
site ranked as  a moderate  priority.   However, because of public concern,
the area is included in the Interim Work  Plan.   Table  2  is the Site Specific
Interim  Work Plan for the  Elliott Bay  Toxics Action Program.  A summary
of the  actions in  the Work Plan follows:

     0     Twenty-one NPDES and state discharge permit  actions, including
          issuance of  new permits, issuance  of  stormwater  permits,
          assessment of tighter controls, and site  inspections

     •     Three RCRA permit actions, including two  site  closures

     •     Two criminal  investigations  and resultant cleanup actions,
          including the  removal of severely contaminated  sediment
          from the Florida Street storm drain

     •     Review  of historical  activities and practices at 12 sites
          to determine significance of  past  toxic contamination

     t     Cleanup  of contamination by  the removal  of sediments from
          five drains

     •     Eleven  groundwater contamination investigations

     t     CSO planning,  including the  removal of the  lower Rainier
          Valley  stormwater component from the Hanford CSO

     •     Facilities planning,  including  the transfer Renton sewage
          treatment plant effluent from the  Duwamish River to a  deep-
          water site in Elliott Bay

     •     Numerous sampling and analysis  studies to better characterize
          environmental conditions and  identify sources.

     Because  actions  in this Work Plan were  defined  based on a review of
existing environmental and contaminant  source data,  it  is  referred  to as
an  Interim Plan.   However, the plan is actually a  working document designed
to be refined as  new data are made available.  The  Interagency Work  Group
and Citizen's Advisory Committee will  be responsible for updating and imple-
menting the Work Plan.  They will meet on a regular, basis  (at least quarterly)
to review progress made on implementation of the plan, resolve any problems,
and refine the plan to reflect new information.
                                    111

-------
                                  CONTENTS


                                                                        Page

EXECUTIVE SUMMARY                                                        ii

LIST OF FIGURES                                                          vi

LIST OF TABLES                                                          vii

ACKNOWLEDGEMENTS                                                       viii

GLOSSARY                                                                  x

INTRODUCTION                                                              1

    STUDY AREA                                                            2

    APPROACH                                                              2

    PRIORITY PROBLEM AREAS                                                7

    REPORT ORGANIZATION                                                   9

INTERIM WORK PLAN FOR ELLIOTT BAY TOXICS ACTION PROGRAM                  10

    AREA-WIDE ACTIONS                                                    10

    SITE-SPECIFIC WORK PLAN                                              15

    DECISION FRAMEWORK FOR CONTROLLING POLLUTANT SOURCES                 30

APPENDIX A.  MAPS

     Map 1.  Public Access Points and Recreational
             Areas

     Map 2.  Contaminant Sources and Selected Industry
             Locations in Elliott Bay and the Lower
             Duwamish River

APPENDIX B.  ENVIRONMENTAL CONDITIONS AND POTENTIAL
             SOURCES OF CONTAMINANTS FOR STUDY AREA
             SEGMENTS OF ELLIOTT BAY AND THE LOWER
             DUWAMISH RIVER

             NORTH HARBOR ISLAND
             EAST WATERWAY
             WEST WATERWAY


                                     1v

-------
SOUTH HARBOR ISLAND
DENNY WAY CSO
SEATTLE WATERFRONT
SLIP 1
SLIP 2
SLIP 3
SLIP 4
FOURMILE ROCK DISPOSAL SITE

-------
                                  FIGURES


Number                                                                  Page

   1    Study area drainage boundaries                                    3

   2    Preponderance-of-evidence approach to evaluation of
        toxic contamination problems                                      5

   3    Classification of study area segments in terms of
        priority for interim action                                       8

   4    Approach to characterization of direct discharges and
        ultimate pollutant sources                                       32

   5    Control of problem drains and CSOs                               33

   6    Control of categorical sources                                   34

   7    Control of illegal dumping                                       35
                                     v1

-------
                                   TABLES
Number                                                                  Page
   1    Primary kinds of data used in problem area identi-
        fication and priority ranking                                     4
   2    Work Plan for Elliott Bay Interim Action Program                  16
                                     vi i

-------
                             ACKNOWLEDGEMENTS
     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  authors  of this report were Mr. Pieter N.  Booth and Dr. Robert
A. Pastorok of Tetra  Tech.  Mr. Gary Brugger of  the  Washington  Department
of Ecology and Mr.  Thomas P. Hubbard  of the Municipality of Metropolitan
Seattle prepared  drafts of the Interim Work Plan table.   Their  contribution
in developing specific  agency actions  and  implementation  schedules was
invaluable.  Dr.  John Armstrong of  U.S.  EPA  provided  critical technical
review and coordination with other agency activities.   Ms.  Joan K. Thomas
of the Washington Department of Ecology and Mr. John  Underwood of  U.S.  EPA
provided managerial  guidance, encouragement, and  review throughout the
project.  Ms. Marcy B. Brooks-McAuliffe of Tetra Tech performed technical
editing and supervised report  production.

     The  Elliott Bay Action  Program has  benefited from the  participation
of an  Interagency  Work Group  (IAWG)  and a Citizen's  Advisory Committee
(CAC).  Duties of the  IAWG and CAC members included:  1)  reviewing  program
documents, agency policies, and proposed actions; 2)  providing  data  reports
and  other technical  information to  U.S. EPA; and  3)  disseminating action
program information to respective  interest groups or constituencies,  and
to the general  public.   We  thank  the  IAWG and CAC members  for their past
and continuing efforts.  Ms.  Patricia O'Flaherty of SAIC/JRB  Associates
provided support  for the CAC activities.  Mr. Hunter  MacDonald of  Ecology
provided support  to the  IAWG.   We are especially grateful  to Ms.  Joan Thomas
                         to Mr. David Schneidler and Ms.  Janet Anderson for
                        to the following individuals  for  insightful comments
                        the project;  Dr. John Armstrong;  Mr.  Douglas Briggs;
                         Thomas Hubbard and other METRO  personnel; Mr. James
Heil; Mr. Douglas Hotchkiss; Mr. David Jamison; Mr.  Edward Long;  Dr.  Charles
Muller; Mr. Dan Petke; Mr.  James Puckett; Dr.  Richard Rutz; and Mr. Frank
Urabeck and  other COE  personnel.  Members of the  IAWG and  CAC are listed
below.
for chairing the IAWG.
co-chairing  the  CAC,  and
on technical  aspects  of
Mr.  Ralph Domenowske,  Mr.
Name

John Armstrong
Ralph Domenowske
Charles J. Henry
Douglas Hotchkiss
Elsie Hulsizer
David Jamison
Carl Kassebaum
Edward Long
                    ELLIOTT BAY INTERAGENCY WORK GROUP

                             Affiliation

                             U.S. Environmental  Protection Agency
                             METRO
                             1984 Puget Sound  Water  Quality Authority
                             Port of Seattle
                             City of Seattle
                             Washington Department of  Natural Resources
                             U.S. Environmental  Protection Agency
                             National Oceanic  and Atmospheric Administration
                                    viii

-------
Jane Lee                      Seattle-King County Department of Public Health
Dan Petke                     Washington Department of Ecology
Carl Sagerser                 Washington Department of  Social and  Health
                                Services
David Schneidler              Citizen's Advisory Committee
Martin Seybold                King County
Joan Thomas                   Washington Department of Ecology
John Underwood                U.S. Environmental Protection Agency
Frank Urabeck                 U.S. Army Corps of Engineers

Alternates and Other Participants^

Jeffrey Bauman                METRO
William Clindaniel            City of Seattle
John Dohrman                  Port of Seattle
Vi11 amor Gamponia             METRO
Burt Hamner                   U.S. Army Corps of Engineers
John Lampe                    METRO
Robert Matsuda                METRO
Stephen Norsted               Washington Department of  Social and  Health
                                Services
Joseph Ralph                  City of Seattle
Robert Swartz                 METRO
Wally Swofford                Seattle-King County Health Department
Joseph Talbot                 City of Seattle
William Yake                  Washington Department of Ecology


                  ELLIOTT BAY CITIZEN'S  ADVISORY COMMITTEE

Janet Anderson                Magnolia Community Club
Douglas Briggs                Puget Sound Industrial Council
Harriett Bullitt              Friends of the Duwamish
Virginia Van Engelen          League of Woman Voters
Donald Hamilton               Seattle Poggie Club
James Heil                    Puget Sound Alliance
Paul Hickey                   Muckelshoot Indian Tribe
Dee Ann Kirkpatrick           Suquamish Indian Tribe
Minor Lile                    Greater Seattle Chamber of Commerce
Charles Muller                Sierra Club
James Pickett                 Puget Sound Alliance
Tom Putman                    Seattle Audubon Society
Annette Ramsour               Washington State Sports Diving Council
David Schneidler              Seattle Marine Business Coalition
Diana Swain                   Port Watch
Terry Thomas                  Northwest Steel head and Salmon Council
Mike White                    Northwest Marine Trade Association
Robert Williscroft            Washington State Sports Diving Council

Alternates and Other Participants

Chris Luboff                  Western Washington Toxics Coalition
Richard Rutz                  Seattle Audubon Society
                                    ix

-------
                                 GLOSSARY
Agency and Program Names
CAC
CATAD

COE
DCLU
DNR
DSHS
Ecology
EPA
EPA/CID
IAWG
METRO
NOAA
NPDES

PSWQA
PSEP

RCRA
SPCC
SUPERFUND
-  Citizen's Advisory  Committee
-  Computer Augmented  Treatment  and  Disposal System used
   by METRO to control  flows and  locations of  combined
   sewer overflows.
-  U.S.  Army Corps  of  Engineers
-  Department of Construction  and  Land Use (City of Seattle)
-  Washington Department of  Natural  Resources
-  Washington Department of  Social  and Health Services
-  Washington Department of  Ecology
-  U.S.  Environmental  Protection Agency
-  EPA/Criminal  Investigation  Division
-  Interagency Work  Group
-  Municipality  of  Metropolitan Seattle
-  National Oceanic  and  Atmospheric  Administration
-  National  Pollutant  Discharge  Elimination System (EPA/
   Ecology)
-  Puget Sound Water Quality Authority
-  Puget  Sound  Estuary Program  (EPA/Ecology),  including
   urban embayment  action  programs  such as the Elliott
   Bay Toxics Action Program
-  Resource Conservation and Recovery  Act
-  Spill Prevention  and  Control Contingency  Plan
-  EPA and  Ecology programs to  clean  up hazardous waste
   sites or other areas  of toxic contamination
TOSCA
-  Toxic Substances Control  Act

-------
TPPS
USCG
   Toxicant  Pretreatment Planning Study (METRO)
   U.S.  Coast  Guard
Chemical  Names
As
Cu
HPAH
LPAH
Pb
PCB
Zn
   Arsenic
   Copper
   High  Molecular Weight Polynuclear Aromatic Hydrocarbons
   Low Molecular Weight Polynuclear Aromatic Hydrocarbons
   Lead
   Polychlorinated  Biphenyls
   Zinc
Pollutant Source Names
CSO
CSO/SD
SD
-  Combined  Sewer Overflow.   A discharge  of raw sewage
   diluted  with  storm water,  which occurs  whenever the
   hydraulic  capacity of a combined sewer line is exceeded.
-  Combined  Sewer Overflow  and Storm Drain.  A combined
   source that discharges storm drainage during low flows
   and raw sewage diluted with storm water during  high
   f1ows.
-  Storm  Drain.   A source of stormwater discharge only.
Other Terms
Amphipod

Benthic
Bioaccumulation
Bioassay
   A small  organism  that superficially resembles a shrimp
   and lives on  the  sea bottom.   Amphipods  are used  in
   laboratory bioassays to test the toxicity of sediments.
   Pertaining to  the  bottom of a water body.
   Concentration  of a substance in tissues of an organism.
   Bioaccumulation of toxic substances may lead to disease
   or other  health problems.
   A laboratory  test used  to  evaluate  the  toxicity  of
   a material (commonly sediments or  wastewater)  by measuring
   behavioral,  physiological,  or lethal  responses  of
   organisms.
                                    xi

-------
Community


Diversity



Dominance
Elevation Above
Reference
Histopathology

Infauna

Invertebrate

Larvae



Lesion


Loading


Nonpoint Source


Pathology

Sediment

Toxic

Toxicity

Toxic
Contamination
A group of interacting  species  populations found within
a defined area.

The number of species  in  a  community, or  a mathematical
index  of the variety  of species  that also  accounts
for the relative abundance  of each  species.

An  index that measures  the relative  distribution of
individuals among  species.  When  dominance  is  high,
a few species are very  abundant and  others are rare.
An  index of toxic contamination  or  biological effects,
which  is equal to the value  of  a  variable  (e.g., chemical
concentration) at a  study  site  divided by the value
of the same variable at  a  relatively "clean"  reference
area.

Study of tissue disease

Animals living  within  the  bottom  sediments

Animals without backbones

(singular larva)  A juvenile  stage with a  body form
that differs greatly  from the adult stage  (e.g., an
oyster larva is a small  free-floating  organism).

An abnormal structural  change in  the body due to  injury
or disease (e.g., a liver  tumor in fish)

Quantity of a substance  that  enters  a  water body during
a specified time interval  (e.g.,  pounds  per year)

A nonspecific  source  of pollutants, often from a large
area (e.g., stormwater drainage)

Study of disease

Material that settles  to the  bottom  of a water body

Relating to a poisonous  substance

Poisonous quality of a  substance
Presence of toxic substances,  often  caused by releases
of metals or synthetic  organic chemicals to the environ-
ment
                                    xi 1

-------
                               INTRODUCTION
     Previous  investigations of  Elliott Bay and the lower Duwamish River
have revealed  extensive contamination by toxic metals  (e.g., copper,  lead,
zinc, mercury, and  arsenic) and organic compounds  (e.g., petroleum products,
PCBs).  Some of these  substances may  accumulate at high  concentrations
in  tissues  of marine  organisms, posing  a  hazard to the aquatic ecosystem
or to human  consumers of local seafood.   Ecosystem perturbations associated
with  anthropogenic  inputs  of toxic  substances may include  decreases  in
abundance and  species diversity of benthic (bottom-dwelling)  communities
and  increases in  the  prevalence of tissue disorders (e.g.,  liver tumors
in fish).

     In cooperation with other resource, management agencies,  the U.S.  Environ-
mental Protection Agency (U.S. EPA) and the Washington Department of  Ecology
(Ecology)  are developing  an action program  to correct toxic problems  in
the Elliott  Bay system.  Corrective actions may include, for example, source
controls to  reduce  toxicant emissions and cleanup  of contaminated sediments.
The objectives of the Elliott Bay Toxics Action Program are to:

     •    Identify problem  sites based  on toxic  contamination and
          associated  biological effects

     t    Identify  toxicant sources

     •    Rank  problem sites  and sources  in terms  of priority for
          action

     •    Outline actions by  individual  agencies  and cooperative efforts
          among agencies to correct the identified problems.

The  ultimate  goals  of the  action program  are  to protect the marine and
estuarine ecosystem against further degradation  from  anthropogenic   inputs
of  toxic materials, to restore areas  degraded  previously, and to  protect
beneficial  uses that  may be affected by toxic contamination.

     The action  program is  being developed in  two  phases.  In the first
phase, interim actions  are specified for high priority problem  areas  based
on  available  data.  These short-term actions mainly involve source controls
and field investigations planned for the 1-2 yr as  part of ongoing regulatory
and  management programs.   The Interim Work Plan described in this report
serves as an immediate  vehicle for interagency coordination.  In the  second
phase,  additional  field  data will be  collected and analyzed to  develop
a Comprehensive Work  Plan (scheduled  for 1986).   Companion documents for
the Interim  Work  Plan are the following:

     •    Elliott  Bay  Toxics Action Program: Review  of Existing Plans
          and  Activities.   A detailed  summary  of ongoing remedial
          action  programs and plans.

-------
     •     Elliott Bay Toxics  Action Program:  Initial  Data Summaries
          and Problem IdentificatioTr!   A synthesis of available data
          on toxic contamination  and  biological effects,  and a decision-
          making approach for ranking  problem areas.

     •     Sampling  and  Analysis Design for Development of Elliott
          Bay  Toxics Action  Program.  A detailed study design for
          further investigation of pollutant sources, sediment contami-
          nation, and biological  effects  to provide a complete database
          for development of the  comprehensive action program.

     The study area,  the approach  used to identify problem areas,  and  the
locations  of high priority  problem  sites are  described  in  the remainder
of this  introduction.

STUDY AREA

     The study area is  defined  as Elliott Bay east of a line drawn  between
West Point and Alki Point,  including the Duwamish River  from its mouth
to the  turning  basin located approximately 6 mi upstream.  The study area
drainage basin consists of about  26 square miles  of highly  developed land
in metropolitan  Seattle  (Figure 1).   Basin boundaries  are roughly  defined
by Beacon  Avenue on  the east side and 35th Avenue S.W.  on  the  west side.
The  basin  includes residential  areas  in the southern portions of the Queen
Anne and Magnolia neighborhoods,  and  most of West  Seattle;  the  industrial
areas along  the  Duwamish  Waterway; the Interstate 5  corridor from James
Street  to  about  S.  Dawson  Street;  and the downtown  business  district.
Public  access  points and recreational  areas are illustrated in Map 1 (Appendix
A).

     Locations of  storm drains, combined sewer overflow (CSO)  points,  and
other potential  sources of toxic contaminants are shown in  Map 2 (Appendix  A).
The  residential  areas are  generally served  by  partially separated storm
and sanitary systems.  Runoff from the  business district  is served entirely
by combined  sewers, and  is  transported to the West Point treatment plant
via METRO'S interceptor  system.  Runoff from Interstate  5 is collected
in two  large  storm  drains and discharged to the Duwamish Waterway at Slip  4
and Diagonal Way.  The remaining  industrial areas, excluding Harbor  Island,
are  served  by combined  sewers, and private  and  municipal  storm  drains.
Harbor  Island  has its own  storm drainage system which discharges  to  the
East and West Waterways.

APPROACH

     The primary kinds  of data  used  in the decision-making process  are
shown in  Table 1.   Contamination and effects data were integrated and evaluated
in a decision  framework based  on the  "preponderance-of-evidence" approach
to problem area evaluation  (Figure  2).  Study  areas that  exhibited high
values  of  environmental  indicators relative to a reference site received
a ranking of "high priority" for evaluation of pollutant sources and remedial
action.  The environmental indices are a ratio between the value  of variable
(e.g., concentration of PCB in sediments) at  a  site in the  study area  and
the  value  of  the same variable at  a reference  site (i.e., "clean" area
remote from urban centers).  Each ratio  is  called an Elevation Above Reference,

-------
Figure 1.  Study area drainage boundaries,

-------
              TABLE 1.  PRIMARY KINDS OF DATA USED IN PROBLEM
                 AREA IDENTIFICATION AND PRIORITY RANKING
General Category
                    Specific Indicator Variables
Pollutant source


Habitat condition

Indigenous organisms
Mass emissions


Sediment quality

Bioaccumulation
                         Benthic community
                          structure
Toxicity
Fish pathology



Acute lethal

Sublethal
0 Pollutant concentrations
• Discharge flow

0 Pollutant concentrations

0 Contaminant  concentrations
  in tissues of English sole
  and crabs
0 Total abundance
0 Species richness
0 Dominance
0 Amphipod abundance

0 Prevalence of  liver lesions
  in English sole and rock
  sole

0 Amphipod mortality

0 Oyster larvae abnormality

-------
  CONTAMINATION
     SEDIMENT
     FISH
     SHELLFISH
            BIOLOGICAL  EFFECTS
             SEDIMENT TOXICITY
             BENTHIC COMMUNITIES
             FISH DISEASE
             HUMAN HEALTH THREAT
                 (I)  MAGNITUDE OF INDICATORS
                 [T)  NUMBER OF INDICATORS
                       ACTION I  CRITERIA
                  EACH
                  AREA
               CLASSIFIED
                  AS:
HIGH PRIORITY
MEDIUM PRIORITY
LOW PRIORITY
NO IMMEDIATE ACTION
Figure  2.   Preponderance-of-evidence approach to evaluation of
            toxic contamination  problems.

-------
because  the value of  the  index  increases as the deviation  from reference
conditions increases.

     Contamination of sediments and biota  was evaluated by  examinating
the following chemical  concentrations:

     •    Low Molecular Weight Polynuclear Aromatic Hydrocarbons (LPAH):
          the sum of  light petroleum compounds  such as naphthalene,
          acenaphthalene, and fluorene

     •    High  Molecular Weight Polynuclear Aromatic Hydrocarbons
          (HPAH):  the  sum of heavy petroleum compounds or combustion
          products such  as  fluoranthene, pyrene, benzo(a)pyrene, and
          chrysene

     •    Polychlorinated Biphenyls (PCBs):  the  sum of  PCBs

     •    Copper  (Cu), Lead (Pb), and Zinc (Zn):   the  sum of selected
          metals

     •    Arsenic (As):  a toxic metal known to be  present in  emissions
          from the ASARCO smelter, in sandblasting material used  by
          shipyards,  and in  natural seawater.

The rationale for choosing these selected indicator variables  and supporting
data for the study area and  reference  areas  are  provided  in the  Initial
Data Summaries and Problem Identification report.

     Because available data  are limited, the  prioritization of specific
problem areas for this  Work  Plan  was based mainly  on  sediment chemistry
and  toxicity bioassays using amphipods and oyster larvae.  Elevation Above
Reference (EAR)  values  for these indicators are provided for  each priority
area  in  Appendix  B  of this report.   Given the  uncertainty associated with
the original  sample analyses  and pooling of data sets  from different investi-
gators, EAR values are  presented as ranges, for example:

     Chemical Concentrations

     t    Very high          >1,OOOX reference

     •    High               100-1,OOOX

     t    Moderate           10-100X

     •    Low                <10X

     •    Not significant     Below the maximum  concentration observed
                             in reference areas.

-------
          V:'''-"'
                                                                       SPOKANE STREET
                                                                            BRIDGE
Figure 3.   Classification of study  area
           segments in terms of priority
           for interim action.
HIGH PRIORITY — INTERIM ACTION
MODERATE PRIORITY — INTERIM ACTION
NO IMMEDIATE ACTION
INSUFFICIENT DATA

-------
REPORT ORGANIZATION

     The remainder  of this document  describes interim actions  to  be  taken
to control  the  input of contaminants  to Elliott Bay and the  lower  Duwamish
River.   Two  kinds of interim  actions are  addressed:  area-wide  actions
and site-specific actions.   Area-wide actions  generally  apply  to large
portions of the study  area, whereas site-specific actions are unique measures
taken (by a  regulatory agency or other  entity)  within each study area  segment.
Because many area-wide actions are regulatory programs that affect  specific
sites (e.g.,  discharge permitting programs),  area-wide actions are described
first.   For  a more complete  description of area-wide actions,  refer to
the Review  of Existing Plans and Activities.

     Site-specific  actions are  described  in the Site-Specific Work Plan
(Table 2).   The introduction to the  second  section describes how  interim
actions are  defined, and  the  steps  for  implementing them.  The Work Plan
contains an annotated  list  of actions  and  an  agenda for  implementation.
The  actions  are organized  according  to  study  area segment (see  Figure 3
above) and  appear  in approximate order  of  priority for interim action.

     Following the  Site-Specific Work  Plan  are several figures that  outline
the decision  framework for  controlling pollutant sources.   The  decision
framework  illustrates  the  regulatory and  management decisions that  occur
throughout  the source  control process.

     The appendices include additional  information which the reader may
find helpful:

     •    Appendix  A  contains two  maps  of  the study area.  The first
          map illustrates public access points and recreational  areas,
          and  the second  map shows contaminant sources and selected
          industry locations.

     •    Appendix  B  describes each  study  area segment  in terms  of
          existing environmental  conditions (based  on  recent data,
          1979-present) and potential sources of toxic contamination.

-------
          INTERIM WORK PLAN FOR ELLIOTT BAY TOXICS ACTION PROGRAM


AREA-WIDE  ACTIONS

     The following  programs and  plans are described  in  terms of actions
that can be  taken to identify or control  sources of toxic contamination.
Regulatory  measures in some areas would  be greatly facilitated  with better
information  about the extent of existing contamination, and/or  information
about  sources of toxicants.   For this  reason, ongoing or planned studies
(sampling  and  analysis) are considered  interim actions.

U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA)

     t    Superfund:  This  program provides  for  the identification,
          study, and  cleanup of dangerously contaminated sites.   Western
          Processing  in Kent  and the Harbor  Island  Superfund site
          may  be  contributing  toxic  contaminants  to  the  study area
          via  surface runoff or groundwater.  The Final  Remedial  Investi-
          gation  Data Report was  released for  Western  Processing in
          December,  1984.  A draft report  on the preliminary assessment
          of Harbor Island  was released in  June,  1985.  Superfund
          also provides for on-site testing, which may lead to  further
          source identification.  Section 104(e) of Superfund  legislation
          requires  private industry within designated areas to  release
          any  pertinent information, such as data on groundwater  testing
          or past spills.  Under a joint U.S. EPA/Washington Department
          of Ecology program,  preliminary  assessments  of potential
          hazardous waste  sites  are  being performed.  Several  such
          sites  are  in the study area.

     •    Elliott Bay Sampling and Analysis  Design:  This plan has
          two purposes:1)  to fill  in  data  gaps  needed to  better
          characterize existing problems, and 2) to obtain  data  needed
          to relate  contaminant  sources  to environmental problems.
          The sampling  and  analysis  was initiated in September,  1985
          as part of the Elliott Bay Toxics Action Program.   The final
          report  on  the results of the  field investigation is  scheduled
          for  late 1986.

WASHINGTON DEPARTMENT OF ECOLOGY (Ecology)

     t    National   Pollutant Discharge  Elimination System  (NPDES);
          Permits are generally  issued on a site-by-site  basis, and
          can  include more than one discharge or source of  pollutants.
          Permits for sewage treatment plants  extend  throughout the
          plant's service  area and include  combined sewer  overflows
          (CSOs).  Industrial permits can include  a storm drain  component
          (for  surface  runoff)  as  well as wastewater discharges.
          New  NPDES  regulations  require  land  users  in  certain land
          use  categories to submit data regarding surface water  runoff


                                   10

-------
         by  December,  1987.   Washington  Department of Ecology will
         review this information to assess the need  for issuing stormwater
         permits.

     •    Superfund:   The Washington Department of Ecology  is the
         lead  agency for the  Harbor Island  site.  A contractor has
         been  retained to start evaluating the  extent of the problem.
         Washington Department of Ecology reviewed  the initial assessment
         of  Harbor Island  (mid-1985) and will  make a decision  about
         future action.  Several action alternatives exist,  including
         1)  de-listing the area, 2) recommending  a sampling  and analysis
         plan,  or 3) proceeding with a remedial  investigation.

     •    Resource  Conservation  and Recovery  Act (RCRA):  This is
         a joint U.S. EPA/Washington Department of  Ecology program
         that  governs the generation, handling, and disposal  of hazardous
         wastes.  Spill prevention and containment measures, material
         handling requirements, and groundwater monitoring  can be
         required as part of a RCRA permit.   There are six RCRA permits
          (pending) in the study area.

     •     Sampling and  Analysis:   Under  various  Washington Department
         of  Ecology programs, sampling  and analysis will  provide
          additional information about existing conditions and possible
          sources of contamination in the  study area.   Specific  study
         designs are not yet available.

MUNICIPALITY  OF METROPOLITAN SEATTLE (METRO)

     •     Duwamish Industrial Non-Point Source Investigation:  Several
          source-control  actions are pending  as  a result of this program.
          Future investigations are  not  yet defined, but  in general,
         the program includes 1) visits  to 20 additional   industrial
         and commercial  sites, 2)  follow-up monitoring  and control
         measures at 10  previously  identified sites, 3) sediment
         and water analyses for selected  heavy metals and toxic  organic
          compounds at 4 storm  drains, and 4) follow-up  sampling to
         determine the effectiveness of control  measures.

     •     Industrial Pretreatment:   METRO  grants  permits for industries
         discharging into its collection system.  METRO and its component
         agencies are identifying new businesses  and evaluating their
         need  for pretreatment.

     •    CSO Planning:   METRO has  begun  CSO planning as  an integral
         part  of facilities  planning.  New  treatment  plant permits
         will  include  revised conditions  for CSOs (schedules of com-
         pliance, monitoring requirements).   Short-term actions include
         the ongoing effort of improving CATAD to maximize in-line
          storage (thus reduce  CSOs) and  to  prioritize the overflow
          sequence.
                                    11

-------
    •    Facil ities Planning:   Facilities planning includes  upgrading
         the West  Point  plant to secondary treatment  capacity and
         determining the fate  of the Alki  plant.   A draft EIS was
         released in July,  1985.

    •    Renton Effluent Transfer  System:  METRO plans  to divert
         Renton treatment plant  effluent  from its current  discharge
         point  in  the Duwamish  River  to a site offshore from Duwamish
         Head in Elliott  Bay.  METRO  recognized the  need  to divert
         the Renton effluent from  the  river  in the Renton 201  Wastewater
         Plan.   In March,  1982,  Washington Department of  Ecology
         issued an  order and compliance schedule to  relocate the
         discharge.   METRO is now revising facility  plans for the
         diversion pro-ject.

    •    Household Hazardous Waste Project:   This is a public education
         program aimed at reducing the  disposal of household  toxic
         materials to the sewer  system.

    •    Sampling  and Analysis:   Current  knowledge about  toxicant
         sources and existing contamination may be augmented by the
         sampling and analysis components of  some of METRO'S  programs.
         Specifically, sampling and analysis of storm drains  is planned
         as  part of the continued  Duwamish  Industrial  Non-Point  Source
          Investigation (1985-1986).   Sampling and analysis of selected
         CSOs will be required as  part of METRO'S new NPDES  facilities
         permits.  The baseline study  for the  Renton outfall  relocation
         to  Duwamish head will  include subtidal ,  intertidal, and
         water  column monitoring.

U.S. ARMY CORPS  OF  ENGINEERS (COE)

     •     Sampling and Analysis:  The  COE may contribute valuable
         source and contamination  information as a  result of various
         dredging projects.  As  part  of  the  COE "widening and deepening"
         project,  sediment in  the East and West  Waterways and the
         lower Duwamish  River  up to  the  1st Avenue South Bridge will
         be  sampled.  If  the  project is authorized and proceeds,
         some contaminated sediment will  be  removed.  The COE also
         has a major role  in the "Puget  Sound  Dredged Disposal  Analysis"
          (see below,  Interagency Coordination).  As a result of this
         project, the future of  the Fourmile  Rock  Disposal  Site will
         be  determined.   At  this time, it  is unclear whether  or not
         the COE will be sampling  the  sediments in this area.

CITY OF SEATTLE

    •    CSO Planning:  With  direction from  Washington Department
         of  Ecology,  the City of  Seattle is continuing efforts to
         reduce the  frequency  and severity of CSOs.  The  city's CSO
         planning will depend in large  part on  METRO'S planning efforts,
         as  the two  systems  are  closely related.  The city, however,
         has taken several actions to  increase storage and to separate
         or  partially separate stormwater  from sewer lines.

                                   12

-------
    •    Shoreline Master Program  and  Grading and  Drainage Code_s_;
         Recent amendments to the Program and Codes  include considerations
         for  the  storage  and handling of  hazardous or dangerous
         materials.  It should be noted, however,  that these regulations
         are not retroactive and only apply  to future  construction.

    •    Water  Supply  Corrosion Control  Program:   The City of Seattle
         treats its water  with hardeners to  reduce the leaching of
         zinc, copper,  and iron from distribution  pipes, thus reducing
         the input of these metals to receiving  waters.

INTERAGENCY COORDINATION

    •    Elliott  Bay Toxics  Action Program:   As  part of the planning
         process,  U.S.  EPA has established  an interagency workgroup
         composed  of representatives from U.S. EPA,  Washington Department
         of Ecology, Washington Department of  Natural  Resources (DNR),
         Municipality  of Metropolitan  Seattle  (METRO), U.S.  Army
         Corps of  Engineers  (COE), Port of Seattle, City of Seattle,
         King  County,  National Oceanic and  Atmospheric Administration
         (NOAA), and the Washington Department-of  Social  and Health
         Services (DSHS).  This work group  provides  a communication
         network whereby  involved agencies  can  reduce duplication
         of  effort  and bridge institutional  and regulatory gaps.
         Work group representatives review the approach, progress,
         and  results   of  the Elliott  Bay Action Program project.
         Work  group sessions were  instrumental  in  developing  the
         interim actions specified in this report.   One obvious result
         from  increased  interagency  coordination will  be  seen  in
         the  Elliott Bay Sampling and Analysis  Design, which combines
         the resources  of several agencies to  meet  a common goal.

    •    Puget  Sound Dredged Disposal  Analysis:   A  3-yr cooperative
         project by  DNR,  COE, U.S.  EPA, and Washington Department
         of Ecology.  The objectives are to identify  acceptable sites
         for open-water unconfined  disposal of  dredged  material,
         to  define  chemical  and biological  evaluation procedures
         for assessing disposal alternatives, and to  formulate management
         plans  for disposal  sites.  The draft  EIS for Phase I, which
         includes  Elliott Bay  and the Fourmile Rock  Disposal Site,
         is scheduled to be  available by December,  1986.

    •    CSO  Planning:  Strategies for reducing  City of Seattle CSOs
         will be based  upon  METRO planning efforts for their CSOs.
         METRO  intends to set priorities  for reducing CSOs, partly
         in response to input  from U.S. EPA  and  Washington Department
         of Ecology (based on the  results of  the Elliott Bay Toxics
         Action Program findings).  A draft  report on alternatives
         for reducing  major CSOs in the project area  will be released
         in November, 1985.
                                   13

-------
•    Nonpoint  Sources:  Increased coordination between Washington
     Department of Ecology,  U.S. EPA, METRO,  King County, and
     the City  of  Seattle would  facilitate control  of  toxicant
     loading from nonpoint surface  runoff.  For example, the
     Seattle Department of Construction  and Land Use (Shoreline
     Management Program, Grading and  Drainage Codes) will  interact
     closely  with  Washington Department of  Ecology's permit branch
     to coordinate  on-site control  (storage, handling,  etc.)
     of toxic  substances.   A consistent  strategy for control
     of stormwater runoff will  be developed.

•    Puget Sound  Water Quality Management  Plan:  The Puget Sound
     Water Quality Authority (PSWQA)  is directed by the Washington
     State Legislature to prepare  a comprehensive, region-wide
     plan  for managing water quality.   At the  time of this  writing,
     a  focus  for this  plan  has not  been  developed, but  it  is
     expected to include toxic contamination.  Current legislation
     calls for  preparation of the plan by January, 1987.

•    Toxic Spills:   The Coast  Guard, U.S.  EPA, METRO, municipal
     fire departments,  the Port of Seattle,  the  City of Seattle,
     King County,  and Washington Department  of Ecology will  continue
     to develop procedures for  systematic cooperation  during
     emergency  cleanup  operations.
                              14

-------
SITE-SPECIFIC  WORK  PLAN

     The Elliott  Bay Action Team  was created  by Washington Department of
Ecology, U.S.  EPA,  and METRO to implement the  Interim Work Plan.  The multi-
disciplinary  team consists  of professionals who will be responsible for
on-site investigations, permit-writing, and permit  inspections.  The  Action
Team will  also be responsible for helping  personnel from other agencies
with cleanup and sampling activities.  Two Washington Department of  Ecology
positions  are funded directly by Washington Department of Ecology and two
are funded  (for a period of at least 1 year) by METRO.  Additional personnel
from METRO  and the  City of Seattle will participate  in  source investigations
and cleanup.  The Action Team will  coordinate the team's  activities  with
U.S. EPA contractors and  agencies responsible for ongoing investigations
in Elliott   Bay and the  Duwamish River.   The Action  Team is expected  to
be  fully operational  in October, 1985, and its agenda  through 1987 includes
27 site investigations.

     The Action Team  provides the regulatory link between problem  identification
and source  control.   The responsibility  of the  Action Team is to  control
or  eliminate   sources of  toxic contaminants in a timely  manner, through
negotiations with responsible parties, permitting mechanisms, or compliance
orders.

     Table  2  presents the Work  Plan for the  Elliott Bay Action Team and
associated  agencies for late 1985, 1986,  and 1987.  The study area segments
refer  to  priority areas  defined in the Initial Data  Summaries and Problem
Identification report.   Refer to  Figure 3 above for a map of the  study
area and  locations  of  these segments.   The personnel column in Table 2
indicates the  agency  and program (where relevant) responsible for overseeing
or  carrying out the  actions.   The last  column refers to the quarter, or
month and year, in which  implementation will  begin.  This Work  Plan  is
the  product of the  coordinated,  intensive  efforts  of many organizations
and individuals (see  Acknowledgements at  front of this  report).  The actions
noted  in  Table 2 were  agreed  upon after a great deal of discussion among,
and planning by, members of the Interagency Work  Group  and Citizens Advisory
Committee.  Appendix A contains a summary of environmental conditions and
lists potential sources  of contaminants for  each priority segment.   The
sources identified  are  probably not the only sources of contaminants, but
they are subject  to interim actions pending further source  investigations.
                                    15

-------
                                        TABLE 2.  SITE  SPECIFIC WORK PLAN  FOR ELLIOTT BAY INTERIM ACTION PROGRAM
                                                                 NORTH HARBOR  ISLAND
                                                                     SEGMENT 48
            Source
                                 Action
          Personnel
  Implementation
     Dates
Waste disposal area
Mobil 011
Todd Shipyards
CSO/SO 077
Non-specified
Perform search of ownership and business-license records to determine
Identities of former owners.  Classify amounts and types of previous
on-site wastes.  Determine disposal practices of former occupants.

Perform NPDES Inspection.

Sample sediment directly under discharge of oil separator.

Review number, severity, and recovery methods of historic spills at site.

Review SPCC plans and Implementation.

Perform groundwater Investigation.


Inspect Todd Shipyard.  Interview Todd personnel.  Document historic and
present disposal practices of sandblast waste, paint and paint overspray,
bilge water and stack cleaning wastes, waste oil, and solvents.  Document
previous occupants on site.  Review SPCC plan and Its Implementation.

Review present NPDES permit and modify 1f necessary based on FY 86
U.S. EPA samples.

Sample storm drains and perform regular maintenance If necessary - and
probably corrective measures.

Investigate groundwater contamination (waste paint and oil storage area
was unpaved until 1984).

Interview prior owner of part of site (I.e., Mobil 011) and Its employees
for Information on former waste handling and disposal practices.

Characterize sediment contamination, toxldty, Infauna, b1oaccumulat1on,
and liver pathology 1n Immediate vicinity of CSO/SD.  Analyze for
priority pollutants 1n CSO/SD sediments and relate to environmental
conditions.

Complete Initial assessment of Harbor Island toxic contamination and
sources by June, 1985.  Issue sampling and analysis plan, Including
Identification of groundwater sources.  Also, Superfund legislation
requires Industries to disclose Information on toxic spills, hazardous
waste, and groundwater testing.

U.S. Status and Trends Program:  Conduct annual long-term monitoring of
sediment contamination, toxldty, and fish pathology at station north
of Harbor Island.
City  of Seattle



Ecology

Ecology/USCG

Ecology

Ecology

H.I.  Superfund
U.S.  EPA/Ecology

Ecology




Ecology


Todd
Todd/H.I. Superfund
U.S. EPA/Ecology

METRO/Ecology
Mobil 011

U.S. EPA
H.I. Superfund
U.S. EPA/Ecology
                                                                                                              NOAA
 10-12/85



 1-3/86

 1-3/86

 1-3/86

 7-9/86

 To be scheduled


 To be scheduled




 4-6/87


 10-12/85


 To be scheduled


 1-3/86


9/85 - ongoing




Ongoing





Ongoing

-------
TABLE 2.  (Continued)


Source
Seattle Iron and Metal


Oil tank farms (Texaco, Shell,
GATX, Golden Penn, Chevron)

A
j



Major storm drains

Major CSOs


Crowley Environmental Services
Terminal 30 contaminated
sediments
1 EAST WATERWAY
| SEGMENTS 4A/5A/5B

Action
Monitor and verify removal of copper wash effluent from Hanford St.
storm drain to sanitary sewer with adequate pretreatment.
Sample Hanford St. storm drain for metals and organic toxicants,
prioritize relative to other sources, and relate to waterway contamina-
tion and bloeffects.
Determine sources of PCB-laden transformers, chemical content of
transformers from each owner, and treatment practices of transformer
owners. Submit report to Washington Department of Ecology.
Investigate historic spills for on-site quantity and recovery. Include
sites which have been redeveloped Into Port container terminals, e.g.,
Shell. Check for on-site wells (7,000 gal at Chevron).
Perform NPDES inspections for disposal of oil separator wastewater.
Inspect Texaco truck wash discharge to check for detergent Intruding
Into separator.
Review and Implement SPCC plans.
Sample river sediment below discharge of NPDES outfalls (except Chevron).
Review Chevron stormwater permit and require stricter controls 1f
necessary.
Sample storm drain sediment at critical junctures of the major storm
drains that discharge into the East Waterway(Hanford St., Hinds St.,
Spokane St., Florida St.). Relate sources to waterway contamination and
bloeffects. Identify ultimate sources and develop control measures.
Continue mapping storm drains at Terminals 19, 102, 30, 37, and 25
Implement CSO sampling concurrently with a key manhole sampling study to
determine wastewater sources. Priority CSOs include Lander and Hanford.
Analyze priority pollutants in major CSO sediments and relate to
waterway contamination and bloeffects.
Divert upper Rainier Valley/Capitol Hill storm water from sanitary
system by constructing Hanford St. tunnel.
Issue RCRA permit, Including consideration of groundwater monitoring.
Remove 50,000-90,000 cubic yards of contaminated sediments by dredging.



Personnel
METRO/Ecology
U.S. EPA
City Light
Ecology
Ecology
Ecology
U.S. EPA
USCG/Ecology
Ecology

U.S. EPA, METRO,
Ecology, City of
Seattle
Port of Seattle
METRO
U.S. EPA
METRO,
City of Seattle
U.S. EPA
Port of Seattle



Implementation
Dates
7/85
9/85-ongoing
Begin 1/86
1-3/86
1-3/86
1-3/86
1-3/86
1-3/86
12/85

9/85-ongoing
Ongoing
9/85 to 1987
9/85 - ongoing
9/85 to 1989
To be scheduled
1985-1986


-------
  TABLE  2.   (Continued)
                                                                         EAST WATERWAY
                                                                       SEGMENTS 4A/5A/5B
                                                                                                                                                Implementation
               Source                                                 Action                                               Personnel                 Dates

  Non-specified                     Superfund:   Complete Initial  assessment of Harbor Island toxic contamlna-    Ecology                       Ongoing
                                    tlon  and  sources  by June,  1985.   Issue sampling and  analysis  plan,
                                    Including Identification of groundwater sources.  Also,  Superfund
                                    legislation  requires industries  to  disclose Information  on  toxic spills,
                                    hazardous waste,  and groundwater testing.

                                    Implement Elliott Bay Sampling and  Analysis Design to characterize  entire    U.S.  EPA                      9/85-ongo1ng
                                    area  In terms  of  sediment  contamination, toxicity, and bloeffects.

                                    Dredging:  Develop plans for  removal  of contaminated sediments from          COE                           1985
                                    portions  of East  Waterway  as  part of  Widening and Deepening Project.
                                    Conduct sampling  and analysis of deep sediment cores.
CO

-------
TABLE 2.   (Continued)

Source
SeaFab Metals
WEST WA
SEGMENT
Action
Investigate groundwater disposal practices.
TERWAY
S 6A/6B
Personnel
Ecology/RCRA
Proceed with RCRA closure plan for SeaFab Metals. Ecology/RCRA
Verify Lander St. cleanup, resample storm drain sediment. U.S. EPA
Pioneer Sand and Gravel
Lockheed Shipyards 112
Perform site Inspection.
Ecology
Inspect Lockheed Shipyards. Interview Lockheed personnel and document Ecology

Implementation
Dates
4-6/86
4-6/86
9/85 - ongoing
4-6/87
10-12/85
 Florida  St.  storm drain
 (Purdy Lot,  Wyckoff)
Tank  farms  (Texaco,  Shell,
Arco)
Seattle Iron and Metal
Waste Disposal Areas
West Seattle Landfill
historic and present disposal practices of sandblast waste,  paint and
paint overspray, bilge water and stack cleaning wastes, waste oil, and
solvents.  Document previous occupants of site.
Review present NPDES permit and modify 1f necessary based on results of
U.S. EPA Elliott Bay Sampling and Analysis.
Sample storm drains and perform regular maintenance and corrective
measures 1f necessary.
Investigate groundwater contamination.
Review SPCC plan and Its Implementation.
Clean out sediments contaminated with PCB, PCP, PAH, copper, and arsenic.

Control source of PCBs at head of storm drain.
Investigate historic spills for on-s1te quantity recovery (e.g., check
for on-s1te wells).  Include sites that have been redeveloped Into Port
container terminals.
Perform NPDES Inspections for disposal of oil separator wastewater.
Inspect Texaco truck wash discharge to determine If discharge 1s
Intruding Into oil/water separator.
Review SPCC plans and Implement them.
Sample river sediment below discharge of NPDES outfalls.
Investigate groundwater disposal practices.
Investigate groundwater contamination.
Investigate groundwater contamination.
Ecology

Lockheed
Lockheed Superfund
U.S. EPA
Ecology, METRO, City,
Wyckoff, Purdy
U.S. EPA TOSCA
Ecology

Ecology
Ecology

Ecology
USCG/Ecology
Ecology/RCRA
H.I. Superfund
U.S. EPA/Ecology
H.I. Superfund, Sea-King
Co. Health Dept., Ecology,
U.S. EPA Emergency Response
4-6/87

10-12/85

To be scheduled
To be scheduled
7/85 (completed)

10/85
1-3/86

1-3/86
1-3/86

1-3/86
1-3/86
4-6/86
4-6/87

Ongoing

-------
TABLE 2.  (Continued)

Source
Bethlehem Steel liquid and
slag waste disposal area
Small storm drains discharging
Into West Waterway

Mono Roofing
Fischer Mills
Shell
Chelan St. CSO
Other CSOs
Non-specified


WEST WATERWAY
SEGMENTS 6A/6B
Action
Continue RCRA closure proceedings. Investigate drainage history of
Longfellow Creek.
Sample small drains (Florida St. /Harbor Island, Spokane St. /Harbor
Island) to determine 1f they are contributing contaminated sediment
and water to the river.
Continue mapping of storm drains on Port properties (especially
Terminal 5).
Resolve issue of dumping solvents and roofing wastes into Spokane St.
storm drain.
Review cooling-water NPDES permit.
Review stormwater permit, apply stricter controls if necessary.
Review West Point treatment plant permit with monitoring requirements
for discharge.
CSO Planning: Construction was completed 1n 1984 to allow Longfellow
Creek system to contain runoff from up to a 10-yr storm without CSO
events. Begin planning to reduce or eliminate other CSOs.
Superfund: Complete Initial assessment of Harbor Island toxic contami-
nation and sources by June, 1985. Issue sampling and analysis plan,
including Identification of groundwater sources. Also, Superfund
legislation requires Industries to disclose information on toxic spills,
hazardous waste, and groundwater testing.
Implement Elliott Bay Sampling and Analysis Design to characterize
area further, Including source evaluation.
Dredging: Develop plans for removal of contaminated sediments as part
of Widening and Deepening Project. Conduct sampling and analysis of
deep sediment cores.

Personnel
Ecology /RCRA
METRO, City of Seattle,
Ecology, U.S. EPA
Port of Seattle
Ecology, METRO
Ecology
Ecology
Ecology, METRO
City of Seattle
H.I. Superfund
U.S. EPA/Ecology
U.S. EPA
COE

Implementation
Dates
7-9/86
9/85-ongoing
1985
7/85-6/86
1985
1985
1985
Ongoing
Ongoing
9/85-ongo1ng
1985

-------
                                                                     SOUTH  HARBOR  ISLAND
                                                                          SEGMENT  7A
              Source
                                                                    Action
                                                                                       Personnel
                                Implementation
                                    Dates
  Diagonal Way storm drain
  Ash Grove Cement
  Diagonal Way CSO
  Ideal Cement
r\>
•-Port of Seattle T-105

  Janco-Unlted,  Inc.
  Port of Seattle storm drains
  Hanford 1 CSO
  Non-Specified
Resample Diagonal Way storm drain sediments to prioritize relative to
other sources and relate to Waterway contamination and bloeffects.
Implement cleanup of pole treatment yard  (stabilize site).
Monitor storm drain discharge.
Determine 1f unllned surge pond on rlverbank  1s a pollutant source.
Perform Washington Department of Ecology  state discharge permit
Inspection.
Document historical storage methods and use of ASARCO slag, flyash, and
coal.
Implement CSO sampling concurrently with  a key manhole sampling study to
determine wastewater sources.
Divert upper Rainier Valley/Capitol H111  storm water from sanitary system
by constructing Hanford St. tunnel.
Conduct a permit Inspection.
Conduct grountjwater study, Investigate upland disposal of contaminated
sediments.
Proceed with criminal Investigation.
Continue mapping storm drains on Port properties (especially Terminal
102 and shorelines south to Diagonal Way).
Review West Point Treatment Plant NPDES permit with monitoring require-
ments for discharge and receiving environment.
CSO Planning:  Evaluate alternatives for  reducing CSOs.  Monitor
Hanford 1 CSO discharges.
Superfund:  Complete initial assessment of Harbor Island toxic contamina-
tion and sources by June, 1985.  Issue sampling and analysis plan,
Including Identification of groundwater sources.  Also, Superfund legis-
lation requires industries to disclose information on toxic spills,
hazardous waste, and groundwater testing.
Implement Elliott Bay Sampling and Analysis Design to further
characterize this area.
Dredging:  Develop plans for removal of contaminated sediments as part
of Widening and Deepening Project.  Conduct sampling and analysis of
deep sediment cores.
National Cancer Institute Study:  Conduct sampling in June, 1985, to
characterize sediment contamination, chemistry of English sole muscle
and bile, and English sole histopathology.
 U.S. EPA
9/85-ongo1ng
 Seattle  City  Light,  Ecology    10/85
 METRO                          1985
 Ecology                        1-3/86
 Ecology                        1-3/86
Ecology
METRO
METRO, City of Seattle

Ecology
Port of Seattle

U.S. EPA
Port of Seattle
Ecology
METRO
H.I. Superfund
U.S. EPA/Ecology
                                                                                                                U.S. EPA

                                                                                                                COE

                                                                                                                NOAA
1-3/86
9/85 to 1987
9/85 to 1989
1-3/86
Ongoing (ground-
water study
complete)
To be scheduled
1985
1985
To be scheduled
Ongoing
                              9/85-ongo1ng
                              1985

                              Ongoing

-------
  TABLE  2.   (Continued)
                                                                      DENNY WAY CSO
                                                                       SEGMENT 2A
                                                                                                                                                Implementation
              Source                                                Action                                               Personnel                 Dates

  Denny Way CSO                    NPDES:  Renew METRO West Point Treatment Plant permit and require            Ecology                       To be scheduled
                                   monitoring of Denny Way CSO discharges.

                                   CSO Planning:  Evaluate alternatives for reducing CSOs.  Assess              METRO                         Ongoing
                                   benefits and Impacts of onslte storage or treatment and transfer of                                        (Report 11/85)
                                   Denny Way CSO load to subtldal dlffuser.

                                   Implement 1985 Elliott Bay Sampling and Analysis Design to test for          U.S. EPA                      9/85-Ongoing
                                   contamination and toxlcity of Intertldal sediments.  Analyze priority
                                   pollutants 1n CSO sediments to prioritize Denny Way CSO relative to
                                   other sources.

                                   National Cancer Institute Study:  Conduct sampling 1n June, 1985, to         NOAA                          Ongoing
                                   characterize sediment contamination, chemistry of English sole muscle
                                   and bile, and English sole hlstopathology.
ro
ro

-------
  TABLE 2.  (Continued)
                                                                    SEATTLE  WATERFRONT
                                                                        SEGMENT 3C
                                                                                                                                               Implementation
              Source                                                Action                                               Personnel                 Dates

  CSOs                             CSO planning:   Begin planning to reduce  or  eliminate  Number 071 CSO          City of Seattle               Ongoing
                                   and Number 164 CSO.

  CSOs and historical sewage       Characterize sediment contamination,  toxldty,  benthlc  Infauna, bloac-       U.S. EPA                      9/85-Ongo1ng
  dlshcarge                        cumulation, and English sole  liver  pathology  off  Piers  53/54.
isi

-------
  TABLE  2.   (Continued)

Source
Ideal Basic Industries
Non-specified
1 SLIP 1
1 SEGMENT 7B
Action Personnel
NPDES: Issue permit and require stricter controls 1f necessary. Ecology
Characterize sediment contamination, toxldty, and benthlc Infauna at U.S. EPA

Implementation
Dates
7/85-6/86
9/85-Ongolng
ro
-P.
                                    head  of Slip 1  to prioritize area relative to other potential  problem
                                    areas.


                                    Require local  Industries to supply data on storm drainage.                    Ecology                       To be scheduled

-------
  TABLE 2.   (Continued)
              Source
                                                                           SLIP 2
                                                                         SEGMENT 8A
                                 Action
         Personnel
 Implementation
     Dates
  Michigan St. CSO



  Chempro
  Historic dumps/waste
  disposal areas
  Non-specified
Implement CSO sampling concurrently with a key manhole sampling study
to determine wastewater sources.  Evaluate alternatives to reduce or
eliminate Michigan CSO.

Determine 1f groundwater 1s contributing to contaminated sediment 1n
Slip 2.

Perform Inspection and Issue status report.

Identify potential contaminated areas.  Research ownership and business
license records to obtain names of previous owners and site-use Infor-
mation.

Characterize sediment contamination and toxiclty at head of Slip 2 to
prioritize area relative to other potential problem areas.
METRO



METRO/Ecology


RCRA

City of Seattle



U.S. EPA
9/85 to 1987



1-3/86


To be scheduled

To be scheduled



9/85-Ongoing
en

-------
TABLE 2.  (Continued)
                                                                        SLIP 3
                                                                      SEGMENT 88
            Source
                                 Action
         Personnel
                                                                                                            Implementation
                                                                                                                Dates
Marine Power and Equipment
Fox Street storm drain
Possible groundwater contami-
nation from Chempro and his-
toric site

Michigan St. CSO
Inspect MP&E.  Interview personnel.  Document historic and present dis-
posal practices of sandblast waste, paint and paint overspray, bilge
water and stack cleaning wastes, waste oil and solvents.  Determine
previous occupant of site.

Review NPDES permit.


Proceed with Issuance of Ecology fine and U.S. EPA criminal  Investi-
gation.

Map and identify storm drains.

Identify sources, resample storm drain sediment.


Remove sediment from storm drain.
Determine 1f groundwater is contributing to contaminated sediment 1n
Slip 3.
Implement CSO sampling concurrently with a key manhole sampling study
to determine wastewater sources.

CSO Planning:  Evaluate alternatives to reduce or eliminate Michigan CSO.

NPDES:   Renew permit for West Point treatment plant and require METRO
to monitor CSO to determine degree of Influence on conditions 1n Slip 3.
Ecology




Ecology


U.S. EPA


City of Seattle

U.S. EPA, METRO/Ecology
City of Seattle

METRO/Ecology
City of Seattle

U.S. EPA/CIO WDOE



METRO


METRO

Ecology
10-12/85
                                                                                                                                            Draft 1/86
                                                                                                                                            Final 6/86

                                                                                                                                            To be scheduled
9/85

9/85-ongolng


To be scheduled


To be scheduled



9/85 to 1987


Ongoing

To be scheduled
Non-specified
Characterize sediment contamination and toxldty at head of Slip 3.
U.S. EPA
9/85-Ongo1ng

-------
  TABLE 2.  (Continued)
              Source
                                                                          SLIP 4
                                                                        SEGMENT 80
                                                                    Action
                                                                                      Personnel
                               Implementation
                                   Dates
  Georgetown Flume


  Storm drains, CSOs
Remove flume sediments and clean up upland site.
Characterize priority pollutant concentrations in drain  and CSO  sedi-
ments and relate to sediment contamination and toxidty  at head  of Slip.
Seattle City Light,
Ecology

U.S. EPA
10/85
9/85-Ongoing
ro

-------
  TABLE 2.  (Continued)
                                                               FOURMILE ROCK DISPOSAL  SITE
                                                                      SEGMENT  IDA
              Source
                                 Action
         Personnel
 Implementation
     Dates
  Four-mile Rock Disposal Site
Puget Sound Dredged Disposal Analysis:  Investigate suitability of Four-
mile Rock Disposal Site for future dredged material disposal.  If site
Is selected for further use, develop final criteria for disposal and a
management plan.

Disposal Criteria:  Issue Interim criteria for material to be disposed
at this site before Puget Sound Dredged Disposal Analysis 1s completed.
Proposed Interim criteria were Issued April 7, 1985.

Implement Elliott Bay Sampling and Analysis Design to characterize
contamination and effects at 30 ft depths Inshore of the designated
disposal site.

Analyze toxic contaminant levels 1n samples of clams and sediments from
an Intertldal site on Magnolia Beach.
COE/DNR, EPA/Ecology
                                                                                                                U.S. EPA
                                                                                                                U.S. EPA/COE, DSHS
                                                                                                                METRO
1985
                              4/85
                              10/85 to 3/86
                              8-10/85
r\>
ca

-------
  TABLE 2.   (Continued)

Source
Sunset Demolition
Ma larky Asphalt
Duwamlsh Shipyard
Monsanto
Whitney Fldalgo
Lone Star
Northwest Glass
Time O.C.
Seattle Rendering
Shell 011
| ADDITIONAL ACTIONS IN STUDY AREA |
Action
Perform site Inspections.
Inspect for PCBs and zinc.
Perform Inspections and draft NPDES permits.
Perform Inspections and draft NPDES permits.
Perform Inspections and draft NPDES permits.
Perform Inspections and draft NPDES permits.
Perform Inspections and draft NPDES permits.
Perform Inspections and draft NPDES permits.
Perform Inspections and draft NPDES permits.
Perform Inspections and draft NPDES permits.

Personnel
Lang Co., BALD, WDOE,
Sea-King County Health
Ecology
Ecology
Ecology
Ecology
Ecology
Ecology
Ecology
Ecology
Ecology

Implementation
Dates
7-9/85
7-9/85
7/85-6/86
7/85-6/86
7/85-6/86
7/85-6/86
7/85-6/86
7/85-6/86
7/85-6/86
7/85-6/86
ro
vo

-------
DECISION FRAMEWORK  FOR CONTROLLING POLLUTANT SOURCES

     Pollutant  sources are controlled via several  regulatory and management
processes.   The  avenue for control depends on many  factors, one of which
is the  nature of  the source.  Direct discharges and  illegal dumping, for
example, are controlled differently.   This section outlines the principal
strategies  for source control and  the  decision-making steps inherent in
each.

     There  are  three principal stages in the process of contaminant source
control:

     •    Characterization of  direct discharges

     •    Characterization of  ultimate sources

     •    Source control  and cleanup.

Figures 4-7 illustrate  the major  steps taken by  regulatory agencies to
characterize and control sources of toxicants from drainage systems  to
the  Elliott Bay/lower Duwamish River  area.  For a single drainage system
(e.g., storm drain  and its upstream sources), the entire process of problem
identification and  source control is anticipated  to take 1-5 yr.  The actual
time spent depends  on many variables, including 1)  the complexity of the
drainage system, 2) the nature and extent of contamination, 3) the feasibility
of controlling the  identified  sources,  and 4) the  nature  of enforcement
and  regulatory action.

     The  first  stage -  characterization of direct  sources, such as drains
discharging directly to waterways - involves the  identification of problem
storm  drains and  problem  contaminants.  This is  accomplished primarily
by analyzing storm  drain  sediments collected from  drainage  conduits close
to the point of discharge into the waterway.

     In the second  stage, the  highest priority drains are further investigated
to determine the ultimate sources of the contaminants.   Drainage system
mapping and additional  sampling may be required to identify and rank the
ultimate sources of contaminants.   Additional sampling  may be required
in several  instances, for  example when data about  existing conditions are
not adequate  to identify ultimate sources or when legally defensible information
is needed for a criminal  investigation.  Once ultimate sources are identified,
responsible parties  may be required to perform effluent analyses and estimate
loading.

     The third  stage of regulatory activity involves actual cleanup and
control  of sources.  Cleanup and control  strategies  vary  widely depending
on the nature of the source.   Figure 5 presents procedures related to identified
or point sources.   If  a discharge permit is  required, the source can be
controlled  by  1)  pretreatment, 2)  discharge to a sanitary sewer, or 3)
installation of a best management practice  (BMP).   If  a  discharge permit
is not required, the responsible party may be called  on  to halt its discharge.
                                    30

-------
In either  case,  the  discharger may have to assume costs  related to sampling
and site or sediment  cleanup.

     Nonpoint  or categorical  sources (Figure 6), such  as  direct runoff
from urban  areas, are predominantly controlled by designing and  implementing
BMPs.   BMPs  are usually  designed for  categories  of  sources (e.g., site
runoff from oil  tank  farms or city streets).

     For illegal dumping  (Figure 7), criminal investigation and enforcement
depend heavily  on apprehending the violator in  the act.    Until a  violator
is identified,  regulatory  activity involves primarily monitoring or "staking
out" an area  where  illegal dumping is suspected.
                                    31

-------
     Stage of
     Process
                               Technical Decision/Action
                                                                     Regulatory Decision/Action
                                                                                                                  Agency/Program
characterization
of direct      <
discharges
                           (locate and nap direct Inputs (drains) \
                             of pollutants to waterway          }

                            (evaluate existing daU for each drain)


                                (define problem chemicals)
                                                                      decision feedback loop
' noV—|1s drain a proble
                       (document decision)
                                               f( require further sampling )


                                      [noV-hs sampling plan part of EBAP?)—(yes)
                                      /analyze sediments  \     /proceed according \
                                     I In drain near d1s- \    I to EBAP sampling   I
                                     1 charge point and   I    \plan design	I
                                      Vevaluate results   /            I
                                 (prioritize drains for con- \
                                 slderatlon of upstream     J
                                 sources	I
                            c
  nap drainage system:  contrlbutarles
  present and historical Industrial/
  connerclal activities, etc.
                                                   /Identify responsible
                                                   (  parties to recover
                                                   Vcosts of sampling

characterization
of ultimate
sources
 source control
 and cleanup
1 N,
(
no
prioritize Identifiable sources ^ J notify aooroorlate Dirties
of problem chemicals
1
-J1s further sampling needed?
/ '{ of potential hazard


                                         (yti)
                                                                   decision feedback loop

(

1 i
design sampling plan and
QVQC to further Identify
sources


M Identify responsible parties, require '
analysis of stormwater/CSO discharges
and estimate loading for problem chem-
icals
i
                             (prioritize sources based on newly
                             acquired Information
                               proceed with control/cleanup\
                               action                      I
                                                 [sufficient Information?]—^no;


                                                         (yes)

1
Problem
Drains
See Figure 5


1
Categorical
Sources
See Figure 6


Illegal
Dumping
See Figure 7
                                                                                    EPVEBAP, (Ecology,
                                                                                    METRO. CITY)
                                                                                                               EPVEBAP. KDOE
                                                                                                                EPVEBAP.  also METRO,
                                                                                                                CITY, Ecology, others
                                                                                    EPA/EBAP, Ecology/task
                                                                                    force, METRO/DNPSI, CITY
                                                                                    HETRO/lndustrlal  waste.
                                                                                    facilities planning,
                                                                                    C1TY/DUU. comnunHy
                                                                                    development, licenses
                                                                                    «nd consumer affairs

                                                                                    EPVEBAP
                                                                                                                EPVEBAP
                                                                                                                EPVEBAP,  also METRO,
                                                                                                                Ecology, CITY
                                                                                    EPVEBAP
                                                                                                                EPVEBAP
                   Regulatory actions Include: 1) notification of pernlt compliance violation,
                   2] administrative order (e.g., to cease discharge, to cleanup stte).
                   3) permit Issuance or modification, and 4) Issuance of penalty
                  ' EPA
                   Ecology
                   METRO
                   CITY
                   EBAP
                   DCLU
                   COUIITY
U.S.  Environmental Protection Agency
Washington Department Of Ecology
Municipality of Metropolitan Seattle
City  of Seattle
Elliott Bay Action Program
Department of Construction and Land Use, City of Seattle
King  County
                 Figure  4.    Approach  to  characterization  of  direct  discharges
                                    and  ultimate  pollutant  sources.
                                                                 32

-------
    Technical Decision/Action
    |mega 1 pollutant discharge?)—(yes
        [permitted discharge?
                                    Regulatory  Decision/Action"
                                   perform permit compliance
                                   Inspection

                                  Veview permit and modify  for
                                   roblem chemicals, BMP, or  BATj


                                   issue notice of violation
 can source be controlled  by
 on-s1te treatment,  BMP, or BAT?
                                     issue  permit with limits on   N
                                     problem chemicals	J

                                    Iissue notice to cease  discharged
                                    require pretreatment and/or
                                    diversion to sewer system	j
  ^l
compliance achieved?









4- ^-^
is cleanup feasible? Kyes)*
JL —





decision feedback

[ require site-cleanup and/or
\ removal of drain sediments




J

loop
\

/
\
I

V— .
r

                              Agency/Program0






                           Ecology


                           Ecology

                           Ecology
                            Ecology
                                                                                Ecology,  EPA, METRO
                                                                                Ecology, EPA


                                                                                Ecology, EPA
                                                                              I  Ecology. EPA

                                                                              I

                                                                              I
8 Regulatory actions  include: 1) notification of permit  violation,
  2) administrative order  (e.g., to cease discharge,  to  cleanup site),
  3) permit issuance  or modification, and 4) issuance of penalty
  EPA
  Ecology
  METRO
  CITY
  EBAP
  DCLU
  COUNTY
  BMP
  BAT
   U.S.  Environmental Protection Agency
   Washington  Department of Ecology
   Municipality of Metropolitan Seattle
   City  of  Seattle
   Elliott  Bay Action Program
   Department  of  Construction and Land Use,
   King  County  •
   Best  Management Practices
   Best  Available Treatment
City of Seattle
        Figure  5.    Control  of problem drains  and  CSOs,
                                               33

-------
   Technical Decision/Action

/approach similar sources as a group'' i
 and review existing plans or develop'
 plans for pollutant control; e.g. BMP/
    shipyards  and oil tank farms.
                                       Regulatory Decision/Action*
                                   decision  feedback loop
                                                          Agency/Program

                                                         EPA/EBAP. Ecology
are recommendations feasible
or adequate?
                       return to Issuer for revision)      EPA/EBAP,Ecology
                    ^/require implementation of plan or
                    ^  program and require periodic
                     V performance or monitoring reports
                                                                               EPA/EBAP.Ecology, also
                                                                               METRO, CITY and COUNTY
           Regulatory actions Include: 1) notification of permit violation,
           2) administrative order  (e.g., to cease discharge, to cleanup site),
           3) permit Issuance or modification, and 4) Issuance of penalty
           EPA
           Ecology
           METRO
           CITY
           EBAP
           DCLU
           COUNTY
                                           penalty

U.S. Environmental Protection Agency
Washington Department Of Ecology
Municipality of Metropolitan Seattle
City of Seattle
Elliott Bay Action Program
Department of Construction and Land Use,  City of Seattle
King County
      Figure 6.   Control  of categorical  sources.
                                             34

-------
 Technical Decision/Action
                                 Regulatory Decision/Action*
                                                                                  Agency/Program''
c
revl
comp
con<
\- 1s dumping a recurrin
X problem?
(no)
g, serious -(yes) »f initiate criminal Investigation^
^—S ^and enforcement /
1
(require site cleanup \
and/or removal of I
drain sediments /
(defer action^

ew manifests and
uct interviews

	 l( monitor suspected \
rl problem site J
i
                                                                                  EPA/EBAP. Ecology
                 decision feedback loop
    8 Regulatory actions Include:  1) notification of permit violation,
      2) administrative order (e.g., to cease discharge, to cleanup site),
      3) permit Issuance or modification, and 4)  Issuance of penalty
      EPA
      Ecology
      METRO
      CITY
      EBAP
      DCLU
      COUNTY
U.S.  Environmental Protection Agency
Washington Department of Ecology
Municipality of Metropolitan Seattle
City of Seattle
Elliott Bay Action Program
Department of Construction  and Land Use,  City of Seattle
King County
Figure  7.    Control  of  illegal  dumping.
                                          35

-------
APPENDICES

-------
APPENDIX A



   MAPS

-------
                                            COMBINED SEWER OVERFLOW (MAJOR)
                                        •*•   COMBINED SEWER OVERFLOW (MINOR)
                                        *   COMBINED SEWER OVERFLOW/STORM DRAIN
                                       - 48") .
                                        O   TREATMENT PLANT OUTFALL
                                        S)   OTHER POTENTIAL SOURCES
                                                                                                                   GEORGETOWN
                                                                                        ELLIOTT
                                                                                           BAY
Public access  points and
recreational areas
                              MAPI
,   «.  , RECREATIONAL SHELLFISH
       HARVEST AREA
  0    EXISTING PUBLIC ACCESS    ,-/'V'v/ 4  PROPOSED WILDLIFE REFUGE
  ©    FISHING
  ED    PROPOSED PUBLIC ACCESS
  A    FUTURE PUBLIC ACCESS
millllMIIIIIIIIII  CITY PARKS
       GEODUCKS
       KELP
       EELGRASS

-------
                                     COMBINED SEWER OVERFLOW (MAJOR)
                                     COMBINED SEWER OVERFLOW (MINOR)
                                     COMBINED SEWER OVERFLOW/STORM DRAIN
                                     STORM DRAIN (8" to 24")
                                     STORM DRAIN (25' 10 48')
                                     STORM DRAIN (> 48")
                                     TREATMENT PLANT OUTFALL
                                     OTHER POTENTIAL SOURCES
                                                                                                 GEORGETOWN
                       \ DISPOSAL /
                        V AREA S
                                                                           ELLIOTT
                                                                              BAY
Contaminant sources and selected industry locations
in Elliott Bay and the lower Duwamish River
                                                       MAP 2
.V-

-------
                            APPENDIX  B

   ENVIRONMENTAL  CONDITIONS  AND  POTENTIAL  SOURCES  OF  CONTAMINANTS
FOR STUDY AREA SEGMENTS OF ELLIOTT BAY AND THE LOWER DUWAMISH RIVER

-------
                         NORTH  HARBOR  ISLAND (4B)
ENVIRONMENTAL  CONDITIONS
     At Site 4B  (North Harbor  Island), sediments  at the highest  ranked
stations  exhibited  the  following environmental  characteristics:

          Variable                      Elevation Above Reference

          LPAH                          Very  high      >1,OOOX
          HPAH                          Very  high      >1,OOOX
          PCB                          High           100-1,OOOX
          Cu+Pb+Zn                      High           100-1,OOOX
          As                           High           100-1,OOOX
          Amphipod  mortality            Moderate       3.6-7.IX

This site ranked  highest among all areas  based on "worst-case" stations.
Nearshore stations exhibited extremely high  levels of PAH, PCBs, and  metals
in sediments from the mouth of the West  Waterway east along  the shore of
North  Harbor Island to Pier 16.  Although the  outflow of the Duwamish River
contributes to  high levels of pollution in this area, gradients in sediment
concentrations  of  toxic chemicals suggest that local sources are important.
Moreover, this  is one of the few known  locations in the  study  area where
concentrations  of  LPAH in  sediments exceeded  1,000 times  the reference
value of  41 ppb.  The high levels of LPAH in  sediments suggest  an ongoing
source of petroleum pollution.  Much of the high arsenic content  in sediments
may be accounted  for by historical  releases of  sandblast material containing
50 ppm or more  of  arsenic.   However,  some arsenic contamination  may be
related to historical treatment of shipyard dry docks with sodium arsenite.
In sediment toxicity  bioassays, amphipod  mortality was 25-50 percent at
the mouth of the  West Waterway (Reference = 7 percent mortality), but was
not  significantly  elevated at about the 50-ft depth off Pier 14.  Finally,
the prevalence  of liver tumors in English sole  collected  from  North Harbor
Island and adjacent areas was 5.5 percent (Reference = 0 percent  prevalence).

     Although  sediment chemical concentrations showed some variation among
stations, the entire area  displayed  moderate to high  elevations of all
chemical  indicators.  Based  on average  conditions, this area ranked as
one of the top  four priority problem areas.

POTENTIAL SOURCES

     t    Todd  Shipyards                t    NPDES discharge of sandblast
                                            material  and  cooling  water
                                            (24  M  gal/yr)  until  1975,
                                            Dry  docks treated with
                                            (1,940 Ib/yr arsenic),
                                            Storm drains

-------
•    Mobil  Oil Company            •    NPDES stormwater discharge

•    Pier  15                      •    Oil  Transfer  Pier, possible
                                      oil spills.

-------
                         EAST WATERWAY  (4A/5A/5B)


     Segments  4A,  5A, and 5B  are considered  together as part of the East
Waterway system for two  reasons.  First, each of these  sites may be influenced
by sources throughout  the waterway.   Therefore,  source  control actions
are similar for all of the  sites.  Second, when data become available  for
areas between  these sites,  extensive toxic contamination  may be found throughout
the waterway.

ENVIRONMENTAL  CONDITIONS

     Within the East Waterway,  the highest  ranked stations exhibited  the
following conditions  for  sediment chemistry and sediment toxicity:

          Variable                      Elevation Above Reference

          LPAH                         Moderate       10-100X
          HPAH                         High           100-1,OOOX
          PCB                           High           100-1,OOOX
          Cu+Pb+Zn                      Moderate       10-1OOX
          As                           Moderate       10-100X
          Amphipod mortality            High          ^7. IX
          Oyster abnormality            High          ^8.2X

Segment 5A, which ranked third among all  high priority areas based on "worst-
case"  conditions, accounted for the  high ranking for the  East Waterway
overall.   Contamination was heterogeneous within the  waterway.  For example,
the  head of the waterway  (Segment 5B)  ranked 17th, and the mouth of  the
waterway  (Segment 4A)  tied  for the  12th position among priority problem
areas.   Based on the most contaminated  sediment  samples,  PCBs, with an
elevation of 770 times reference  (6  ppb) , and HPAH, with  an elevation  of
240  times reference  (79 ppb), were the main problem  chemicals.  Also,  the
sum of copper,  lead,  and zinc exceeded an elevation above reference  of
25 at  two stations.  Average EAR values were about 23 for LPAH, 120  for
HPAH, 150 for  PCBs, 3  for arsenic, and 16 for the other selected metals.

     Both  the  amphipod bioassay and the  oyster larvae bioassay exhibited
above 50  percent response for samples  from several locations within  the
waterway.  The only bioassay response above 90 percent  for the entire Elliott
Bay system was  found  in an  amphipod  bioassay  (98 percent  mortality) near
the  Lander Street CSO.  Based on the  available pooled data for West  and
East  Waterways  and the North Harbor  Island area, the  prevalence of  liver
tumors in English sole  was  5.5 percent, which was significantly elevated
relative  to reference  conditions of 0 percent prevalence.

-------
POTENTIAL SOURCES
     •
     •
     •
     t
Connecticut  CSO               •
Hanford CSO                   •
Lander CSO                   •
Hanford CSO/SD  (162)          t

Seattle Iron and Metal        •

S. Hinds CSO/SD  (107)         •

S.W. Spokane CSO/SD  (163)     0

S.W. Florida SD               •
S. Spokane SD                a
GATX                         •
Chevron Oil  Company           t
Groundwater  sources
- Shell/Chevron
- Golden Penn

- SEAFAB
          Value  Plating
30-100 M gal/yr
100-700 M gal/yr
20-330 M gal/yr
SD  =  60 M  gal/yr,  emergency
CSO only
Cu wash > settling  pit overflows
to Hanford  SD
SD  =  40 M  gal/yr,  emergency
CSO only
SD  =  3 M  gal/yr,  emergency
CSO only
20 M gal/yr
Unknown flows
NPDES - storm  water
NPDES - storm  water

"Product recovery" wells
Waste  solvent recycler, sludge
lagoon possible  (historical)
Old seepage pond  (battery
acid,  spent chemicals,  yard
drainage) closed  1982,
Monitoring  well  installed
1970-1978 wastewater  discharged
on grounds.

-------
                          WEST WATERWAY (6A/6B)
ENVIRONMENTAL CONDITIONS

     The most  contaminated  stations within  the  West Waterway  exhibited
the following conditions for  sediment chemistry and  sediment toxicity:

          Variable                     Elevation Above  Reference

          LPAH
          HPAH
          PCB
          Cu+Pb+Zn
          As
          Amphipod mortality
          Oyster abnormality

The West Waterway ranked among the top seven priority areas based on "worst-
case"  stations  and  among  the top  three  priority areas  based on average
conditions.   Sediment chemistry was  relatively homogenous throughout the
West Waterway,  although  for some  contaminants,  sediment  concentrations
near the shore were slightly  higher  (e.g.,  2-3 times) than  those near mid-
channel.  Sediment toxicity bioassays and fish pathological indices indicate
biological  problems within this area (see  section on  East Waterway above
for  fish  pathology  data).   Several stations exhibited bioassay responses
above 40 percent response  (47 and 63 percent mortality  of  amphipods and
78 percent abnormality of oyster larvae).
High
High
High
Moderate
Low
High
High
100-1, OOOX
100-1, OOOX
100-1, OOOX
10-100X
<10X
>7.1X
>8.2X
POTENTIAL SOURCES

     •    Chelan CSO
     •    S.W.  Hinds CSO/SD  (099)

     •    S.W.  Florida  CSO/SD  (098)

     •    S.W.  Lander CSO/SD  (105)

     •    S.W.  Florida  CSO/SD  (106)

     •    S.W.  16th  CSO/SD  (104)

     •    S.W.  Lander SD
     t    Fischer Flour
•    1-50 M gal/yr
t    SD = 280 M gal/yr,
     CSO = 60-90 M gal/yr
t    SD  =  20  M gal/yr, emergency
     CSO only  (PCBs, PAH, metals)
•    50 M gal/yr (Pb),
     Cleaned 1984
•    SD  =  30  M gal/yr, emergency
     CSO only
•    SD  =  10  M gal/yr, emergency
     CSO only
t    8 M gal/yr  (Pb, oil and grease)
t    NPDES cooling water
     (23.4 M gal/yr),
     Storm drain

-------
     Lockheed Shipyards
•
•
t
Arco
Shell
Texaco

SEAFAB/RSR
•    Golden  Penn
•    Harbor  Island Machine

•    Old W.  Seattle landfill
•    NPDES  cooling water
     (43.8  M gal/yr),
     Storm  drains,
     Dry dock  -  Na^AsOo treatment
     (1,490-2,980  fbs  As/yr) until
     1982
•    NPDES  - storm water
•    NPDES  - storm water
•    NPDES  - storm water (historical
     source of  truck wash water)
•    NPDES -  cooling  water (Pb)
     Groundwater  -  old  seepage
     pond
•    Groundwater  source
t    Oil-contaminated surface runoff
     (source removed 1984)
•    Possible groundwater source.

-------
                         SOUTH HARBOR  ISLAND  (7A)
ENVIRONMENTAL CONDITIONS
     The highest elevations  of sediment  chemistry and toxicity bioassay
variables observed  in  the  South  Harbor Island area were  the  following:

          Variable                      Elevation Above  Reference

          LPAH                         Moderate       10-100X
          HPAH                         High           100-1,OOOX
          PCB                          High           100-1,OOOX
          Cu+Pb+Zn                      Moderate       10-100X
          As                           Low            <10X
          Amphipod  mortality            High           >7.IX
          Oyster abnormality            Moderate       4.1-8.2X

Based on the worst-case stations,  this  area  tied  with Segment 6B (West
Waterway) for the 7th  priority position.  PCBs were the  main problem chemical
in sediments at this  site, with  elevations ranging  from 170 to 805  times
the  reference value  of 6 ppb.  Although HPAH were elevated in the same
order of magnitude  range as PCBs, elevations of  HPAH at all stations were
below 150 times reference.  In general, metals in sediments were not excessively
high (i.e., metals  indicators  were less than  20 times reference  at  all
but one station).

     Average  chemical  conditions in the sediments indicated low to moderate
contamination for all  indicators.  Based on average  conditions, this area
tied with Segment 5B  for the 10th priority position.

     Sediment  toxicity bioassays  at the  worst station and fish pathology
reflected the high  levels  of contamination in  this  area.   The prevalence
of liver tumors  in English sole collected from this area and adjacent areas
of the Duwamish River  was  13-16  percent, among the highest values observed
throughout Puget Sound.   Average  oyster larvae abnormality was very high
(78 percent).   However, average amphipod mortality for all  stations  was
relatively low  (22 percent),  indicating heterogeneous conditions in this
area.

POTENTIAL SOURCES

     •    Diagonal  Way  CSO/SD  (111)     t    CSO = 80-550 M  gal/yr,
                                            SD = 430 M  gal/yr
                                            (1-5 - metals,  PAH)
     •    S.W.  Dakota  SD               •    20 M gal/yr
     •    S.W.  Idaho  SD                •    60 M gal/yr

-------
Ash Grove Cement               •     NPDES cooling water
                                    (78 M gal/yr)
                               •     Storm water/wastewater discharged
                                    to unlined surge pond (metals)
Seaboard Lumber                •     NPDES cooling water (4 M gal/yr).

-------
                            DENNY WAY CSO  (2A)
ENVIRONMENTAL CONDITIONS
     Based on  the  highest ranked stations,  environmental conditions for
this site are  as  follows:

          Variable                      Elevation  Above  Reference

          LPAH                         High           100-1,OOOX
          HPAH                         Very high       >1,OOOX
          PCB                           High           100-1,OOOX
          Cu+Pb+Zn                      High           100-1,OOOX
          As                            Moderate       10-100X
          Amphipod  mortality            Moderate       3.6-7-1X
          Oyster  abnormality            Moderate       4.1-8.2X

Among the high priority  areas, this area ranked as the  second most important
site.   Although lack of  adequate reference data precluded calculation of
Elevation Above Reference  values  for  the site,  available data show  that
benthic infaunal  communities are degraded  (i.e., low  species richness,
high abundance of pollution-tolerant species).   Amphipod and oyster larvae
bioassays of  sediment  also  suggest that biological problems may be caused
by the existing contamination of sediment at this  site.  Based on average
conditions represented by sediment chemistry variables and bioassays,  this
site ranked only  as a moderate priority, indicating heterogeneous conditions
at  the  site.   Nevertheless, HPAH were  on average more  than 300 times the
reference level  of 79  ppb, and PCBs  were about  190  times the reference
level  of 6 ppb.   Average  concentrations of metals were of  relatively minor
concern.

POTENTIAL SOURCES

     The  ongoing source of  toxic contamination in this area is the Denny
Way CSO, the largest CSO in the Elliott Bay system (flow = 80-620 M gal/yr).
No other potential  sources have been identified.

-------
                         SEATTLE WATERFRONT (3C)
ENVIRONMENTAL CONDITIONS

     Based on the  two  highest ranked stations sampled  in  this area, sediment
conditions for this  site  are as follows:
          Variable

          LPAH
          HPAH
          PCB
          Cu+Pb+Zn
          As
          Amphipod mortality
          Oyster abnormality
Elevation Above  Reference
High
High
High
Moderate
High
High
Not significant
100-1,OOOX
100-1,OOOX
100-1,OOOX
10-100X
100-1,OOOX
>7.1X
This area tied with two  other  areas for the 5th rank among  14 high  priority
sites.   Conditions  at  the two stations in this area were similar.  Based
on average sediment chemistry  and  bioassay data,  the area ranked  5th  in
terms of environmental  problems.  On average, LPAH and total PCBs  in sediments
were each 260 times reference,  and HPAH was  570  times reference.  The  sum
of  copper, lead,  and  zinc was 190 times reference at one  station, but only
8 times reference at the other  station.  Arsenic concentrations in  sediments
did not indicate a problem, but only one data point was available.

POTENTIAL SOURCES

     Several  CSOs under  the  jurisdiction  of the City of Seattle may be
a continuing source of  pollution in this area.   Raw sewage was  discharged
into  this area  from the late  1800s to the early 1970s.   Historical spills
along the waterfront may also  account for some  of the contamination  in
this area.
     The ongoing sources  are  as  follows:

     •    City CSOs  (071,  164)          •


     •    Seattle Steam                •
     Total  flow  =  1.14 M  gal/yr,
     approximately  12  events  per
     year
     NPDES  discharge  of  cooling
     water (23.5 M gal/yr).

-------
                               SLIP 1 (7B)
ENVIRONMENTAL CONDITIONS

     Only sediment chemistry  data were  available for Slip  1.   Based on
three stations,  the  highest levels of contamination were:
          Variable

          LPAH
          HPAH
          PCB
          Cu+Pb+Zn
          As
Elevation Above  Reference
Very high
High
Moderate
Moderate
Moderate
>1,OOOX
100-1,OOOX
10-100X
10-100X
10-100X
Slip 1 tied with  Segment  6A  (West  Waterway) for  the  4th highest  priority
position  based on  environmental contamination and  effects.  The  very high
concentrations  of  LPAH  (up to 42,000 ppb in sediments  at the head  of  the
slip)  indicated  an  ongoing  source of petroleum pollution.   For all chemical
indicators, there  was a gradient  from high concentrations at the head  of
the  slip  to relatively  lower concentrations at midchannel of the Duwamish
River adjacent  to  the slip.  Based on average  contaminant concentrations
relative to other  areas,  Slip 1 ranked as the highest  priority area.
POTENTIAL SOURCES

     •    PCB spill  (1974)
     •    Manson Construction
     •    Ideal  Cement
t    255 gal  AROCLOR  1242
•    Storm drain
t    NPDES cooling water
     (5.5 M gal/yr),
     Settling  Pond - Kiln and truck
     wash water.

-------
                               SLIP 2 (8A)
ENVIRONMENTAL CONDITIONS
     The entire  Slip 2 area ranked as a low priority  area based on average
conditions  as  well  as  on "worst-case" stations.   However, the head of  the
slip  is  included  in  this  Interim Work Plan because contamination gradients
from the mouth to the  head  of the  slip are indicated  by the limited data
available.  Concentrations of HPAH,  PCBs, and the  sum of copper, lead,
and zinc in  sediments were each elevated 10-100X reference  levels.  Elevations
of  HPAH  and PCBs  were  about 35 times reference levels.   Data on LPAH were
not adequate for  analysis.  Arsenic  in sediments  did not appear  to be a
problem.  No bioassay, benthic infauna, or fish pathology  data were available.

POTENTIAL SOURCES

     •    Michigan CSO                 •    90-210 M gal/yr

-------
                               SLIP 3 (8B)
ENVIRONMENTAL  CONDITIONS

     Slip 3 and  the adjacent  river  channel  ranked 9th (tied with  Fourmile
Rock Disposal Site) based on "worst-case"  stations, and 14th based  on  average
conditions.   The most  contaminated station within Segment 8B  was at the
head  of Slip 3.   Because of the limited  data  available and  the relatively
high  contamination  indicated by this  one  station, the head of Slip 3 is
included in  this  action  plan.

     Both LPAH  and  HPAH in sediments from the head of Slip 3 were  elevated
about 120 times  above  the  reference  value (Reference =  41  ppb  for LPAH;
Reference =  79 ppb for HPAH).   PCBs were elevated 38 times above the reference
value of 6 ppb.  Arsenic  in sediments  was  24 times
of 3.4 ppm.   Although  the  sum of copper,
reference value  of  34 ppm,  this  elevation
with  respect  to biological  effects.  Data
              the  reference level
     lead, and zinc was 17 times the
     is not of  particular concern
     on sediment toxicity bioassays,
benthic infauna,  and  fish pathology were not  available for Slip 3.
POTENTIAL SOURCES

     t    Michigan CSO

     •    S. Fox CSO/SD  (116)
t    90-210 M gal/yr

t    SD = 30  M gal/yr, emergency
     CSO only

-------
                               SLIP 4 (8D)
ENVIRONMENTAL  CONDITIONS
     Relative  to  other study sites,  Slip 4 and the adjacent river channel
area ranked  only as a moderate priority based  on  average conditions  and
"worst-case"  stations.   Nevertheless, the head  of  Slip 4 is included in
this plan because  of extremely high concentrations of PCBs in sediments
and the known  importance of nearby sources.

     The  time-averaged concentrations of toxic chemicals  in sediments from
the U.S. EPA 1982-1983 surveys were  used to  characterize conditions  at
the  head of Slip 4.   The contaminant group of major concern in Slip 4 is
PCBs.  The concentrations of PCBs in  sediments  at the head of the  slip
were 1,600 ppb in  the 1982 survey and  4,600 ppb  in the 1983 survey, yielding
an average of  3,100 ppb or 517 times the reference value of 6 ppb.   HPAH
was  of less concern, with an Elevation Above Reference of  about 90.  Metals
were of no immediate concern, since  elevations  were less than 20  times
reference values.  No adequate data  were available for LPAH and biological
indicators.  However,  the observed concentrations of PCBs in sediments
of Slip 4 are  expected  to  cause biological problems.

POTENTIAL SOURCES

     •    Georgetown Flume             •    PCBs  in  sediments =  137 ppm
                                           (dry weight)
     t    Slip 4 CSO/SD (117)           •    PCBs  in  sediments =  103 ppm
                                           (dry weight); SD = 150 M gal/yr,
                                           emergency CSO only
     •    Slip 4 SD                     •    140 M gal/yr
     •    1-5 drain                     •    10  M gal/yr
     •    East Marginal Pump  Sta CSO    t    Emergency CSO only.

-------
                     FOURMILE  ROCK DISPOSAL SITE (10A)


ENVIRONMENTAL CONDITIONS

     Based  on  the highest  ranked stations  within Fourmile  Rock Disposal
Site, environmental  conditions  for this area are as follows:

          Variable                     Elevation Above Reference

          LPAH                         Moderate       10-100X
          HPAH                         High           100-1,OOOX
          PCBs                         High           100-1,OOOX
          Cu+Pb+Zn                     Moderate       10-100X
          As                           Low            <10X
          Amphipod mortality           High           >_7.IX

Among the high  priority areas,  this area was  ranked lowest in terms  of
environmental problems.   However, the disposal site is  considered for interim
action because 1)  available  data  are  limited,  2)  the  public is concerned
about  transport  of  disposal  material to beaches along Magnolia, and 3) the
disposal area will be evaluated as part of the Puget Sound Dredged Disposal
Analysis.

     Environmental conditions  at  the  Fourmile Rock  Disposal Site  are relatively
heterogeneous.   Based on  average  conditions, this  area ranked lower  than
some of the moderate  priority  areas in the Elliott  Bay  system.  Nevertheless,
average PCB and HPAH  concentrations in sediments were  about 100 times the
respective reference concentrations.   The average  concentration of PCBs
in sediments at Fourmile Rock Disposal  Site  was  584 ppb, which is  high
enough to be of potential  environmental concern.

     The Fourmile Rock Disposal Site was the only priority area with both
adequate data on benthic  infauna  (bottom-dwelling  invertebrate organisms)
and  adequate reference  data that could be used to  calculate Elevation Above
Reference values.   These  values indicated that benthic  infaunal communities
were modified slightly  relative  to corresponding communities found in clean
areas near Seahurst  in  the main  basin of Puget  Sound.  At the disposal
site,  dominance  was  moderately  elevated (1.12-4.90 times Reference), total
abundance was not  depressed  (<1 times Reference), the total  number of  taxa
was moderately depressed (1.12-4.90  times below reference), and amphipod
abundance  was moderately depressed (1.12-4.90  times below reference).
Because  the available  data are limited, no  definitive conclusions about
biological  conditions  at the  Fourmile  Rock Disposal  Site  can be made  at
this time.

POTENTIAL SOURCES

     Disposal of dredged material is  the primary source of toxic contamination
at the Fourmile Rock  Disposal  Site.

-------