Puget Sound Estuary Program
ELLIOTT BAY TOXICS
ACTION PROGRAM
REVIEW OF EXISTING
PLANS AND ACTIVITIES
PREPARED BY:
TETRA TECH, INC.
PREPARED FOR:
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON DEPARTMENT OF ECOLOGY
PROGRAM PARTICIPANTS:
City of 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:
REVIEW OF EXISTING PLANS AND ACTIVITIES
by
Tetra Tech, Inc.
for
U.S. Environmental Protection Agency
Region X - Office of Puget Sound
Seattle, 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 toxicant-related problems in the Elliott Bay
system. The Action Program 1) identifies existing problems of toxic contami-
nation, 2) locates sources of contaminants, 3) defines corrective actions
to eliminate existing problems, 4) identifies appropriate agencies to implement
the actions, and 5) provides a schedule for action implementation.
This report outlines ongoing remedial activities and plans of agencies
presently involved in solving problems of toxic contamination in Elliott
Bay and the lower Duwamish River. By also identifying gaps in existing
activities and plans, this report serves as a guide for improving current
regulatory and management activities, and for developing new ones. These
improvements will be summarized in an Interim Work Plan for the immediate
future (i.e., within 2 yr) and a comprehensive Work Plan for subsequent
years.
Remedial actions and plans are divided into two categories: 1) those
aimed at controlling sources of toxicants and 2) those aimed at managing
contaminated sediments. Source control programs and plans are subdivided
ii
-------
by type of source [for example, municipal sources, combined sewer overflows
(CSOs), and nonpoint sources].
In the following descriptions, ongoing activities are identified with
an asterisk; all other plans or activities are either in the planning stages,
or are not yet funded. NPDES permits for direct discharges are discussed
in general terms because most permittees discharge noncontact cooling water.
The contribution of toxic contamination by permitted discharges is therefore
minor or negligible.
MUNICIPAL SOURCES
Plans and Activities
Renton Effluent Transfer System*: Metro plans to divert
the Renton treatment plant effluent from its current discharge
site in the Duwamish River to a less sensitive site in Elliott
Bay.
Toxicant Input to Metro's Treatment System*: Metro's (1984)
toxicant Pretreatment Planning Study reports include an
evaluation of the industrial pretreatment program and recommen-
dations for improving pretreatment.
Corrosion Control Program*; The City of Seattle hardens
its water to reduce the leaching of metals from distribution
pipes.
Planning Gaps
Although Metro has made a commitment to eliminate the Renton
effluent from the Duwamish River, changes in plans for the
new outfall have led to significant delays in construction.
iii
-------
There is currently no formal program for Metro and the Washington
Department of Ecology to coordinate with city and county
licensing and permitting programs to screen new and/or converted
businesses in Metro's service area for possible toxicant inputs.
COMBINED SEWER OVERFLOWS (CSOS)
Plans and Activities
Improvements to Metro's CATAD System*; The Computer Augmented
Treatment and Disposal System (CATAD) is being improved
to reduce CSO intensity and frequency by increasing in-line
storage capacity.
Elimination of CSOs: One goal of Metro's long-term facilities
planning is to reduce CSOs. Washington Department of Ecology,
however, will require eventual elimination of CSOs.
Planning Gaps
If the Denny Way CSO (largest in Metro's system) and other
northern Elliott Bay CSOs continue to be heavily used, it
is unlikely that sediment conditions (or water quality during
storm events) will improve at those sites.
There is presently no firm commitment to eliminate CSOs.
A draft report on CSO planning alternatives is due in November,
1985.
Major improvements to Metro's CATAD system have been repeatedly
postponed because of facilities planning.
iv
-------
NONPOINT SOURCES
Plans and Activities
Duwamish Industrial Nonpoint Source Investigation*: Metro
personnel, with support from the Washington Department of
Ecology, have visited Duwamish-area industrial sites to
identify possible contaminant sources and to recommend remedial
actions.
Hazardous Waste Site Cleanup*; Four major sites of concern
in the study area are designated for cleanup under federal,
state, or local hazardous waste programs.
Seattle Shoreline Master Program and City Grading and Drainage
Codes*; These city ordinances provide for the incorporation
of special conditions in permits issued for facilities that
store or handle hazardous substances. These conditions
could have the effect of reducing contamination from spills
and surface water runoff.
Planning Gaps
There is inadequate implementation of the hazardous material
provisions of Shoreline Master Permits and permits for grading
and drainage. This deficiency is primarily due to a lack
of expertise and personnel resources in the city's Department
of Construction and Land Use.
The City of Seattle lacks a stormwater treatment and storm
drain/CSO maintenance program designed to control toxicant
contamination.
-------
Although existing discharge permit mechanisms can be used
to control stormwater discharges, there is no state or federal
strategy to do so.
CONTAMINATED SEDIMENTS
Plans and Activities
Fourmile Rock Disposal Site Standards*: Standards now in
effect require thorough testing of candidate materials and
represent a policy of no further degradation.
Short-Term Dredging Plans: Maintenance dredging by the
U.S. Army Corps of Engineers and the Port of Seattle may
incidentally remove contaminated sediment.
Environmental Impact Statement for the Puget Sound Dredged
Disposal Analysis Study (PSDDA)*; Identify procedures to
determine the quality of dredged material so that disposal
alternatives can be evaluated.
Planning Gaps
There is a major need to develop a long-term sediment management
strategy for Puget Sound, especially for contaminated "hot
spots."
vi
-------
CONTENTS
Page
EXECUTIVE SUMMARY ii
LIST OF FIGURES viii
LIST OF TABLES ix
ACKNOWLEDGMENTS x
INTRODUCTION xi
1. IDENTIFICATION OF PROBLEM ISSUES AND AREAS 1-1
1.1 IDENTIFICATION AND ELIMINATION OF CONTINUING SOURCES OF
TOXIC POLLUTANTS . 1-1
1.2 TOXIC CONTAMINATION OF ELLIOTT BAY AND THE LOWER DUWAMISH
RIVER 1-2
1.3 NEED FOR INTERAGENCY COORDINATION 1-2
2. REMEDIAL ACTIONS AND PLANS 2-1
2.1 CONTROLLING TOXICANT SOURCES 2-1
2.2 MANAGING CONTAMINATED SEDIMENTS 2-26
3. ASSESSMENT OF EXISTING PLANS AND ACTIVITIES ADDRESSING TOXICANT
PROBLEMS 3-1
3.1 MUNICIPAL POINT SOURCES 3-1
3.2 COMBINED SEWER OVERFLOWS 3-3
3.3 TOXICANT INPUT TO METRO'S TREATMENT SYSTEM 3-5
3.4 NONPOINT SOURCES 3-7
APPENDICES
APPENDIX 1 - LIST OF INTERVIEWEES; ELLIOTT BAY ACTION PLAN
DEVELOPMENT QUESTIONS ON PLANNING AND REMEDIAL
ACTIVITIES
APPENDIX 2 - REFERENCES
APPENDIX 3 - METRO TOXICANT PROGRAM REPORTS
vii
-------
FIGURES
Number
1 Generalized map of sediment chemistry in central Puget Sound/
Elliott Bay area 1-3
2 Contaminant sources and selected industry locations in
Elliott Bay and the lower Duwamish River 2-13
3 Decision process for dredge disposal at Fourmile Rock site 2-28
4 404 (dredge and fill) and shoreline permit process 2-31
5 Proposed East, West, and Duwamish Waterways navigation
improvements 2-35
viii
-------
TABLES
Number Page
1 Plans and activities addressing toxic pollutant problems 2-2
2 METRO'S adopted capital program - 1984 2-6
3 Industrial NPDES permittees discharging to Duwamish 2-7
4 METRO'S overflow priorities 2-15
5 Activities resulting from Duwamish industrial nonpoint
investigations 2-19
6 Remedial activities and plans for toxicant control 3-2
ix
-------
ACKNOWLEDGMENTS
This document was prepared by Tetra Tech, Inc., under the direction
of Dr. Robert A. Pastorok, for the U.S. Environmental Protection Agency
in partial fulfillment of Contract No. 68-03-1977. Mr. John Underwood
and Ms. Martha Burke of U.S. EPA were the Project Officers, and Dr. Thomas
C. Ginn of Tetra Tech was the Program Manager.
The primary author of this report was Ms. Judy Mayer of JRB Associates
(a Company of Science Applications, Inc.). Mr. Pieter N. Booth, Dr. Robert
A. Pastorok, and Ms. Marcy B. Brooks-McAuliffe of Tetra Tech contributed
to the writing and editing. Initial drafts of the report were produced
for Tetra Tech by JRB Associates under the direction of Ms. Jessica Kaplan.
Ms. Joan Thomas of the Washington Department of Ecology (WDOE) and Dr. John
Armstrong of U.S. EPA reviewed the report. Review comments were also provided
by members of the Elliott Bay Interagency Work Group and the Citizens Advisory
Committee. Special assistance in compiling information on existing plans
and activities was provided by the agency representatives interviewed during
the project (Appendix 1).
-------
INTRODUCTION
This report was prepared for the U.S. Environmental Protection Agency
(U.S. EPA) as part of the Elliott Bay Toxics Action Plan. The report outlines
the ongoing remedial activities and plans of agencies involved in solving
problems of toxic contamination in Elliott Bay and the lower Duwamish River.
Gaps in existing action plans are also identified. A physical description
of the study area and summary of available data on toxic contamination
and biological effects are given in a companion report entitled "Elliott
Bay Toxics Action Plan: Initial Data Summaries and Problem Identification."
Information contained in this'report was obtained in two ways: 1)
through on-site or telephone interviews with key agency personnel, and
2) by a review of relevant planning and program documents. In January
and February, 1985, interviews were conducted with agency officials involved
in planning and implementing programs relevant to toxic contamination.
Officials interviewed were from the following agencies:
Municipality of Metropolitan Seattle (METRO) - local government,
regulatory agency, and user
City of Seattle (City) - local government and regulatory
agency
Port of Seattle (Port) - user
State of Washington Department of Ecology (WDOE) - regulatory
agency
U.S. Environmental Protection Agency (U.S. EPA) - regulatory
agency
xi
-------
U.S. Army Corps of Engineers (COE) - regulatory agency and
user.
Appendix 1 contains a list of the officials interviewed and a sample interview
format.
The interviews were complemented by a review of planning and program
documents that address toxic contamination of Elliott Bay and the lower
Duwamish River. Appendix 2 contains a list of these documents.
xii
-------
1. IDENTIFICATION OF PROBLEM ISSUES AND AREAS
The interviews and document review indicated that agencies' planning
and program concerns include technical, biological, and engineering problems
as well as decision-making and institutional coordination issues. In general,
plans and remedial programs focus on three major issues:
Identifying and elimination sources of toxic contaminants
Managing lower Duwamish River and Elliott Bay toxic "hot
spots"
Need for interagency coordination.
Each issue is briefly summarized below.
1.1 IDENTIFICATION AND ELIMINATION OF CONTINUING SOURCES OF TOXIC POLLUTANTS
Recent studies of water and sediment quality by the National Oceanic
and Atmospheric Administration (NOAA), METRO, WDOE, and U.S. EPA have contribu-
ted to the identification of some major sources of toxicants. In particular,
METRO'S 1984 Toxicant Pretreatment Planning Study (known as "TPPS") concluded
that stormwater runoff and combined sewer overflows (CSOs) (which contain
contaminated stormwater as well as untreated wastewater) were major sources
of toxic contamination in the lower Duwamish River and inner Elliott Bay.
WDOE, METRO, and the City of Seattle all have programs to identify
and eliminate nonpoint sources of pollution. METRO has been required by
U.S. EPA and WDOE to eventually eliminate its CSOs. This task is concurrent
with METRO'S planning efforts for upgrading its wastewater treatment plants.
METRO also has programs to reduce the levels of toxicants that enter its
system.
1-1
-------
1.2 TOXIC CONTAMINATION OF ELLIOTT BAY AND THE LOWER DUWAMISH RIVER
Sediments in much of the lower Duwamish River (especially the East
and West Waterways), in areas adjacent to Seattle's major combined sewer
overflows, and area surrounding the Four Mile Rock Disposal Site show elevated
toxicant levels relative to nonurban reference areas. Populations of benthic
organisms and bottom fish near some highly contaminated areas appear to
have elevated prevalences of abnormalities, possibly attributable to their
toxic habitat. Major toxic "hot spots" in the lower Duwamish River and
Elliott Bay, as identified by METRO'S Toxicant Pretreatment Planning Studies,
are shown in Figure 1.
There are three management alternatives for toxic sediments:
The sources of toxics can be removed, thus allowing natural
sedimentation to cover the contaminated area with clean
material
The sediments can be isolated from biological resources
by "capping" them with cleaner material
The sediments can be removed by dredging.
Each of these management options requires that ongoing sources of pollution
be controlled to avoid recontamination of "cleaned" sites. However, the
second alternative encompasses yet another management problem: the disposal
of contaminated material. This problem is encountered by the Corps of
Engineers, the Port of Seattle, and others when contaminated sediments
are removed during routine dredging activities. Dredging activities are
explained in further detail in the section on managing contaminated sediments.
1.3 NEED FOR INTERAGENCY COORDINATION
The success of pollution abatement and cleanup activities depends
largely on coordination between the planning and program implementation
activities of involved agencies. Such coordination helps each agency use
1-2
-------
KEY:
Deep Central Basin
Highest overall
toxicant levels
High toxicant
levels
Scales are different for each
example toxicant; all units
are concentration means in
PPM dry weight.
Cu * copper
Pb = lead
Hg = mercury
CPAH * combustion PAHs
LPAH = Low mol. wt. PAHs
PCB = total PCBs
DOT = total ODE & ODD & DDT
Denny Way CSO
Old North Trunk Sewer
FIGURE 1
A GENERALIZED MAP OF SEDIMENT CHEMISTRY IN THE CENTRAL PUGET
SOUND/ELLIOTT BAY AREA SHOWS THREE HOTSPOTS: THE INNER ELLIOTT BAY
ALONG THE ENTIRE WATERFRONT, THE FOUR MILE ROCK DREDGE SPOILS
DISPOSAL SITE, AND THE SITE OF THE OLD NORTH TRUNK SEWER OUTFALL
Source: Metro. 1984. Toxicant Pretreatment Planning Study Summary Report,
Metro Toxicant Program Report No. 3, p. 150.
1-3
-------
its limited resources more effectively. Discussions with agency personnel
indicate that staff are concerned about the need to obtain outside support
to satisfactorily fulfill their responsibilities. In several cases, staff
pointed out the need for open communication among agencies, including the
need to improve access to information which can support decision-making.
Other concerns were related to the time-consuming process of permit appli-
cations, the need for additional inspection or enforcement resources, and
the need for some agencies to make definitive determinations of environmental
standards or requirements.
1-4
-------
2. REMEDIAL ACTIONS AND PLANS
A variety of remedial actions and plans have been developed by the
involved agencies to deal with the broad concerns mentioned above (Table
1). Generally, the programs focus on two types of problems:
Sources of toxicants
Contaminated sediments.
For each of these problems, Table 1 identifies programs or plans which
address the problem, identifies the agency leading the remedial effort,
and summarizes program activities. Program activities are described in
more detail in the following sections, which are organized to correspond
with Table 1. Many of the programs explained here refer to written planning
documents. Full citations for the documents can be found in Appendix 2.
Note that the COE activities are directed at facilitating navigation, although
they may have the incidental benefit of removing or containing contaminated
sediments.
2.1 CONTROLLING TOXICANT SOURCES
METRO, the City of Seattle, and WDOE currently cooperate on several
programs to identify and eliminate sources of toxic pollutants to the lower
Duwamish River and Elliott Bay (e.g., Duwamish Nonpoint Industrial Source
Investigation; Trouble Call Response Program). METRO, WDOE, and U.S. EPA
have plans and programs aimed at reducing pollutant discharges from point
sources and nonpoint sources.
2-1
-------
TABLE 1
PLANS AND ACTIVITIES ADDRESSING TOXIC POLLUTANT PROBLEMS
Problems
TOXICANT SOURCES
Problem Identification
Municipal Point
Sources
Agencies
EPA
Metro
Metro/EPA
(DOE)
Programs/Plans
Water Quality Management
Program for Puget Sound
(1983-1984)
Renton Effluent Transfer
System (1986)
301(h) Secondary Treatment
Waiver Application (West
Point) (1979-1984)
Activities
Studies and general recommendations of water quality
data management systems; proposed approach and technical
support effort; managing for long-term cumulative
effects.
Plan to divert Renton trearatent plant effluent from
Duwamish to Puget Sound; based on 1981 wastewater plan
for the Lake Washington/Green River Basins.
Application for waiver of secondary treatment
requirements; supporting facilities and operation
improvement plans; supporting water quality modeling and
evaluation; application denied by EPA; DOE will reissue
NPDES permit with compliance schedule to meet secondary
standards.
Toxicant Input
to Metro's
Treatment System
Combined Sewer
Overflows
(CSOs)
Nonpoint Sources
Metro
Metro
City of
Seattle
Metro
Metro
Metro/City of
Seattle (DOE)
Metro (208
authority)
Upgrade West Point and
Alki Plants to Secondary
Treatment (1985-1991)
Toxicant Pretreatraent
Planning Study (TPPS)
(1979-1984)
Water Supply Corrosion
Control Program (1982)
Household Hazardous Waste
Program
CATAD System Improvements
(1985-1986)
Elimination of CSOs
(long-term planning)
Areawlde Water Quality Plan
(1978)
Now planning to upgrade primary treatment plants to
meet secondary standards by 1991 in compliance with
September 1984 Administrative Order from DOE.
Comprehensive study of toxicants throughout Metro's
collection and treatment system; toxicant sampling In
receiving waters; specific recommendations to reduce
toxicant input, strengthen industrial pretreatment
program, and Improve toxicant removal rates.
Routinely treats City water supply to reduce pipe
corrosion and leaching of metals.
Guidance and public education on disposal of common
toxic materials.
Improvements in hardware and data management for
Metro's computer augmented treatment and disposal
network.
CSO discharge permits to be reissued by DOE will Include
compliance schedules for CSO elimination; Metro and
Seattle are planning CSO Improvements in conjunction
with Metro's treatment plant upgrade.
Highlighted nonpolnt source problem; recommended
division of responsibilities.
-------
Metro (208
authority)
Metro
[205(j) grant]
Investigations
(1983-1986)
DOE/Metro/
EPA/Coast
Guard
DOE/EPA/
Metro/City
City of
Seattle
City of
Seattle
Duwamlsh Clean Water Plan
(1983)
Duwamlsh Industrial
Nonpolnt Source and Clean
Water Plan
Interagency Trouble Call
Response Program
Designation and Clean-up of
Superfund Sites
Seattle Shoreline Master
Program (SSMP) (1977-)
Grading and Drainage Code
(1983-)
Recommended nonpolnt source control measures.
Identifies and assists Industries needing Improved
toxics management or pretreatment; traces contaminated
drainage to Industrial sources; Initiated toxic
groundwater study.
Reponds to citizen reports of suspected water quality
problems; follow-up Including source detection, clean-
up and enforcement.
Three Superfund sites in Seattle and Kent pending
action to eliminate potential toxic contributions to the
Duwamish.
Shoreline authority powers Include permit process for
development In shoreline district; can require spill
control, etc. 1977 program updated; revised SSMP to be
effective late 1985.
City can require runoff and spill control measures for
new construction anywhere in City.
NJ
I
u>
MANAGING CONTAMINATED
SEDIMENTS
EPA/DOE/City
of Seattle
Port/COE
Port/COE
(DOE/EPA/
City)
COE (DOE/EPA)
COE
COE/EPA/DOE
Four Mile Rock Standards
(1984)
Immediate Dredging Plans
(1985-1986)
Development of Pier 90/91
Disposal Site (1985)
Corrective Action for other
"Hot Spots" (long-term)
Widening and Deepening
of Federal Navigation
Channel (long-term)
Environmental Impact
Statement for Open Water
Disposal
Formulation of criteria to determine acceptability of
dredge spoils for open water disposal at Four Mile Rock;
under appeal.
Maintenance dredging of navigation channel and berths;
"404" dredge and fill permitting process Including water
quality assessments.
Proposal to dispose of contaminated dredge spoils at
short-fill between Piers 90 and 91; application under
review pending draft of fill criteria and safeguards;
long-term plans may Include fill of greater area between
Piers 90 and 91.
Studies on sediment removal or "capping" strategies.
Capping may be considered under the widening and
deepening project.
Studies providing additional Information on toxicant
levels In sediments in 1985-1986 (to Identify dredge
spoil disposal options).
Develop long-term strategies for disposal of dredged
sediments; develop sediment quality criteria.
-------
2.1.1 Problem Identification
Activity: Water Quality Management Program for Puget Sound
Sponsoring Agencies: EPA/DOE
Time Frame: 1983 - 1984
In 1983 and 1984, EPA and DOE sponsored a series of studies of water
quality data and management programs throughout Puget Sound. EPA's
"Water Quality Management Program for Puget Sound" indicated the
importance of Federal cooperation with Washington DOE, especially
regarding regulatory efforts. The first phase of this work involved
an evaluation of "Management Activities, Data Requirements and Data
Base" (Jones & Stokes Associates, Inc., September 1983). The study
summarized existing water quality and hydrologic studies of the Sound
and gave detailed information on toxicant levels detected at selected
locations. The report also made general recommendations for future
water quality monitoring and modeling needed to provide adequate
information to design a comprehensive management program. The report
pointed out the need for additional information on toxic pollutants
and their effects in the Sound's urban embayments, including Elliott
Bay.
The second stage of the water quality management program, "Proposed
Approach and Technical Support Effort" (Jones & Stokes Associate,
Inc., January 1984), discussed EPA's priorities, objectives, and means
for Puget Sound water quality management. It included technical
analyses of pollutant mass loadings, mass transport and accumulation
models, bioassays, and other data. The proposed approach then
described recommended studies needed to continue water quality
management planning, and recommended a general interim approach,
including strategies for regulating municipal discharges.
The third stage in EPA's 1983-1984 program focused on "Managing for
Long-Term Cumulative Effects" (Jones & Stokes Associates, Inc.,
September 1984). Although toxic contamination in the urban embayments
was only one of several concerns discussed in this report, the study
did point out the need for appropriate management of sedimentation and
dredge spoil disposal, and the control of existing sources of heavy
metals and toxic organic compounds to areas such as Elliott Bay. The
study also described the background of current research in Commencement
Bay, Port Gardner, Sinclair Inlet, and Bellingham Bay.
2.1.2 Municipal Point Sources
Activity; Renton Effluent Transfer System
Sponsoring Agency: Metro
Time Period; To begin in 1985
Metro is currently committed to an adopted capital improvement program
amounting to at least $531 million. Several elements of this program
are expected to reduce toxicant loadings to the Duwamish and Elliott
2-4
-------
Bay. Major projects of the capital improvement program are listed in
Table 2. Most significant for toxicant reduction in the Duwamish and
Elliott Bay is the Renton Effluent Transfer System.
Metro plans to divert Renton treatment plant effluent from its current
discharge point on the Duwamish River to a less sensitive site in
Puget Sound, 9,000 to 10,000 feet from shore, northwest of Duwamish
Head. DOE currently permits direct discharges from 25 sources on the
Duwamish, but the Renton plant discharge is the only source of
municipal or industrial wastewater at this time (see Table 3 for list
of Duwamish dischargers). Metro's primary reason for diverting the
Renton effluent is to avoid providing costly advanced treatment and
ammonia removal that would be necessary to maintain Duwamish water
quality. Recently, Metro has stated that DOE would not consider
allowing Metro to retain its Duwamish outfall in any case. However,
the diversion will also result in substantial reductions in toxicant
loadings to a stretch of the river between Tukwila and the head of
navigation.
Metro recognized the need to divert its Renton treatment plant
effluent from the Duwamish when the Metro council adopted the
"Wastewater Plan for the Lake'Washington/Green River Basins" (known as
the Renton 201 Study) in November 1981. This decision was reinforced
by a DOE order of March 1982 (Order DE 82-206) which included a
compliance schedule for relocating the discharge to Puget Sound no
later than June 31, 1986. The Renton plant's NPDES permit, reissued
to coincide with the State order, also included final limits for an
upgraded Renton treatment plant.
By relocating the discharge point to marine waters, Renton will need
to provide only secondary treatment, rather than the advanced treat-
ment that would be required to continue discharging to the Duwamish.
Final limits for the expanded Renton plant will also double the
permitted flow from the current 36 million of gallons per day (mgd) to
72 mgd (monthly dry weather average) and allow the plant to double its
treatment capacity; the expansion is another major project of Metro's
capital program. Interim discharge limits for both ammonia and
residual chlorine have been eliminated from the final marine discharge
permit, along with limits on nine heavy metals.
Metro's facility planning indicates that the construction phase of the
Renton diversion project will cost approximately $200 million, in 1985
to 1987. A State referendum authorized the use of $150 million in
State revenues. Metro's user charges and borrowing will supply the
balance of necessary funds. This project is to be carried out con-
currently with the expansion of the Renton plant, which will include
additional treatment capacity and solids handling facilities. Esti-
mated construction cost for the expansion, from 1985 to 1988, is about
$65 million.
The plan originally called for Metro to build a tunnel to convey
treated effluent from the Renton plant to a discharge point off
Seahurst Park. This discharge point was the subject of an extensive
2-5
-------
TABLE 2
METRO'S ADOPTED CAPITAL PROGRAM - 1984
Renton Treatment Plant Expansion
Renton Effluent Transfer
System
Renton Solids Handling
Facilities
Renton Collection System
Improvements Including Sun-
set/Healthfield Improvements,
Pump Station Upgrades, and
Misc. Projects
Alki Treatment Plant
Modernization
Alki System Pump Station
Improvements
Carkeek and Richmond Beach
Treatment Plant Upgrades
Sludge Program Improvements
Including Equipment and Site
Acquisition
Computer Augmented Treatment and
Disposal (CATAD) System Upgrade and
Flow Monitoring System
Water Quality Lab
TPPS
Alki Outfall Improvement
West Point Solids Handling
Improvements Including Increased
Digester Capacity
West Point Collection System
Improvements Including Kenmore
Interceptor, Matthews Beach
Force Main, Pump Station
Upgrades, East Lee/East Lynn
CSO Project, North Creek Trunk
Extension, and Misc. Projects
Note: This program does not include funds for upgrading primary treatment
plants to meet secondary standards, nor does it include additional CSO
elimination which may be included as part of the secondary upgrade
project.
Source: Metro. 1984. Toxicant Pretreatment Planning Study Summary Report,
Metro Toxicant Program Report No. 3, p. 186.
2-6
-------
TABLE 3
INDUSTRIAL NPDES PERMITTEES DISCHARGING TO DUWAMISH
PERMIT NO/TYPE
ENTITY
LOCATION RECEIVING WATER
WA-002902-5 I S
WA-002969-6 I S
WA-003036-8 I S
WA-000351-4 I S
WA-000291-7 I S
WA-000291-7 I S
WA-002987-4 I S
WA-003065-1 I S
WA-000185-6 I S
WA-000223-2 I S
WA-003076-7 I S
WA-000055-9 I S
WA-000309-3 I S
WA-002912-2 I S
WA-000343-3 I S
WA-000143-1 I S
WA-000162-7 I S
WA-000308-5 I S
WA-000179-1 I S
S5162 I S/6
S3024 I G/S
WA-003071-6 I S
WA-000127-9 I S
WA-002214-4 I S
WA-002135-1 I S
Airco Welding Seattle
Arco Seattle
Boeing, Awacs Seattle
Boeing, DC Seattle
Boeing, no field Seattle
Boeing, Plant 2 Seattle
Boeing, SRC Seattle
Boeing, Thompson Seattle
Columbia Cement Seattle
Ideal Basic Ind. Seattle
Liquid Air Kent
Lockheed 1&2 Seattle
Monsanto-Van Seattle
Northcoast Chem. Seattle
NW Glass Co. Seattle
Quemetco-RSR Seattle
Seattle Rendering Seattle
Shell Oil Co. Seattle
Texaco Seattle
Ash Grove Co. Seattle
Blk. River Quarry Seattle
Boeing, EMF Seattle
Chevron USA Seattle
Gatx Tank Seattle
Fisher Mills Seattle
Duwamish R
Duwamish R
Duwamish R
Duwamish R
Duwamish R
Duwamish R
Duwamish R
Duwamish R
Duwamish R
Duwamish R
Duwamish R
Duwamish R
Duwamish R
Duwamish R
Duwamish R
Duwamish R
Duwamish R
Duwamish R
Duwamish R
Duwamish R & Groundwater
Duwamish R & Groundwater
Duwamish R via Storm Sewer
Duwamish R/EWW
Duwamish R/EWW
Duwamish R/WWW
Note: Table does not include all dischargers to Duwamish system.
Source: DOE Northwest District.
2-7
-------
baseline study from April to December of 1984 that estimated potential
environmental effects. However, the study indicated that the Seahurst
discharge point would not be the least costly alternative. Facility
plans for the diversion project are currently being revised to accom-
modate the new discharge point northwest of Duwamish Head. Results of
a contaminant study for the new Duwamish Head outfall site were pub-
lished in April 1985.
Activity: 301(h) Waiver Application
Sponsoring Agency; Metro
Time Frame: 1979 - 1984
In September 1979, Metro applied for a variance from secondary
treatment requirements, as provided under Section 301(h) of the Clean
Water Act, for its West Point treatment plant. The application was
based on proposed changes in West Point operations, including some
chemical additions, the elimination of sludge input from the Renton
plant (since Renton's upgrading will include sludge handling), addi-
tional toxicant source control measures, and combined sewer overflow
(CSO) controls. Metro's supporting documentation contained plan
summaries and water quality studies, concentrating mainly on the
impacts of the West Point discharge in Puget Sound's central basin.
In August 1984, EPA tentatively denied the application basing its
decision in part on data published in Metro's Toxicant Pretreatment
Planning Study. EPA's decision stated that:
...The TPPS and other recent studies have indicated that
biological and sediment conditions in large parts of Elliott
Bay are substantially impacted or degraded. Solids which
are discharged by the West Point POTW, which is the largest
permitted discharger to Puget Sound, are dispersed
throughout the Central Puget Sound Basin and Elliott Bay.
Environmental studies completed to date do not indicate the
presence of acute or obvious signs of a degradation of the
biological community, or high levels of pollutants in the
sediment, near the discharge. These findings are not
surprising considering that the point of discharge is swept
by strong tidal currents.
Even though the biological and sediment conditions in the
immediate vicinity of the West Point discharge do not appear
to be acutely impacted or polluted..., this discharge is
contributing to the overall environmental degradation
observed in and near Elliott Bay. Given the circulation in
Puget Sound, the widespread distribution of solids (and
their associated pollutants) from the West Point discharge
serve as a continual source of pollutants throughout Elliott
Bay and the adjacent waters and, at a lower level, through-
out Puget Sound.
...The discharge will violate the 301(h) criterion requiring
2-8
-------
maintenance of water quality which assures protection of a
balanced indigenous population of the shellfish, fish and
wildlife and recreational activities in and on the water.
Therefore, to protect a resource of the value and sensitivi-
ty of Puget Sound, the Seattle Metro West Point variance
request is tentatively denied.
Metro is currently beginning facilities planning to upgrade the West
Point plant to comply with secondary treatment standards. At the same
time, DOE is drafting a new discharge permit for the West Point plant
which will contain a compliance schedule for the upgrading. The
revised permit is expected to be issued in mid-1985, pending discus-
sions between Metro and DOE, EPA recommendations, and public comments
on the draft permit. However, resources necessary to upgrade the West
Point plant are above and beyond Metro's adopted capital program.
Upgrading is unlikely to begin before 1987, according to Metro
planners.
2.1.3 Toxicant Input to Metro's Treatment System
Activity; Toxicant Pretreatment Planning Study (TPPS)
Sponsoring Agency; Metro
Time Frame; Conducted 1979 - 1984; recommendations now being
implemented
Metro's major activity in the TPPS program, a five-year, $7 million
investigation, was to trace the occurrence of toxic substances in its
treatment plants (to the receiving waters or sludge), in its col-
lection system, and at selected industrial locations. To define
toxicant problems for receiving waters and assess priorities for
future planning and corrective action, Metro evaluated the relation-
ship of three factors: high toxicant concentrations, documented
biological disruptions, and potential impacts on important resources.
Areas where all three indicators overlap were considered to be likely
problem areas, where remedial action should become a Metro priority.
By this process, Elliott Bay and the Duwamish Estuary were classified
as definite problems areas. The area surrounding Four Mile Rock was
in a less critical category, since there was less complete documen-
tation of toxic impacts there. The study found that toxic con-
tamination of sediments was more significant than corresponding
contamination of the water column during nonstorm conditions.
TPPS also evaluated Metro's pretreatment program. In addition, TPPS
included several projects with implications for toxic contamination in
Elliott Bay and the Duwamish:
- The Household Hazardous Waste Disposal Project, which contained a
list of toxicants in consumer products and a directory of disposal
recommendations for agency personnel
2-9
-------
- Technical reports, tracing toxicants throughout the Metro system
including discharges to the Duwamish and the Bay through treatment
plant effluent, CSOs, and some nonpoint sources
- Fate and effect studies of toxicants through the treatment plants,
and into sludge and receiving waters
- A general synthesis of TPPS and related project information,
problem definition from Metro's perspective, conclusions and
recommendations.
A list of TPPS reports is contained in Appendix 3 .
Activity; Strengthen Enforcement of Industrial Waste Program
Sponsoring Agency; Metro
Time Frame: 1985 - 1986
Metro has an extensive industrial waste control program (pretreatment
program) aimed primarily at regulating industrial wastes entering the
sewer system in its service atea. Metro's industrial waste regula-
tions address both conventional and priority pollutants and include
specific limits on pollutant concentrations that dischargers are
allowed to release to the Metro system. In addition, approximately
170 industrial dischargers are regulated by industrial waste discharge
permits that are issued for five-year periods and generally contain
concentration limits on conventional and priority pollutants,
including metals and toxic organic compounds. Further, permits
require that industries monitor these regulated pollutants in their
effluent and regularly report results to Metro. Where industries have
been unable to meet their discharge limits, permits also contain
compliance schedules to install pretreatment facilities or implement
practices to meet discharge limits or spill containment requirements.
Metro administers its pretreatment and other industrial waste control
programs using a cooperative approach toward noncompliant industries.
Industrial waste control staff provide technical advice to industries,
and take formal enforcement action only when industries fail to make
good-faith efforts to comply with their permit conditions. Two recent
reports described and evaluated Metro's pretreatment program (see JRB,
"Audit of Pretreatment Program," and TPPS Technical Report A4 by J. J.
Gall). While recognizing the value of a cooperative approach, both
reports recommended that Metro strengthen its enforcement activities
against recalcitrant industrial permittees. This recommendation was
strongly supported in the TPPS Summary Report.
Recently, Metro has begun to combine its enforcement actions with
incentives for compliance. Fines for permit violations are doubled
for each repeated violation of the same standard. However, if indus-
tries fined for permit violations install required facilities,
enabling them to comply with pretreatment standards, Metro will reim-
burse their costs at a rate of up to half of the fines paid. Costs
2-10
-------
recovered for damages are not reimbursed. Metro and EPA, in coopera-
tion, are expected to give greater emphasis to enforcement activities
than they have in the past.
Activity; Corrosion Control Program
Sponsoring Agency; City of Seattle
Time Frame: 1982 - Current
TPPS found that, before full implementation of Seattle's water supply
corrosion control program, the City's water supply was the largest
source of zinc and a significant source of copper to both West Point
and Renton treatment plants. Slight acidity and extreme softness of
Seattle's water combined to cause leaching from metal distribution
pipes, in turn adding metals to sewage. Seattle's corrosion control
program began in June 1982 in the Tolt water supply system (serving
the northern third of the City) and was broadened to include the Cedar
system (serving the rest of the City) by March 1983. The program
involves adding lime and soda ash to water supplies. Annual chemical
addition costs are approximately $150,000. In the Tolt system, the
City adds 2 mg/1 of lime and 9 mg/1 of soda ash to the supply, raising
pH from 6 to 8 and alkalinity' from 2 to 13. This has resulted in
reductions of 50 to 70 percent of copper, lead, cadmium, and zinc
loadings to water supplies, and a 20 percent reduction in iron
loading. In the Cedar system, the City adds 2 mg/1 of lime, to raise
pH from 7 to 8, and alkalinity from 16 to 19. This also resulted in
significant reductions in metal loadings by mid-1983.
Activity; Household Hazardous Waste Project
Sponsoring Agency; Metro
Time Frame; Ongoing
As part of TPPS, Metro found that residential areas contributed only
11 percent of the total metal loadings to Metro's treatment plants,
but significant portions of total loadings of mercury (52 percent),
nickel (47 percent), and arsenic (40 percent). Residential areas were
the major source of three phthalates (used as plastic stabilizers) and
significant amounts of some volatile organics, especially benzene. To
address these sources, Metro began a public education program aimed at
reducing the disposal of household hazardous wastes to the sewers.
Activities in Metro's household hazardous waste disposal project
include:
- Production and distribution of a list of toxicants in consumer
products (Toxicant Program Report IB)
- Pilot collection study and public opinion survey on household
hazardous waste disposal (Toxicant Program Report 1C)
2-11
-------
- Production and distribution of school curriculum materials on
hazardous waste issues (Toxicant Program Report ID)
Distribution of a directory of product disposal recommendations for
public agency personnel (Toxicant Program Report IE).
2.1.4 Combined Sewer Overflows (CSOs)
A total of 48 combined sewer overflow points are permitted by DOE to
discharge wastewater and stormwater to Elliott Bay and the lower Duwamish
River. The City of Seattle owns 31 of these CSOs, with a total annual flow of
24 million gallons. Metro owns the remaining 17 CSOs, with total annual flows
between 500 million and 2,100 million gallons, according to Metro's monitor-
ing. Many of these are used only in emergency situations. The locations and
DOE permit members of these discharge points are shown in Figure 2. Permit
numbers beginning with "W" or "A" designate CSOs owned by Metro. Virtually
all CSOs used for discharge to Elliott Bay and the lower Duwamish contribute
measurable amounts of toxicants to the water column during storm events, and
eventually to sediments adjacent to the discharge points, according to
sampling done by Metro.
Activity; Improvements in Metro's CATAD System
Sponsoring Agency; Metro
Time Frame: 1985 - 1986
During the 1970s, Metro developed an extensive computer augmented
treatment and disposal (CATAD) network. CATAD was designed to allow
Metro to use its in-line stormwater storage capacity most effectively
in order to minimize adverse effects of CSO discharges on receiving
water quality. It embodies the priorities formulated by Metro to
control the order in which its CSOs are used. Diversion and overflow
control strategies reflect Metro's emphasis on protecting the region's
freshwater streams and lakes first, then the Duwamish Estuary, and
finally northern Elliott Bay. Thus, the Denny Way, King Street, and
Connecticut CSOs should be used before combined sewer overflows are
allowed to occur elsewhere in Metro's system. Table 4 shows priori-
ties for Metro's 22 most significant CSO discharges controlled through
the CATAD system. The water quality criteria used by Metro as a basis
for the CSO priorities emphasized conventional pollutants. However,
Metro's TPPS project found that the use of toxicant criteria would not
have changed its CSO priorities significantly.
2-12
-------
CO
COMBINED SEWER OVERFLOW (MAJOR)
COMBINED SEWER OVERFLOW (MINOR)
* COMBINED SEWER OVERFLOW/STORM DRAIN
STORM DRAIN (8' to 24')
<8> STORM DRAIN (25* to 48')
Ǥ> STORM DRAIN (> 48')
O TREATMENT PLANT OUTFALL
D OTHER POTENTIAL SOURCES
GEORGETOWN
Contaminant sources and selected industry locations
in Elliott Bay and the lower Duwamish River
MAP 2
FIGURE 2
Note: CSOs with numbers preceded by "A" or
"W" are owned by Metro. Others are
owned by the City of Seattle.
-------
Metro is now improving CATAD control capacity and flexibility by
combining design of new CATAD hardware with that of updated control
systems to be installed in the Renton and West Point treatment plants
in 1985 and 1986. The improved system will coordinate in-plant
processes with collection system storage and diversions. It will also
employ remote telemetry and control units for individual pumping
stations, and is expected to reduce CSO occurrences and volumes
throughout Metro's system. Costs for CATAD system improvements, part
of Metro's adopted capital program, are estimated at up to $1.8
million for 1985 and 1986. Metro expects to sign contracts for
hardware in December 1985.
Use of the City of Seattle's CSOs is controlled to great extent, by
Metro's stormwater storage practices, since Metro generally owns the
largest sewer mains. Many of the City's CSOs are actually overflows
through storm drains. Most significant in the City's CSO strategy is
the use of CSOs on Harbor Island (numbers 106, 105, 104, 102, 163,
162, and 077) only in emergency situations. As with Metro's CSOs,
discharges to northern Elliott Bay are used before other CSOs, when
possible. At this time, specific effects of CATAD system improvements
on toxicant loadings to the Duwamish and Elliott Bay have not been
estimated in detail, though sampling for some toxicants has been
carried out for some CSOs to Elliott Bay and the Duwamish River.
Activity; Elimination of CSOs
Sponsoring Agency: Metro
Time Frame: To be decided in conjunction with planning for treatment
plant upgrading
Feasibility studies to eliminate CSOs in Metro's system were actually
undertaken, in part, to support Metro's 1979 301(h) application to
EPA. Metro claimed that water quality goals would be better served by
spending limited resources to eliminate CSOs than by upgrading Metro's
marine discharges to meet secondary treatment standards. In 1979, the
Metro Council adopted a CSO control plan establishing priorities to
eliminate or control CSOs throughout the Metro/City of Seattle sewer
system. However, some CSOs now known to contribute heavy toxicant
loads to Elliott Bay, including the Denny Way CSO, were given a
relatively low priority for action in 1979, because their public
health impacts were not as immediate as those of other Metro CSOs.
In addition, Metro's TPPS study recommended that the impacts of CSOs
on toxicant problems in Elliott Bay and the Duwamish River be eval-
uated as part of an Elliott Bay action plan for toxics. TPPS also
recommended that Metro's priorities for CSO elimination be limited to
those already in Metro's capital program. These do not include struc-
tural elimination of Elliott Bay and many Duwamish River CSOs.
Reissued final NPDES permit requirements for Metro's treatment plants,
now being drafted by DOE and EPA, will require Metro and the City to
eliminate their CSOs. Appropriate compliance schedules are now being
negotiated, while Metro completes facility planning for both upgrading
2-14
-------
TABLE 4
METRO'S OVERFLOW PRIORITIES
(From least to most harmful based on water quality criteria)
Priority Order
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
CSO Name Permit #
Denny - Local W027
Denny - Lake Union
King W028
Connecticut W029
Harbor
Chelan W036
Hanford #2 ' W032
Lander W030
Brandon
W. Michigan
Michigan W039
8th South
Norfolk
Hanford #1
Duwamish Siphon
Denny - Interceptor
3rd Avenue West
Freemong Siphon
Dexter Avenue
University Regulator
Montlake Regulator
Matthews Park
Max. Flow/Year (mg)
620
60
100
50
50
730
330
40
5
210
20
400
Source: Metro 1985
2-15
-------
the West Point plant and eliminating its CSOs. DOE and EPA expect
Metro to submit comprehensive facilities plans for CSO elimination in
1987 following intensive CSO monitoring in 1985 and 1986. Detailed
requirements for CSO elimination have not yet been issued by DOE; they
will be included in reissued permits for Metro's treatment plants and
to the City of Seattle.
In planning to eliminate CSOs (in conjunction with upgrading to meet
secondary treatment standards), Metro is using 1981-1983 CSO
discharges as a baseline. No upgrading configuration that would
aggravate CSO conditions as they existed during the 1981-1983
monitoring period will be considered by Metro. Two of the four major
alternatives for the secondary upgrade being developed in mid-1985
include provisions for a wet weather treatment plant. Incremental
improvements in CSOs will be factors in cost-effectiveness analyses
associated with Metro's treatment plant upgrading.
2.1.5 Nonpoint Sources
Activity; Areawide Water Quality Plan
Sponsoring Agency: Metro
Time Frame: 1978 to Present
In January 1978, Metro issued its Areawide Water Quality Plan for King
County Cedar-Green River Basins. The 1978 plan, prepared as part of
Metro's 208 areawide water quality planning efforts, generally high-
lighted the importance of nonpoint source control. Toxicant control
recommendations recognized the lack of documented threats to human
health or the environment from toxic contamination of the area's
surface waters. However, despite the lack of documented risks, the
plan did assign toxicant control program responsibilities among
agencies, including the following recommendations:
- DOE should take a key role in coordination and in providing public
information on toxic pollution. DOE should be a "clearinghouse"
for toxicant control information and should prepare guidance on
storage and disposal of toxic material for other agencies.
- Metro should work with all affected agencies to inventory data on
toxicant levels in water and sediments of the Cedar-Green River
Basins. Metro should prepare a specific analysis of the Duwamish
Estuary to quantify known water quality problems, a program to
analyze suspected problems, and a rehabilitation plan to correct
documented problems. Metro should also work with Duwamish Valley
industries on voluntary improvements in storage, handling, and
disposal of toxic materials as well as in carrying out its indus-
trial pretreatment program.
- Local fire departments should work closely with DOE, EPA, and the
Coast Guard to develop hazardous spill cleanup techniques that
would avoid washing toxicants into nearby waterways.
2-16
-------
All of these recommendations have been implemented to some extent
since the plan's publication in 1978.
Activity; Duwamish Clean Water Plan
Sponsoring Agency; Metro
Time Frame: 1983 to Present
Metro published the Duwamish Clean Water Plan in May 1983. The plan
built upon the 1978 recommendations, recognizing the importance of
nonpoint source control, but focused specifically on the Duwamish.
Recommendations in the Duwamish Clean Water Plan were based on water
quality evaluations and sediment sampling conducted by Metro between
1980 and 1983, and reported in Metro's 1983 Water Quality Assessment
of the Duwamish Estuary. The plan assumed that the Renton treatment
plant effluent would be diverted to Puget Sound and did not deal with
other point source (or permitted source) issues.
The plan's eleven major recommendations to improve Duwamish water
quality include four which relate directly to controlling nonpoint
source toxicant contamination of the Duwamish River: (1) control
toxicants in the West Waterway, which has heavy concentrations of
metals and PAHs (polynuclear aromatic hydrocarbons); (2) improve
storage, handling, and disposal of potentially hazardous materials;
(3) continue the emergency response and action program; and (4)
pave contaminated Harbor Island parking areas. Many of the activi-
ties associated with these recommendations combine identifying
nonpermitted sources with more concrete actions to control them.
The 1983 Duwamish Clean Water Plan recommendations led to Metro's
Duwamish industrial nonpoint source investigations, described below.
Activity: Duwaraish Industrial Nonpoint Source Investigations
Sponsoring Agency; Metro
Time Frame; 1983 - 1984 (initial); 1985 - 1986 (continuation)
An EPA/DOE 205(j) grant supported Metro's initial 1983/1984 program to
identify nonpermitted or nonpoint toxicant sources in Duwamish Valley
industrial areas. The program also assisted industries to improve
their storage, handling, and disposal of hazardous materials. In
addition, the investigations initiated groundwater sampling projects
in the Duwamish Valley. This investigative program coordinates
Metro's trouble call response program as well. Each of these
activities is outlined below.
- Inspection of Industrial Sites and Follow-up Action
In the first 18 months of Metro's Duwamish nonpoint project, Metro
staff visited 34 industrial facilities. Sites were selected based
on ten criteria related to the likelihood that the facility was a
significant source of toxic pollution to the Duwamish, past history
of the facility or site, and willingness of the industry to
cooperate. Before site visits, Metro reviewed relevant permit,
2-17
-------
compliance, or other available information on each industry.
Visits were conducted according to procedures established at the
beginning of the project.
On site visits, Metro inspectors attempted to identify inadequate
spill control measures, the possible need for fugitive toxic dust
control, and illegal or inadequate stormwater measures. Inves-
tigators approached companies in a cooperative stance, offering
free technical assistance to firms willing to take measures
identified for their sites after inspections and runoff sampling.
Twelve of the industries visited had adequate pollution controls,
requiring no follow-up work after initial discussions with Metro.
Three hazardous waste sites were referred to DOE for follow-up. As
part of follow-up investigations, samples were requested from ten
industries to determine if they contributed significant toxic
loadings to the Duwamish. If so, these industries were asked to
develop control measures. This phase of the investigations
emphasized cooperation and improvements were made in several cases,
including the development of pretreatment systems, catch basin
cleaning, or changes in storage, cleaning, and handling practices.
The project attempted to integrate several kinds of industrial
waste control and storage practices that could affect water
quality.
Table 5 lists activities resulting from the Duwamish industrial
nonpoint project that were being carried out or pending in late
February 1985. In addition, Duwamish industrial nonpoint source
investigations resulted in some unresolved issues which have been
referred to other agencies for action. These include the following
industries:
Industry Name
Marine Power and
Equipment
Todd/Lockheed
Shipyards
Site Investigation
Date
9/14/83
1/12/84
Value Metal
Polishing
Wyckoff
Referral Action
Referred to DOE 5/3/84
Fined $5,000 by DOE 7/26/84
EPA enforcement investigation
pending
Post site visit conference
3/6/84
Response letter 4/6/84
Referred to DOE 4/17/84 at
Todd/Lockheed request
Metro Industrial Waste case
DOE lead
EPA/DOE lead
Storm drain samples 4/5/84
2-18
-------
TABLE 5
ACTIVITIES RESULTING FROM DUWAMISH INDUSTRIAL NONPOINT INVESTIGATIONS (JUNE 1985)
Industry Name
Site Investigation
Date
Action Pending
NJ
I
Marine Power and
Equipment
Jorgensen Steel
Columbia Cenent
Shell Oil
ARCO
Todd/Lockheed Shipyards
Seattle Iron and Metal
Chevron
Nonferrous Metals
Meltec
Pacific Molasses
Malarkey Asphalt
Purdy Company
Ashgrove Cement
Hanson Construction
Duwamloh Shipyard
9/14/83
10/24/83
11/10/83
11/15/83
12/16/83
1/12/84
2/8/84
2/22/84
6/21/84
7/19/84
7/23/84
8/21/84
9/17/84
10/10/84
i1/14/84
11/28/84
Letter requesting additional Information 10/27/83; postslte visit
conference 3/7/84; response 4/13/84; referred to DOE 5/3/84; fined
$5,000 by DOE 7/26/84. Appealed to WPCHB (settled without formal
hearing); EPA enforcement Investigation pending.
NPDES permit and acid pit referred to DOE 11/1/83; Jorgensen response
to DOE Hazardous Waste 3/20/84; NPDES permit has been updated.
No additional control measures necessary; letter 11/23/83; trouble call
10/24/84; recommending bermlng wash area 10/25/84.
Letter requesting groundwater Information 1/24/84.
Request for groundwater Information one sample belowscheduled
stormwater discharge to river.
Post site visit conference 3/6/84; response letter 4/6/84; referred to
DOE 4/17/84 at Todd'a request.
Samples taken 2/29/84; postsite conference 4/16/84; additional samples
4/27/84; letter with results, recommendations 10/24/84; hook-up to
sanitary sewer scheduled for 8/85; work continuing with Industrial
Waste Division.
Request for groundwater data 4/23/84; part of current Duwamlsh
groundwater study.
Drain sample taken 7/13/84; recommendation letter 10/24/84; additional
storm drain sampling spring 1985.
Storm drain samples 12/84.
Recommendation that emergency shut-off valve be Installed.
Samples taken of pond 10/22/84, river bank sediment 10/23/84; referred
to DOE for NPDES permit 6/85.
Recommended recycling used oil, avoid transformers with PCBs.
EPA TSCA Investigation scheduled; cooperating with several agencies on
clean-up of Florida street drain.
Preslte 10/10, Postsite 11/29; recommended paving berm and cover oil
storage area. Requested samples of slag fly ash, coal and surge pond.
Oil storage area upgraded; will work with DOE on surge pond
Improvements; started 12/84.
Preslte 11/9; facility upgrading recommended.
Preslte 11/15. Postsite 12/6; referred to DOE 2/27/85.
-------
Site Investigation
Industry Name Date Referral Action
Purdy Company 9/17/84 EPA TSCA investigation
pending
Ashgrove Cement 10/10/84 Work with DOE on surge pond
improvements; referred to
DOE 12/84.
Duwamish Shipyard 11/28/84 Referred to DOE 2/27/85
Mono Roofing Referred to DOE 11/84 for
enforcement action
Seattle Boiler Metro recommended that the
Works company apply for NPDES
permit from DOE for non-
contact cooling water 3/85
Malarkey Asphalt Referred to DOE for State
discharge and/or NPDES
permit 6/85
- Storm Drain Sampling
Metro sampled twelve major storm drains in the Duwamish Valley to
find sources of toxicants in the Duwamish that could not be
accounted for by permitted point sources or "typical" runoff.
Drains sampled are shown in Figure 2. Four of these drains were
found to have elevated concentrations of toxic metals and organic
compounds, including those at Lander Street (lead); Georgetown
Flume (PCBs); Florida Street SW (metals, PAHs, PCBs); and Fox
Street South (metals).
Results of storm drain sampling were shared with DOE and EPA. EPA
plans to investigate several facilities which may be the sources of
toxic runoff, including facilities near the storm drains in ques-
tion, owned by City Light and Boeing (near the Georgetown Flume),
Wyckoff, and Purdy Company (near Florida Street SW). The Lander
Street drain was probably contaminated by runoff containing lead
dust from a lead smelter that no longer operates. The drain has
since been cleaned and the contaminated parking lot paved. Wycoff
has been referred to EPA for enforcement action. The Purdy Company
remains under investigation.
- Groundwater Study
Duwamish nonpoint source investigations highlighted the need for a
comprehensive study of Duwamish Basin groundwater. Staff developed
a work plan for research on past dredge and fill activities in the
lower Duwamish as well as past and present industrial waste dis-
2-20
-------
posal practices that could affect groundwater, and a review of
existing groundwater studies. Metro hired the Sweet-Edwards con-
sulting firm to carry out its work plan and develop a scope of work
to formulate groundwater models of the lower Duwamish. The final
consultant's report was released in May 1985.
- Trouble Call Response Program
The Trouble Call Response Program is operated jointly by Metro,
DOE, EPA, and the Coast Guard, to respond to calls from the public
about suspected water quality problems. A public information
campaign has made Seattle area residents aware of the need to call
Metro or DOE if they observe evidence of toxic spills or dumping.
Metro's efforts in this regard have concentrated particularly on
the Renton plant's service area; DOE's have been more general,
consistent with emergency investigation and response activities
throughout the State.
In general, Metro's program emphasizes spills affecting sewer
systems. DOE is called in,, however, when serious spills are likely
to have a direct impact on State waters. Both programs provide
that other agencies, including the Coast Guard, are called upon to
assist in response and clean-up if Metro and DOE resources are
inadequate to cope with emergency situations. Metro's industrial
dischargers have been informed through the pretreatment program of
their obligation to call Metro when toxic spills take place at
their facilities.
In the Duwamish, calls to Metro and DOE have resulted in
enforcement action against Marine Power and Equipment for illegal
discharges from sand blasting operations in Slip 3. The company
appealed the $5,000 fine that DOE assessed against it. This appeal
was denied; an EPA enforcement investigation is pending. Investi-
gations of other shipyards' practices are planned for 1985. In
another case, DOE has required control measures to eliminate
illegal discharges of asphalt roofing and solvents by Mono Roofing.
Metro intends to continue its Duwamish industrial nonpoint source
investigation program into 1985 and 1986 in order to investigate 30 to
40 additional industrial sites and assist industries to improve their
toxicant management practices. Metro has committed funds to continue
its site visits.
2-21
-------
Activity; Identification of other contaminated sites resulting from
past activities (e.g., lead smelter wastes; tank farm
leachate; hazardous waste disposal sites)
Sponsoring Agencies; DOE and Metro
Time Frame; Ongoing
Similar to the formal program described above is the effort by Metro
and DOE to identify sites where toxic materials had been produced,
stored, or disposed of in the past. These sites may now contribute to
River and Bay contamination through storm runoff containing con-
taminated material or through leaching of toxics from contaminated
landfill and groundwater. DOE, Metro, and the City are particularly
watchful for evidence of such pollution from previous activities in
the industrial areas of Harbor Island and at the older port facili-
ties. While Metro and DOE have already dealt with several highly
contaminated sites, other less acute situations have appeared on
several occasions.
Metro staff also believe that it is very important to do additional
monitoring and toxics analysis of all Elliott Bay and Duwamish
permittees' discharges, and to use broad "indicator" tests for non-
permitted discharges (such as Total Organic Carbon and conductivity
tests) to trace toxic sources among them and potential new permittees.
DOE and Metro inspectors estimate that there are between 800 and 1000
nonpermitted discharges to storm drains or sanitary sewers which could
be regulated either by NPDES permits (possibly including general DOE
permits for contaminated runoff to storm drains or combined sewers) or
by Metro industrial waste permits for discharges to sanitary sewers,
and which should include enforceable toxicant limits. These non-
permitted discharges may include some with significant toxic loadings,
or leaching as significant as that found at the four storm drain sites
which Metro, DOE, and the City have already cleaned or designated for
clean-up in the very near future.
Activity; Hazardous Waste Site Clean-up
Sponsoring Agencies; EPA and DOE
Time Frame; Ongoing
The sites described below are designated for clean-up under Superfund,
State, or local hazardous waste cleanup programs. They may contribute
significant amounts of toxicants to the Duwamish River via surface
runoff or contaminated groundwater migration.
- A site owned by Western Processing, in Kent, may be a significant
source of toxicants to the Duwaish via runoff to the Green River
and Mill Creek, and through contaminated groundwater movement. A
remedial action plan has been developed for the site. The most
recent report on this site is CH2MHill's December 1984 "Final
Remedial Investigation Data Report, Western Processing, Kent, WA."
EPA leads the Superfund effort.
2-22
-------
- A Port of Seattle road construction project at Terminal 5 generated
tons of waste dirt contaminated with PNAs. Much of this dirt was
moved to twelve sites around King County, but was later retrieved,
and is now being stored at Terminal 105 under tarps. The remaining
dirt at Terminal 5 is uncontained, but is not considered a hazard-
ous waste. Port of Seattle studies for improvements at Terminal 5
(described in a later section of this chapter) have considered
various management plans for contaminated soils.
- Fugitive dust from the abandoned lead smelter has lead to inves-
tigations of lead contamination and ambient air quality standard
violations for lead around Harbor Island. The parking lot thought
to be causing the problem has recently been paved. DOE is respon-
sible for leading any additional Superfund action, and has hired
Black and Veatch to do a preliminary assessment of the site. The
City has requested that Harbor Island be removed from the Superfund
list.
- Metro, DOE, the City, Purdy Company, and Wyckoff are cooperating to
clean up a contaminated Florida Street storm drain. Metro and the
City have asked EPA to reimburse the City (via Wyckoff settlement
money) for clean-up work. The cleanup operation was conducted during
July and August, 1985.
Activity: Seattle Shoreline Master Program (SSMP)
Sponsoring Agency; City
Time Frame; 1977 - Present. Updated program will become effective
in 1986 or 1987
The Seattle Shoreline Master Program (SSMP) could become an important
regulatory tool for controlling nonpoint sources of toxic pollutants
to the lower Duwamish River and Elliott Bay. The City published its
draft SSMP, updating a 1977 version, in October 1984. SSMP, which
contains shoreline zoning and use regulations applying to any new
construction of over $1000 value, allows the City to regulate land use
in order to minimize toxic runoff from any site within the City's
shoreline zone (all land within 200 feet of the ordinary high water
line, and adjacent submerged lands). A major consideration in
drafting the new SSMP was to protect environmental quality while
promoting an acceptable level of commercial and industrial development
in the shoreline areas. Many of the conditions that both the existing
and draft SSMP impose on shoreline uses are formulated to mitigate
negative affects of otherwise desirable development, including the
possibility that shoreline activities will continue to be sources of
toxic pollution in the adjacent waters.
Under the draft plan, the Elliott Bay/lower Duwamish shoreline and
adjacent submerged lands include eight environmental designations.
Designations under the current Shoreline Plan include: Conservancy
Navigation; Conservancy Preservation; Conservancy Management; Urban
Stable; and Urban Development areas. Three new designations under
the draft plan include Urban Harborfront, Urban Maritime, and Urban
2-23
-------
Commercial. "Substantial development" of over $1000 in all shoreline
designations is regulated by a set of detailed land use and permis-
sible development conditions. While permissible uses in the Elliott
Bay/Duwamish shoreline will not be significantly different from
current uses, the shoreline permit process will allow the City to
review plans for any significant construction to ensure that impact of
chemical storage and spills on adjacent waterways is minimized.
Comments from other agencies are solicited and taken into account in
the permit review process. The existing SSMP can also be used to
control toxicants, although its language does not impart as broad and
explicit authority as the draft SSMP.
The proposed SSMP uses language taken from the DOE Shoreline Master
Program Handbook to establish criteria for permit review. The
language is general in nature and therefore would give the City
considerable authority to condition permits. Other standards in the
draft SSMP apply to dredging and dredge spoil disposal. While COE
dredging is exempt from shoreline permit requirements, the COE
generally abides by applicable standards set by the City.
Standards for each permissible use type may include conditions to
eliminate possibilities of toxic water pollution. For example, stan-
dards for cargo handling and manufacturing (existing ordinance
24.60.565), which apply to all port facilities and shoreline
manufacturing areas, specify that loading and unloading facilities
must be designed to reduce discharges of particles or particulates
related to industrial processes into the air or water. Applicants
must also show evidence that adequate means are available to treat or
clean up spilled materials. Other standards in the draft SSMP apply
to dredging and dredge spoil disposal. While Port and COE dredging is
exempt from some of these conditions, both agencies generally abide by
applicable standards.
Shoreline permit reviews are conducted by the City of Seattle's
Department of Construction and Land Use, which also reviews all
building permit applications in the City. The draft SSMP reflects the
City's shoreline management goals, contained in City of Seattle
Resolution 25173, and the City's shoreline management authority,
delegated by the State based on criteria of the State Shoreline
Management Act of 1971.
Upon State and City approval, the draft SSMP will become Chapter 23.60
of Seattle's Land Use Code. An Environmental Impact Statement (EIS)
for the program is currently being prepared, while the Mayor's
recommendation to adopt the program is expected in September 1985.
After that, a final EIS will be prepared and the City will hold public
hearings. If the City Council adopts the program, it will be for-
warded to DOE for State approval. It is expected that the new SSMP
will become effective in 1986 or 1987. While land use conditions con-
tained in the shoreline program will not be retroactive, most suffi-
cient structural changes after the adoption of the program will be
covered, because of the low $1000 threshold requirement for shoreline
permits for rehabilitation and construction in the shoreline district.
2-24
-------
As the new land use standards go into effect, they will be incor-
porated into shoreline zoning and building code inspections as a
matter of course. Seattle Department of Land Use and Construction
staff anticipate that SSMP standards will help control sources of
toxic runoff and spills, especially in the industrial and harbor
areas. With the cooperation of Metro and DOE inspectors, the stan-
dards could be used to control existing sources of toxic water
pollution when any new construction on existing sites is involved.
Activity; Grading and Drainage Code
Sponsoring Agency; City of Seattle
Time Frame: 1983 - Present
Seattle's Grading and Drainage Code (Chapters 22.800-22.806 of the
Municipal Code) of April 1983 requires that construction or devel-
opment involving significant regrading, or large enough to affect
existing drainage patterns, must have an approved drainage control
plan in order to get a building permit. One of the explicit purposes
of the code is to "protect streams, creeks, and lakes from... silta-
tion and other forms of pollution..." Section 22.802.040 of the Code
states that: "When it appears that pollution may be generated as a
result of the proposed development coverage, the Director of
Engineering may require provision within the Drainage Control Plan to
control, modify, limit or exlcude pollutants in the storm water runoff
from the subject property."
Development covering more than 5,000 square feet, if a drainage plan
has been required, entails a contract between the owner and the City
stating that the owner will carry out the approved drainage control
plan. Like the Shoreline Master Program, provisions in the Grading
and Drainage Code are not retroactive. However, the Code still
provides the City with a means to help ensure that new development
beyond the 200 foot shoreline district will not contribute additional
toxic runoff. Because the Code may cover some renovations at existing
sites, it allows the City to require appropriate berming of chemical
handling and storage areas, for example. The grading portion of the
Code, like the Shoreline Master Program, is administered by the City's
Department of Construction and Land Use, while the drainage portion is
administered by the Seattle Engineering Department.
Other agencies are routinely invited to comment on the City's master
use permit applications (if required by the State Environmental Policy
Act). As a result of coordination between the City, Metro and DOE,
the Grading and Drainage Code could become a major means of control-
ling toxic contamination from industrial and other urban runoff to
Elliott Bay and the Duwamish River. The Grading and Drainage
Ordinance is being revised by the City. A draft should be ready for
public review in late summer 1985.
2-25
-------
2.2 MANAGING CONTAMINATED SEDIMENTS
The contaminant source control programs described above will limit
current and potential toxicant contributions to Elliott Bay and the Duwamish,
but the question of how to deal with already contaminated sediments remains
unresolved. Issues concerning sediment remedial actions (e.g., dredging
and disposal of contaminated sediments) require long-term planning and
impact assessment beyond the scope of the Elliott Bay Interim Action Plan.
Nevertheless, many areas, with both heavily contaminated and relatively
clean sediments, must still be dredged periodically to allow for shipping
activities. The need to dredge and safely dispose of contaminated dredge
spoils from the East and West Waterways, the lower turning basin, and
Port of Seattle berths or slips, has lead to several sediment studies,
the beginning of disposal plans, and standards to regulate disposal
sites and practices.
Dredging activities in the Federal navigation channel and the Port
of Seattle include routine programs to maintain the depth of established
navigation channels and berths, immediate plans to expand berth and dock
facilities, and long-range plans to widen and deepen the navigation channel.
These dredging programs involve slightly different sets of toxicant-
related issues, all of which become increasingly complicated as the scale
of projects and amounts of contaminated sediments increase. Immediate
dredging plans include routine maintenance dredging and some port
facilities development.
2-26
-------
Activity; Four Mile Rock Disposal Site Standards
Sponsoring Agency: City of Seattle
Time Frame: 1985
The major open water disposal site for dredge spoils from Elliott Bay
and the Duwamish Estuary has been in the vicinity of Four Mile Rock,
located in northern Elliott Bay. As a result of years of dumping,
sediment contamination has increased in the surrounding area. Recent
sampling of sediments near Four Mile Rock (by Metro, DOE, NOAA, COE,
and EPA) shows significantly elevated levels of several metals and
toxic organic compounds. At some sampling points, concentrations of
several pollutants (including copper, lead, zinc, mercury, arsenic,
PCBs, and PAHs) exceed those found in all but the most highly con-
taminated sediments of the Duwamish.
Some negative effects on marine life have been detected in the area,
and have been attributed to elevated toxicant levels. EPA has set
interim standards for toxicant levels and sampling requirements for dredged
material to be disposed of at Four Mile Rock. In general, the criteria
prevent further deterioration of sediments and water quality in the
vicinity of the disposal site-.
The standards effectively preclude disposal at Four Mile Rock of
dredge spoils from certain areas of the Duwamish and Elliott Bay.
These areas include much of the West Waterway, the lower turning
basin, and some areas adjacent to contaminated storm drains and other
nonpoint sources.
The State Department of Ecology and Department of Natural Resources
were able to agree with EPA on guidelines that will allow the site to
be used only for "'clean" dredge spoils. The City of Seattle, as the
Shoreline Management authority, issued a conditional disposal permit
incorporating these guidelines in July 1984. However, private
citizens in the City contested the permit, and appealed it to the
State's Shoreline Hearing Board, which has final authority on all
issues subject to shoreline permits. Hearings on the permit were held
in January 1985. The State's decision in the spring of 1985 was to
allow continued use of the site in line with established criteria.
Thus, the Four Mile Rock site will accommodate COE and Port dredging
for the remainder of 1985. Citizens have appealed the Board's
decision to the State Superior Court.
Applications to dispose of dredge spoils at Four Mile Rock are to be
reviewed according to the procedures illustrated in Figure 3, included
in the City's shoreline permit giving conditional approval to the
site's use. Generally, in-water disposal criteria for Four Mile
2-27
-------
In-Wate
Disposal
Not
Utere Is
Location of
Chemical Testl ng
- Conventional
s
e *a
Moderate and High
Concern
Areas
Chemical Testing
- conventional
- H»avy Metals
- Priority Pollutants
Are wavy
Metals Concen-
ratlons Great-
er Than Ambient
Level s At The
4-Mile Rock
Hre Heavy Met-
ils and Priority
tollutant Conetn-
ratlons Greater
Than Ambient levels
it The 4-M11e
teck Site?
In-Water
CH sposal
t
/^proved
Are Oil and
Grease Concen-
trations Great-
er Than 0.11?
NO
Aapnlpod Bloassay
- Sed
sdiment Test
Chemical Testln
- Base/Neutral Prl orlty
Pollutants
xl>
Are Bas
se/Neutral
PHoHty Pollutant
Concentrations
Greater Than Ambient
Level s At The
4-Mile Rock Site?
NO
[$ the Mean Survival
Rate Greater Than Or
Equal To The Mean
Survival Rate At The
4-M11* Rotpk Site?
MO ^
^^
In-Water
Di sposal
Not
Approved
Oyster Larvae Bloassay
- Sedimentrest
[s The Mean MortaT-
ty/Abnormality Rate
Less Than Or Equal
Co The Mortality/
bnormallty Rate At
Ihe 4-Mile Rock Site?
NO | In-Water
[sposal
|Not Approved
In-Water Disposal Approved
FIGURE 3
DECISION PROCESS FOR DREDGE DISPOSAL AT FOUR MILE ROCK SITE
Source: EPA Region X
2-28
-------
Rock require the applicant to perform slightly more stringent testing
of sediments to be dumped if those sediments originate in areas likely
to be contaminated (i.e., "Moderate and High Concern Areas").
Activity; Toxicant Pretreatment Planning Study
Sponsoring Agency; Metro
Time Frame; Completed May 1984
An extensive sediment sampling program in TPPS provided additional
detail on lower Duwamish and Elliott Bay toxic "hot spots." Because
TPPS was aimed at helping Metro's facility and program planning for
its own collection, treatment, discharge, and sludge management
systems, it emphasized effects of toxics that might have passed
through Metro's collection system. TPPS used three indicators to
define areas with high priority toxicant problems: 1) those found to
have high toxicant concentrations; 2) those with documented biological
disruptions; and 3) those with important resources or uses that could
be impaired by high toxicant levels. These areas were designated as
high priorities with regard to future actions to control toxics,
including the elimination of sediment problems.
TPPS chemical analysis of the water column and sediments identified
highly contaminated sediments in the East and West Waterways, along
the Elliott Bay side of Harbor Island and Port areas to the north and
south, and in areas of receiving waters from Seattle's major CSOs in
Elliott Bay. TPPS analyses also confirmed elevated levels of several
metals, PCBs, and pesticides in the sediments surrounding the Four Mile
Rock Disposal Site. Because of Metro's orientation, TPPS recommendations
concentrated on steps which Metro could take to eliminate future toxic
burdens to the "hot spots" rather than eliminating the toxicants already
found in sediments there. However, these findings contributed to dredge
spoil disposal planning by other agencies.
Activity: Short-term Dredging Plans
Sponsoring Agencies; Port of Seattle and COE
Time Frame: 1985 - 1986
Dredging by the Port of Seattle and COE is not designed specifically
to remove or contain contaminated sediments. However, both clean and
contaminated sediments may be encountered during such projects and appro-
priate procedures for assessment, removal, and disposal of contaminated
sediments must be followed. The Port has already applied for dredging and
dredge spoil disposal permits for several projects in 1985. Resolving
the twin issues of appropriate disposal sites and safeguards for the
disposal of dredged material are crucial to carrying out any of the Port's
and COE's immediate plans to conduct four projects:
2-29
-------
- COE maintenance dredging of the navigation channel and turning
basin
- Port "short-fill" of the area between Piers 90 and 91, using
contaminated dredge spoils
- Port maintenance dredging at Terminals 30, 115, and 105
- Port dredging at Terminals 28 and 30, and an extension of the apron
at Terminal 30.
All of these projects have been planned with the assumption that
uncontaminated dredge spoils will be disposed of at Four Mile Rock.
Implementation of COE and Port plans for routine dredging (conducted
annually, in some areas), which also removes some contaminated
sediments from the Duwamish River and the Waterways, are subject to
two separate but concurrent permitting processes for shoreline
permits and for "404" dredge and fill permits. In principle,
shoreline permit reviews take place concurrently with the standard
Federal 404 reviews by the Corps of Engineers. Approval of the Port's
dredging and filling projects follows the general procedures
illustrated in Figure 4. When the Port applies for its shorelines
permit, it also applies to the COE for a Federal 404 permit, which
incorporates City and State decisions. The COE public notice for the
404 dredge and fill permit serves as the application for the State
Hydraulic Permit and for the 401 water quality certification as well.
Attached to the public notice of permit application is the notice of
application for the State water quality certification.
COE makes its final decision based on its own assessments, and
considers reviews by other Federal and State agencies, Indian tribes
(the Muckleshoots, in the Seattle area), and the public. Federal
agencies which evaluate dredge and fill proposals include EPA,
the Fish and Wildlife Service, and the National Marine Fisheries
Service. In addition, the Corps' final decision takes into
account the State response, coordinated by the Washington DOE.
(The Coordinated State Response incorporates reviews by DOE, the
Departments of Game and Fisheries, and DNR). Washington DNR is also
responsible for leasing designated sites to tenants, including other
public bodies, wishing to use them for dredge spoil disposal.
The lag time on some permit applications may be a year or longer.
However, it is possible that once review criteria like the Four Mile
Rock guidelines are standardized and confirmed by appeal to the State
Superior Court, the entire review process may be shortened.
2-30
-------
Appl leant
APPLICATION
Appl(cation for
Corps Permit
Appl(cation for
Shoreline* Permit
\'
Corps of Engl
Cltv of County
Local Govt
Public Notice
Issued (Note: This Public Notice also
tar«* as the the application lor
ttw Hydraulic Permit and 401 Certification
i
ME ICY
REVIEW
Envl
ntal U.S. Fish i
Protection
Agency
wlldtlfa
Service
OJ
STATE
PERMIT
DECISION
FEDERAL
PERMIT
DECISION
\ r
Corps
National
Marine
Fisheries
Service
Others;
FediState
Agencies,
Adjacent
Landowners,
Interested"
Individuals,
Indian ""
Nations
V V
Department
ol
Department
of
Department
of
Fisheries
HydraulIc
Penult
Rev I en
\ I
Department
Hydraulic
Pmralt
Rev Ien
\f
of
Department
of
Ecology
401
Hater Quality
Certification
Aquatic
Lands
and
Open Mater
Disposal
Issues
Ecology
Coordinated
State
Rev I en
of the local
Authority's
decision
Response
ot
Engl
Permit
Revleo
Penult Issued or Denied
FIGURE 4
404 (DREDGE AND FILL) AND SHORELINE PERMIT PROCESS
Source: EPA Region X
-------
Activity; Disposal of Contaminated Dredge Spoils - Piers 90/91
Sponsoring Agencies; Port of Seattle and COE
Time Frame; 1985 - ongoing
Separate from the Four Mile Rock site criteria is the question of what
to do with dredge spoils too contaminated for disposal at Four Mile
Rock. The Port and COE estimate that this might include a consider-
able portion of the upper sediment layer to be dredged for Port and
COE maintenance purposes as well as for expansion of harbor facilities
planned over the next three to five years, such as proposed expansion
at Terminals 28 and 30.
The Port currently has plans to dispose of material too contaminated
to meet Four Mile Rock criteria for open water disposal at a "short
fill" site that would cover approximately six acres, 700 feet along
the area between Piers 90 and 91. While the Port would like to
reserve this site for contaminated material from its own and COE
dredging, it will dispose of "clean" material there as well, if the
Four Mile Rock site is closed in the future. Approval of the 90/91
site appears to be imminent, and DOE has drafted tentative permit
conditions which will ensure that toxic substances contained within
the site do not leach to Elliott Bay or to groundwater.
Washington DOE's draft 401 water quality certification for the Pier
90/91 site includes permit requirements for chemical analysis of fill
material, and DOE approval of a monitoring plan and threshold levels
for contaminants leached from the site (expected mid-summer 1985).
The draft requirements would allow the Port to begin berm construction
at the site (with "clean" material) by late summer 1985. The final
shoreline permit has been issued by the City of Seattle. The "404"
permit, to be issued by COE, may still require the Port to provide
some level of "mitigation" for lost habitat.
The approval of all permits necessary for the Port to dredge and
dispose of dredged material involves cooperation among several agen-
cies, including DOE, the City, DNR, the Port, COE, State Departments
of Fisheries and Game, and various other parties including the
Muckleshoot Indian Tribe. In addition, the timing of permit approvals
is crucial to the feasibility of proposed dredging of contaminated
sediments. Dredging of the East and West Waterways and the turning
basin may not take place during the salmon spawning season. If
dredging does occur before spring high flows, flushing of Duwamish
sediments into Elliott Bay may be reduced. The Port has no formal
plans for maintenance dredging, but must apply to COE for 404 permits.
Annual COE and Port dredging and disposal costs have been approxi-
mately $500,000, using the Four Mile Rock site for dredge spoil
disposal. These costs are expected to increase substantially although
the Pier 90/91 short fill site would be the least costly of potential
alternatives for disposing of contaminated sediments.
2-32
-------
If the Pier 90/91 site is not available to dispose of contaminated
dredge spoils, an alternative upland site will be developed. The
Port asserts that disposal at an upland site is the least desirable
alternative, both because of excessive cost and because moving
saline sediments to a nonsaline environment may increase the risk
of toxic or saline leaching. The Port expects to dispose of appro-
ximately 190,000 cubic yards of contaminated dredged material at the
Pier 90/91 short fill by March 15, 1986, and about 180,000 cubic
yards of "clean" dredge spoils at Four Mile Rock.
Activity: Plans to Expand Pier and Berth Capacity
Sponsoring Agency: Port of Seattle
Time Frame: 1985 - 1990
Several construction and dredging projects proposed by the Port of
Seattle will remove toxic sediments from Port waterways, seal areas
from which toxic leachate is now entering the Duwamish or Elliott Bay,
or potentially aggravate current leachate problems. Testing and
planning for disposal of contaminated dredged spoils have been
important aspects of planning- for all of these projects. Major
projects planned for the near future include:
- Improvements at Terminals 28 and 30, involving dredging along Pier
30 shoreline and building structural supports around an extended
container apron. About half of the 130,000 cubic yards of material
to be dredged is expected to meet Four Mile Rock disposal criteria
and will be disposed of there if the site is reopened in time for
work to proceed. The other half, contaminated by the site's former
use as a tank farm, must be moved either to the Pier 90/91 short
fill site, if it is approved, or upland to a site at Pier 32. The
Port estimates that sampling and analysis necessary for this
project will be as expensive as the actual dredging itself, at
about one dollar per cubic yard.
- Dredging at Terminal 32, involving some contaminated sediments
- Extension of the apron at Pier 5, involving dredging and disposal
of approximately 20,000 cubic yards of potentially contaminated
material
- Shoreline straightening at Pier 105, involving about 230,000 cubic
yards of dredged material along a 1000-foot-long shoreline
- Several other pier improvement projects during the 1987-1990
period.
2-33
-------
Activity; Corrective Action for Other "Hot Spots"
Sponsoring Agency; Metro
Time Frame; 1985 - ongoing
The 1983 Duwamish Clean Water Plan stated that, during the 1970 to
1980 period, the majority of toxic pollution load was due to ongoing,
uncontrolled sources, later addressed by the Duwamish Industrial
Nonpoint Source Investigations. The Plan did not address the toxicant
loading to the Duwamish from the Renton sewage plant, since the Plan
assumed that the Renton outfall would be removed from the Duwamish in
the near future.
The Duwamish Clean Water Plan does recommend that maintenance dredging
be continued, however, in part so that contaminated river sediments
will not continue to be carried into Elliott Bay in an uncontrolled
manner. Combined with Metro's recommendations in the Duwamish plan,
TPPS, and the Duwamish industrial investigations, all aimed at
controlling current sources of toxics, it is assumed that dredging and
natural deposits of cleaner sediments would eventually clear up or
cover sediments contaminated by past activities.
Activity; Plans for Widening and Deepening the Federal Navigation
Channel (see Figure 6)
Sponsoring Agency; COE
Time Frame; Planning studies ongoing; implementation depends on plan
completion and Congressional approval
In January 1983, the Corps published the "Final Feasibility Report and
Final Environmental Impact Statement for the East, West and Duwamish
Waterways Navigation Improvement Study." The Environmental Impact
Statement (EIS) cited several studies of lower Duwamish sediment
chemistry and confirmed that some of the areas for which major
dredging was proposed contained high levels of several priority pol-
lutants. Tests conducted for COE by AM Test, Inc. in 1980 showed that
the top layer of sediments from several areas of the East and West
Waterways, in particular, contained levels of several metals, pesti-
cides, and other contaminants high enough to be harmful to aquatic
life. Other studies cited in COE's Environmental Impact Statement
(e.g., Stout and Lewis, 1977) indicated that sediments in the Duwamish
navigation channel contained levels of PCBs, pestcides, and other
chemicals possibly high enough to be toxic to benthic organisms, but
that these chemical concentrations decreased in the deeper sediments
tested.
2-34
-------
ho
I
CO
ELLIOTT
BAY
1REOQE TO SOO FT
WIDE. 39 FT. OEEI
WIDE.
OEAUTHOHIZE
TUHHMB RA8M
HO. 2
DREDGE TO 281 FT. WIDE. 31 FT. DEEP
UPSTREAM LIMIT OF
EXISTMB FEDERAL PROJECT-
CONITRUCT (HALLOW WATER
HABITAT FOR FISHERY
MITIGATION AND ENHANCEMENT
tMrlu* 8«llll«|
H»4
SCALE IN FEET
I OOP 0 5OOO
LEGEND
PROPOSED CHANNEL ENLARGEMENT
BULKHEADS
RIPRAP SLOPE PROTECTION
FIGURE 5
PROPOSED EAST, WEST, AND DUWAMISH WATERWAYS NAVIGATION IMPROVEMENTS
Source: U.S. Army Corps of Engineers, Seattle District
-------
Public comments on the EIS tended to agree with COE that toxicant
levels in sediments to be dredged would warrant additional testing in
the next stage of COE planning, calling Continuation of Planning and
Engineering (CP&E). In the meantime, 404 permits also require that
the lower Duwamish sediments to be dredged must be tested for toxics.
The CP&E process is expected to last two to four years and lead to the
preparation of a general design memorandum for the project. Environ-
mental quality issues to be addressed in this CP&E phase include an
assessment of management alternatives for contaminated sediments and
an evaluation of aquatic and benthic habitats that would be affected
by proposed large-scale dredging involved in the widening and deep-
ening project.
As part of the CP&E process, the Corps is studying sediment management
and disposal. These studies may be valuable to the interagency plan
of action for the Duwamish. The studies include baseline chemical and
biological testing. COE will analyze existing data on sediments
within the proposed project area, obtain additional data through
sediment core sampling, and perform the sediment characterization
studies, including physical, chemical and biological testing,
necessary to identify which sediments proposed for dredging are
contaminated. Using criteria developed by the Puget Sound Dredged
Disposal Analysis (PSDDA), the volume of sediment suitable for open
water disposal and that requiring confinement will be determined. For
those sediments requiring confinement, contaminant mobility tests will
be performed to determine characteristics of the material and
appropriate disposal designs.
- Sediment tests will be conducted to address general constraints and
requirements needed for nearshore, upland, and possibly capping
disposal options.
- Disposal site identification, evaluation, and selection. The Corps
and the Port of Seattle (the Port as local sponsor for the project
is required to provide acceptable disposal areas) will reevaluate
the sites considered in the Final Feasibility Report/EIS in light
of the results of the baseline testing and PSDDA. For those sedi-
ments requiring confined disposal, consideration will be given to
nearshore, upland, and confined aquatic disposal areas. Detailed
engineering and environmental tests and evaluatios will be made of
a selected site or sites to develop design criteria for equipment
selection, material placement, containment effectiveness and
monitoring requirements.
Activity; Environmental Impact Statement for the Puget Sound Dredged
Disposal Analysis Study
Sponsoring Agencies; COE/EPA/DOE/DNR
Time Frame; Phase I (including Elliott Bay) available late 1986
Phase II available late 1987
The Puget Sound Dredged Disposal Analysis is a three-year study of
open water, unconfined disposal of dredged material in Puget Sound.
2-36
-------
The study was developed in response to public and agency concerns
about the long-term health of the Sound in order to provide the basis
for publicly acceptable and environmentally safe plans for unconfined
disposal of dredged material. It is being undertaken, as part of the
Puget Sound Initiative, as a cooperative effort among the State and
Federal agencies with regulatory responsibility for dredge spoil
disposal (COE, EPA, DOE, and DNR).
The objectives of the study are:
- Locate acceptable sites for open water, unconfined disposal of
dredged material in Puget Sound
- Identify evaluation procedures to assess the acceptability of
dredged material for open water disposal, and for alternatives to
unconfined disposal
- Formulate open water disposal site management plans for Puget
Sound sites.
In order to assess the potential impacts of several alternatives and
to obtain public input for these assessments, COE and Washington DNR
have determined that it is necessary to prepare an Environmental
Impact Statement for each of the study's two phases. The first phase
will include the Central Sound and take about two years to complete;
the second phase will cover the rest of the Sound, begin about a year
after the start of the first phase, and also take about two years.
The results of the study and the Environmental Impact Statement (EIS)
will assist State and Federal agencies in regulating dredged material
disposal. They will also provide a comprehensive basis for subsequent
designation and use of Puget Sound disposal sites. The EIS will
address water quality management goals for Puget Sound, management of
contaminated sediments, alternatives to open water, unconfined dis-
posal, alternative approaches to testing and evaluation procedures for
dredged materials, and needs for monitoring and managing disposal
sites. The draft EIS for the Central Sound phase of the study
(including Elliott Bay and the area around the Four Mile Rock site) is
scheduled to be available by the end of 1986. The draft EIS for the
other areas should be available by the end of 1987.
2-37
-------
3. ASSESSMENT OF EXISTING PLANS AND ACTIVITIES
ADDRESSING TOXICANT PROBLEMS
In this chapter, cleanup plans and actions are examined in terms of
their potential to resolve toxic contamination problems over the short
term (during the interim Elliott Bay Toxics Action Plan period, 1985-1986)
and the long term (after 1986). Table 6 lists current and expected levels
of activity and the timing for plan implementation. Gaps in existing programs
or plans are also identified in this chapter.
3.1 MUNICIPAL POINT SOURCES
Activities that will reduce the effect of toxicants from municipal
treatment plant effluent in 1985 and 1986 include
WDOE issuance of final NPDES permits for Renton and West
Point plants, which will require secondary treatment
the reissued West Point permit (being drafted in 1985) may
contain additional toxicant limits and monitoring requirements.
(Permit requirements are being set by WDOE, with close oversight
by U.S. EPA.) Final limits for the Renton plant require
effluent to be diverted from the Duwamish River to Puget
Sound.
Intensification of WDOE's permit compliance efforts, and
the possibility of issuing additional NPDES permits for
contaminated stormwater discharges
METRO'S Renton treatment plant expansion (to increase treatment
capacity from 36 million gallons per day [MGD], to 72 MGD)
and effluent diversion projects to be under construction
in 1986
3-1
-------
TABLE 6
REMEDIAL ACTIVITIES AND PLANS FOR TOXICANT CONTROL
Problems
Municipal Point
Sources
Toxicant Input to
Treatment System
Ongoing Activities
EPA: Oversee West Point &
Renton permit relssuance
Metro/EPA: Coordinate
pretreatment program
actions
City: Water supply
corrosion control program
Metro: Household hazard-
ous waste program
Efforts to
Strengthen Ongoing
Activities
Metro: Capital program
projects
DOE; Reissue NPDES
permits; possible
toxicant limits
Metro: Improve enforce-
ment of pretreatment
requirements & other TPPS
recommendations, Metro/
DOE additional toxicant
research
Planning:
Implementation
1985-1986
Metro; Renton effluent
diversion & expansion;
other capital Improve-
ments
Metro: Upgrade
toxicant analysis
capabilities
Planning:
Implementation
After 1986
Metro: Upgrade West
Point to secondary
DOE: West Point
compliance schedule
u>
S3
Combined Sewer
Overflows
Nonpolnt Sources
Control CSOs
Metro: Duwanlsh Indus-
trial nonpolnt source
investigations
DOE; CSO control compli-
ance schedules In reis-
sued NPDES permits
Metro: Upgrade CATAD &
expand Renton plant
(construction phase)
City: Updated Shore-
line Program
City: Updated Shore-
line Program
City/Metro: Elimi-
nate CSOs
General toxic
atormwater dis-
charges
City: Grading and
drainage reviews
Metro/DOE: Contaminated
storm drain investiga-
tions
City: Updated Shore-
line Master Program
Toxic spills and
contaminated
groundwater
Dredge spoil dis-
posal and sediment
management
DOE/Coast Guard/Metro/
EPA/City/Port: Spill
response & clean-up
Port/COE: Maintenance
dredging of port &
navigation channel; EIS/
studies of dredge spoil
disposal and management
options
DOE/EPA/Metro! Spill
regulation enforcement
Metro: Duwamlsh Basin
groundwater transport
studies
COE/DOE/Metro/EPA;
Studies of toxicant and
sediment transport;
studies of effects on
water column and benthlc
populations
Port; Environmental
studies for Port
facilities expansion
Port; Containment or
removal of material In
construction
EPA/DOE: Superfund
clean-up (3 sites)
City/EPA/DOE: Reopen
Four Mile Rock site
with 1984 criteria
Port/City/DOE/EPA:
Develop Pier 90/91
short fill site
Port/COE: Maintenance
dredging of channel &
berths
COE: Sediment
evaluation for
widening & deepening
project
-------
Incremental projects included in METRO'S adopted capital
expediture program.
Plans to be implemented after 1986 that will reduce the impact of
municipal treatment plant effluent include
Construction to upgrade METRO'S West Point and Alki plants
to secondary treatment (by 1991)
Completion of the Renton plant expansion and effluent diversion
projects.
The Renton projects are expected to reduce the impact of toxic effluent
in the Duwamish River (below the current outfall) as soon as late 1986.
However, the full effects on Elliott Bay of the treatment plant upgrades
will not be felt until after 1991. While METRO has made a firm commitment
to undertake these upgradings, the precise impacts of treatment plant improve-
ments on toxicant loadings to Elliott Bay are not certain. Also, while
METRO has committed to eliminating the Renton effluent from the Duwamish
River, changes in plans for the new outfall have led to significant delays
in construction. The outfall will probably not be complete by the end
of 1986, and thus will not lead to reductions in toxic loadings to the
Duwamish River in the immediate future.
3.2 COMBINED SEWER OVERFLOWS
Controlling CSOs will eliminate significant toxic loadings to Elliott
Bay and the Duwamish River. In the vicinity of some CSO outfalls, there
are sediment "hot spots" which have documented negative impacts on aquatic
populations. CSO control is especially important in the East and West
Waterways, northern Elliott Bay, and at Michigan Street on the Duwamish
River.
3-3
-------
The key activities that will be carried out in 1985 and 1986 to reduce
the impact of toxicants from CSOs are
Improvements in CATAD system hardware to increase in-line storage
Integration of CATAD with treatment plant operation controls
Revised CSO compliance schedules contained in reissued NPDES
permits (now being drafted).
Current planning activities that may reduce toxicant loadings from CSO
discharges after 1986 include
Diversion of the City of Seattle's stonnwater component
(from lower Rainier Valley) from the Hanford CSO to the
Diagonal Way storm drain. The diversion, to be completed
in 1987, will reduce CSOs at Hanford and Lander.
Stormwater diversion resulting from the Renton treatment
plant expansion
Use of City of Seattle's new shoreline and grading and drainage
code provisions to prevent toxic runoff
Elimination of additional CSOs or complete elimination of
CSOs.
Past water quality management efforts of METRO and WDOE emphasized
protecting Lake Washington and freshwater streams. As a consequence, there
was increased reliance on the use of northern Elliott Bay CSOs. If the
Denny Way CSO and other northern Elliott Bay CSOs continue to be heavily
used, it is unlikely that sediment conditions (or water quality during
storm events) will improve at these sites.
The most significant gap in current plans and activities addressing
point source toxic contamination to the Duwamish and Elliott Bay, is the
3-4
-------
lack of a firm commitment to eliminate CSO. Although METRO'S "baseline"
in facilities planning is to avoid aggravating the CSO problem, its current
budget and policy place a low priority on the complete elimination of Elliott
Bay CSOs. In fact, some of METRO'S planned alternatives would result in
increased flows at the Denny Way CSO.
Currently, the WDOE Administrative Order under which METRO is proceeding
with facility planning for its treatment plants does not include conditions
explicitly requiring CSO elimination, although CSO elimination will be
required under state law. Eventually, a compliance schedule for CSO elimination
will be incorporated into METRO'S NPDES permit requirements. As of mid-1985,
however, METRO had not firmly committed to eliminating Elliott Bay CSOs
in the near future.
At the same time, major improvements in METRO'S CATAD computer system,
which promise to reduce CSOs, have been repeatedly postponed. CATAD reduces
overflow rates significantly (especially in the Duwamish basin), except
in emergencies. Improvements to CATAD would further reduce CSOs in the
Duwamish basin. These improvements, however, are becoming increasingly
linked to plans for treatment plant upgrading. Integrating CATAD with
plant improvements will help reduce CSOs in the short-term. However, the
long-term elimination of CSOs remains to be addressed in a direct manner.
3.3 TOXICANT INPUT TO METRO'S TREATMENT SYSTEM
METRO'S major tool to control toxicants entering its treatment system
is the industrial pretreatment program. U.S. EPA has recommended that
METRO'S pretreatment staff intensify enforcement activities. In addition,
METRO'S TPPS reports, which documented toxics movement throughout METRO'S
system, make detailed recommendations for improving METRO'S toxicant control
programs and raise many questions which merit future investigation. The
household hazardous waste program also focuses on controlling toxic pollutants
in METRO'S system by alerting domestic users against disposing of toxicants
in the sewers. In addition, the City of Seattle has reduced metals in
wastewater by reducing the corrosiveness of city drinking water.
3-5
-------
Activities that will reduce the level of toxicants entering METRO'S
treatment system in 1985 and 1986 are:
Continuation of METRO'S pretreatment and household hazardous
waste programs, and the City of Seattle's water supply corrosion
control program
Carrying out recommendations of METRO'S TPPS reports, including
an update of METRO'S industrial user data and increased
monitoring efforts
Intensified efforts to enforce METRO'S industrial pretreatment
requirements
Additional research on toxicants in the treatment system
carried out by METRO (in cooperation with WDOE), in part
based on questions raised by TPPS
METRO'S plans to increase its in-house laboratory capabilities
for toxicant and water quality analyses.
These measures will reduce the amount of toxicants entering the Duwamish
River and Elliott Bay from emergency overflows as well as from treatment
plants.
Effective enforcement of the industrial pretreatment program, including
its spill prevention provisions, has the greatest potential for reducing
toxicant loadings to receiving waters in the immediate future, before METRO'S
major capital improvements are completed. Implementation and improved
enforcement of the pretreatment program will gain more importance as other
treatment plants convert to secondary treatment, as this process is more
sensitive to disturbances from toxicant inputs than primary treatment.
The continued success of the pretreatment program largely depends
on the ability to identify new and potential sources before they start
discharging to the collection system. There is currently no formal program
3-6
-------
for METRO and WDOE to coordinate with city and county licensing and permitting
programs to screen new and/or converted businesses in METRO'S service area
for possible toxicant inputs.
3.4 NONPOINT SOURCES
Two planning programs may significantly reduce toxic runoff from industrial
areas in 1985 and 1986:
Continuation of the Duwamish Industrial Nonpoint Source
Investigations and enforcement
Implementation of Seattle's current Shoreline Master Program
and Seattle's Grading and Drainage Codes.
The Duwamish Industrial Nonpoint Source Investigation has resulted in some
changes in toxic material handling. Similar results may be expected from
the continuation of the program in 1985 and 1986.
Under Seattle's existing shoreline plan, the city has broad authority
to grant construction permits (for projects with over $1,000 value), with
conditions which may have the effect of reducing the input of toxic contaminants
to the Duwamish River and Elliott Bay. However, these permits have rarely
been used for this purpose. Seattle's proposed Shoreline Master Program,
if approved and implemented, along with grading, drainage, and other city
code requirements, could have important benefits for water quality. The
proposed program will probably not be implemented until late 1986 or early
1987. In the meantime, the city's implementation and enforcement capabilities
are limited by its one-person shoreline inspection staff. Implementation
could be improved through the routine coordination of all city permit and
inspection processes to ensure that the existing shoreline program's water
quality protection provisions are carried out.
3-7
-------
3.4.1 Stormwater Discharges
METRO, WDOE, and the city of Seattle cooperate in investigating and
cleaning up highly contaminated storm drain sediments that affect receiving
water quality during storm events. The city may also enforce its grading
and drainage ordinance if contaminated storm water is expected to result
from new construction. Activities expected to reduce contaminated Stormwater
runoff to Elliott Bay and the Duwamish River include
Continuation of city reviews of grading and drainage activities,
and enforcement of permit provisions
More emphasis on investigations of contaminated storm drains,
with WDOE enforcement.
Runoff control provisions in plans and permits for new construction
are being reviewed and implemented in 1985 and 1986. The provisions will
be imposed and enforced through the city of Seattle's construction permit
process, but will not immediately incorporate changes based on the city's
proposed shoreline program.
Traditionally, control over toxicants in Stormwater discharges has
been limited to the separate efforts of the city and WDOE to control runoff
in general. Only recently has coordination been encouraged between relevant
programs of WDOE and the City of Seattle. Formalized, direct lines of
communication between the city's Department of Construction and Land Use
and WDOE's regional offices would facilitate the control of toxicants from
this source.
METRO and DOE have had major roles in cleaning up contaminated storm
drains and tracing contaminant sources. Although city personnel have been
cooperative in tracing drainage systems and in performing actual cleanup
operations, participation in source investigations by the city engineering
department has been limited by available funds. Development of Stormwater
treatment and drainage system maintenance programs is needed.
3-8
-------
Another nonpoint control measure, NPDES general permits, could offer
another means of regulating stormwater runoff. However, WDOE has not yet
developed a consistent strategy for using NPDES general permits to control
the quantity and quality of storm water. A strong commitment by U.S. EPA
to support funding and implementation of this program is lacking at present.
Further, when WDOE begins to use general NPDES permits to control stormwater
discharges (especially from privately-owned storm drains), the city may
need to become an active partner in using the Building and Drainage Code
to support WDOE's discharge permit requirements. To date, such cooperation
has rarely been undertaken.
3.4.2 Toxic Spills and Contaminated Groundwater
WDOE, METRO, U.S. EPA, the Coast Guard, the Port of Seattle, and municipal
fire departments can all be involved in emergency responses to toxic spills.
No major changes in response strategies are planned at this time. Programs
and activities that may reduce toxic contamination of Elliott Bay and the
Duwamish River from toxic spills and the leaching of contaminated groundwater
include
Continuation of interagency emergency spill response cooperation
WDOE, U.S. EPA, and METRO enforcement of toxic spill regulations
Containment or removal by Port of Seattle of material contami-
nated by past spills
Cleanup of Superfund and other hazardous waste sites
METRO'S groundwater transport studies.
These programs combine emergency response with long-term investigation,
enforcement, and cleanup. The emergency response activities are undertaken
as needed, although different agencies take the lead under various circum-
stances.
3-9
-------
The Port of Seattle facility development plans include removal or
containment of contaminated material from construction sites (e.g., Piers
5, 28/30, and other projects), but these plans continue to highlight the
need for appropriate disposal sites. Removal of toxic material, along
with testing - which the Port is required to conduct for any major earth-
moving and dredging activities - will help document the extent of contamination
and need for cleanup on Port of Seattle property.
The Duwamish basin groundwater transport studies, recently released
by METRO may allow METRO, the Port of Seattle, and private landowners to
focus future cleanup activities on land with contaminated groundwater.
Studies and plans regarding hazardous waste sites that may affect Duwamish
or Elliott Bay water quality should be completed by late 1986. Decisions
on cleanup needs and schedules for these sites will be made, and cleanup
should be in progress by late 1986.
Officials from several agencies are concerned about the need to ensure
more systematic cooperation in emergency cleanup situations, especially
when more than one agency could take lead responsibility. Another concern
centers on the time consuming nature of emergency cleanups. WDOE district
staff are often responsible for leading both emergency cleanup efforts
and later investigations or enforcement activities against perpetrators
of spills. Emergency responses and subsequent monitoring and inspections
often take precedence over routine facilities inspections and the less
acute toxicant violations. There is a need to devote more attention to
investigating the less acute problems.
3.4.3 Dredge Spoil Disposal and Sediment Management
Formulating standards for contaminated dredge spoil disposal and managing
both dredged and in-place sediments raises many unresolved issues. Sediment
issues are complicated by the uncertainty about the effects of contaminated
sediments on aquatic populations. Also, disposal of highly contaminated
material is still very much an unresolved issue. There is a great need
for agencies to work together in designing and implementing sediment management
strategies. Such cooperation may prevent the navigation-oriented activities
3-10
-------
of the Port of Seattle and COE from conflicting with water and sediment
quality management needs of WDOE, U.S. EPA, and other agencies with environ-
mental protection mandates.
Activities that will affect contaminated sediments in the Duwamish
River and Elliott Bay in 1985 and 1986 include
Port of Seattle and COE maintenance dredging of the Federal
Navigation Channel and berths
Decision on the use of the Four Mile Rock Disposal Site
Decisions for development of Pier 90/91 short fill site
Studies of toxicant and sediment transport
Port facility expansion at Piers 5 and 28/30.
Current planning and activities that may affect contaminated sediments
after 1986 include
Results of COE, WDOE, METRO, U.S. EPA, and other studies
of the relationship between contaminated sediments and adverse
effects on biological communities
Decisions on appropriate sites for the disposal of contaminated
dredge spoils and development of criteria for disposal sites
Implementation of COE navigation channel widening and deepening
plans
Puget Sound Dredged Disposal Analysis EIS.
Many of the studies being conducted for projects still in planning
stages (such as development of dredge spoil site evaluation criteria, "capping"
contaminated sediments, maintenance dredging, and port development activities)
3-11
-------
will affect some decisions related to other water quality and cleanup issues.
Staff of all agencies involved in sediment issues expressed a desire to
generate enough information so that sound, comprehensive dredge spoil policies
and long-term cleanup plans for contaminated sediments could be developed.
Currently, there is a major need to develop a long-term sediment management
plan for Puget Sound. Completion of the Puget Sound Dredged Disposal Analysis
Study will contribute greatly toward this end.
3-12
-------
APPENDICES
-------
APPENDICES
-------
APPENDIX 1
AGENCY STAFF INTERVIEWED
City of Seattle
Elsie Hulsizer Project Manager
Shorelines Management Program
Department of Construction and Land Use
Municipality of Metropolitan Seattle
Jeff Bauman Manager
Analysis, Special Projects and Field Activities Division
Water Quality Division
Tom Hubbard Water Quality Planner
Water Resources Section
John Lampe Superintendent of Water Quality
Bill Nitz CATAD System Coordinator
Port of Seattle
John Dohrmann Senior Environmental Planner
Douglas Hotchkiss Oceanographer
U.S. Army Corps of Engineers
Gail Arnold Biologist
Environmental Resources Section
Forest Br.ooks Project Manager
Civil Project Management Section
Burt Hamner Environmental Resources Section
U.S. Environmental Protection Agency, Region X
John Armstrong Senior Science Advisor
Office of Water
Martha Burke Community Involvement Coordinator
Bruce Duncan 301(h) Coordinator
Permits and Compliance Branch
-------
APPENDIX 1 (Continued)
AGENCY STAFF INTERVIEWED
U.S. Environmental Protection Agency (Cont.)
Carl Kassebaum Dredge and Fill Coordinator
Elbert Moore Nonpoint Source Coordinator
Bob Robichaud Pretreatment Coordinator
John Underwood Chief
Office of Puget Sound
Washington Department of Ecology
Gary Brugger Water Quality
Northwest Office
Mary Kautz Environmental Quality Coordinator
Northwest Office
Stuart Messman Northwest District Supervisor
Joan Thomas Northwest District Director/
Chairperson of Inter-Agency Work Group
Jim Thornton Operations Planner
Office of Operations (Olympia)
-------
APPENDIX 1
ELLIOTT BAY ACTION PLAN DEVELOPMENT
QUESTIONS ON PLANNING AND REMEDIAL ACTIVITIES
EPA Contract No. 68-O3-1977
JRB Project No. 2-834-O7-146-OO
Interview Date:
Name
Program
Agency
Address
Phone
1. What are the major problems or issues of concern to you
with regard to eliminating toxic contamination of
Elliott Bay? (Current and future)
2. Who ought to be addressing these issues in planning and
program implementation in the near future?
3. Identify your programs or planning activities which
may have remedial effects on toxic contamination of
Elliott Bay waters or sediments.
4. What regulations or statutory authorities define the
nature or scope of these activities?
5. If these planning activities, programs, or
policies are aimed at particular areas of Elliott Bay.
identify these areas.
6. If specific benchmarks or objectives of planning
activities (or programmatic equivalents) have been
identified, what are they?
7. Are copies of relevant planning and policy documents
available?
8. What other specific benefits, besides the reduction
of toxic contamination levels, will be associated with
these activities?
9. What is the time frQme for each major planning or
remedial activity?
1O. What staff from your agency are involved?
11. What other agencies are participating or cooperating in
these activities?
12. What other agencies have oversight responsibilities for
these activities? Through what means is their input
considered?
13. What is the anticipated implementation period for each
major plan component, recommendation, or remedial
activity?
-------
14. Who is responsible for implementation?
15. What other bodies could be important in ensuring that
plans, programs, or recommendations are carried out?
(Agencies, local governments, nongovernmental entities,
etc. )
16. What other agencies, local government, or nongovernmental
activities will be directly affected?
17. What major obstacles have or will these activities or
plans encounter?
18. What levels of funding or staff will be required to
continue/complete these plans or specific policies?
19. When will these resources be necessary?
2O. From where will funds be available?
21. What kinds of changes in inter-agency cooperation will
facilitate planning or policy implemenation described
above?
22. Will any legal or legislative changes be necessary?
23. What are likely alternatives to these measures, if any?
How close would these alternatives come to fulfilling the
objectiveees of your preferred measures?
24. Would any of these alternatives be acceptable to your
agency?
25. What is the most important role you may be able to play
to assist other agencies in eliminating toxic
contamination of Elliott Bay?
-------
APPENDIX 2
REFERENCES
Am Test Laboratories. 1981. Duwamish Waterway Navigation Improvement Study:
Chemical Testing of Dredged Material. Final Report to Seattle District, Corps
of Engineers. U.S. Army Corps of Engineers, Seattle, WA.
Department of Ecology. 1982. Draft Order Metro-Renton Sewage Treatment Plant
and National Pollutant Discharge Elimination System Waste Discharge Permit.
State of Washington, Department of Ecology, Olympia, WA.
Department of Ecology. 1984. Draft Water Quality Certification, Port of
Seattle Permit Application #9752, Piers 90/91 Short Fill. Washington
Department of Ecology, Olympia, WA.
Dunn, C.A. 1982. Fish and Wildlife Coordination Act Report on the Effects of
the Proposed East, West and Duwamish Waterways Navigation Improvement Study.
U.S. Fish and Wildlife Service, Olympia, WA.
CH2MHill. 1984. Final Remedial Investigation Data Report, Western
Processing. CH2MHill, Kent, WA.
City of Seattle. 1984. Four Mile Rock Disposal Criteria. City of Seattle,
Seattle, WA.
City of Seattle. 1983. Grading and Drainage Code, Chapters 22,800-22.806,
Seattle Municipal Code, as amended by Ordinance 111043 (effective April 21,
1983). City of Seattle, WA.
City of Seattle. 1984. Permit for Shoreline Management Substantial
Development, and Notice of Decision-Shoreline for Four Mile Rock. Department
of Construction and Land Use, City of Seattle, WA.
City of Seattle. 1983. The Seattle Shoreline Master Program, Chapter 24.60,
Seattle Municipal Code. City of Seattle, WA.
Corps of Engineers. 1983. East, West and Duwamish Waterways Navigation
Improvement Study. Final Feasibility Report and Final EIS. U.S. Army Corps
of Engineers, Seattle, WA.
Department of Construction and Land Use, City of Seattle. 1984. Draft:
Seattle Shoreline Master Program. City of Seattle, WA.
Department of Construction and Land Use, City of Seattle. 1984. Summary
Draft: Seattle Shoreline Master Program. City of Seattle, WA.
Department of Construction and Land Use, City of Seattle. 1984. Seattle
Shoreline Master Program: Proposed Environmental Designation. City of
Seattle, WA.
-------
Environmental Protection Agency. 1984. Analysis of the Section 301(h)
Secondary Treatment Variance Application for Municipality of Metropolitan
Seattle (METRO), Seattle, Washington West Point Treatment Plant. U.S.
Environmental Protection Agency Region 10, Seattle, WA.
Environmental Protection Agency with assistance from Jones & Stokes
Associates, Inc. 1981. Final Environmental Impact Statement: Wastewater
Management Plan for the Lake Washington/Green River Basins. U.S.
Environmental Protection Agency Region 10, Seattle, WA.
Environmental Protection Agency. 1981. Tentative Decision of the
Administrative Pursuant to 40 CFR Part 125, Subpart G, Analysis of the Section
301(h) Secondary Treatment Waiver Application for Seattle, Washington Duwamish
Plant. U.S. Environmental Protection Agency Region 10, Seattle, WA.
Gall, J.J. (Camp Dresser and McKee, Inc.). 1984. TPPS Technical Report A4:
Source Controls: Pretreatment Evaluation. Metro Toxicant Program Report 4D.
Municipality of Metropolitan Seattle, Seattle, WA.
Harper-Owes. 1983. Water Quality Assessment of the Duwamish Estuary,
Washington. Municipality of Metropolitan Seattle, Seattle, WA.
Jones & Stokes Associates, Inc., Tetra Tech, Inc. 1983. Water Quality
Management Program for Puget Sound Part I: Management Activities, Data
Requirements and Data Base. U.S. Environmental Protection Agency Region 10,
Seattle, WA.
Jones & Stokes Associates, Inc., Tetra Tech, Inc. 1983. Water Quality
Management Program for Puget Sound Part II: Proposed Approach and Technical
Support Effort. U.S. Environmental Protection Agency Region 10, Seattle, WA.
Jones & Stokes Associates, Inc., Tetra Tech, Inc. 1983. Water Quality
Management Program for Puget Sound Part III: Managing for Long-term
Cumulative Effects. U.S. Environmental Protection Agency Region 10, Seattle,
WA.
JRB Associates. 1984. Audit of Pretreatment Program, Municipality of
Metropolitan Seattle, Seattle, Washington. McLean, VA.
JRB Associates. 1984. Evaluation of Five Regulatory Decision-making
Processes Affecting Puget Sound's Water Quality. McLean, VA.
Metro. 1978. Areawide Water Quality Plan, King County, Washington,
Cedar-Green River Basins. Municipality of Metropolitan Seattle, Seattle, WA.
Metro. 1983. Duwamish Clean Water Plan. Municipality of Metropolitan
Seattle, Seattle, WA.
Metro. 1985. Duwamish Industrial Non-Point Source Investigations.
Municipality of Metropolitan Seattle, Seattle, WA.
Metro. 1984. Enabling Legislation as Codified in the Revised Code of
Washington. Municipality of Metropolitan Seattle, Seattle, WA.
-------
Metro. 1974. Metropolitan Seattle Sewerage System. Municipality of
Metropolitan Seattle, Seattle, WA.
Metro. 1984. Overflow Priority Table (Least harmful from water quality
standpoint). Municipality of Metropolitan Seattle, Seattle, WA.
Metro. 1983. Duwamish Clean Water Plan. Municipality of Metropolitan
Seattle, Seattle, WA.
Metro. 1980. Pretreatment Program Description. Municipality of Metropolitan
Seattle, Seattle, WA.
Metro. 1984. Puget Sound Water Quality Program, Water Quality Committee
Workshop, AUgust 9. 1984. Municipality of Metropolitan Seattle, Seattle, WA.
Metro. 1984. Toxicant Pretreatment Planning Study Summary Report: Metro
Toxicant Program Report No. 3. Municipality of Metropolitan Seattle, Seattle,
WA.
Port of Seattle. 1983. Facilities Handbook: A Directory of Port of Seattle
Facilities and Services (and map). Port of Seattle, Seattle, WA.
Puget Sound Action Program Office. 1985. Minutes, Elliott Bay Toxics Action
Plan Work Group, January 28, 1985. Puget Sound Action Program Office,
Seattle, WA.
Puget Sound Water Quality Authority. 1984. Six-month Status Report of the
Puget Sound Water Quality Authority. State of Washington, Puget Sound Water
Quality, Olympia, WA.
Stober, Q.J., K.K. Chew. 1984. Renton Sewage Treatment Plant Project:
Duwamish Head. Final Report for the Period 1 July to 31 December 1984.
Fisheries Research Institute, University of Washington, Seattle, WA.
Stober, Q.J., K.K. Chew. 1984. Renton Sewage Treatment Plant Project:
Seahurst Baseline Study, Executive Summary Final Report for the Period 1 April
1982 to 31 December 1984. Fisheries Research Institute, University of
Washington, Seattle, WA.
Tetra Tech, Inc. 1980. Draft Technical Evaluation of Municipality of
Metropolitan Seattle (Metro) Duwamish Treatment Plant 301(h) Application for
Modification of Secondary Treatment Requirements for Discharge into Marine
Waters. Tetra Tech, Inc., Bellevue, WA.
-------
APPENDIX 3
METRO TOXICANT PROGRAM REPORTS
Report
number
Project
Title
Topics
1
1A
13
1C
ID
IE
2
3
4
4A
IB
4C
4D
6A
6B
6C
Household Hazardous
Waste Disposal
Nationwide Urban
Runoff Program
Toxicant Pretreatment
Planning study
Summary
TPPS, Part A
TPPS, Part 8
TPPS, Part C
Summary of Household
Hazardous Waste
Disposal
Toxicants in Consumer
Products
Public Opinions and
Actions
SLEUTHEducational
Activities
Directory
Toxicants in Urban
Runoff
TPPS Summary Report
Technical Reports:
Al: Treatment Plant
Evaluation
A2: Collection System
Evaluation
A3: Industrial waste
Characterization
A4: Source Controls:
Pretreatment
Evaluation
Technical Report 9:
Pilot Plant Studies
Technical Reports:
Cl: Evaluation of
Toxicant Trans-
port and Fate
C2:
Puget Sound
Benthic Studies
and Ecological
Implications
Lake Washington
Benthic Studies
and Ecological
Implications
Synopsis of project.
Contents of pesticides, paints,
cleaners, and automotive products.
Pilot collection study and opinion
survey.
School curriculum materials and
hazardous waste issues.
Product disposal/recommendations for
agency personnel.
Occurrence of toxicants in stsrmwater
runoff, [be hc'ViAi- )
Synthesis of all TPPS and related
project information, problem defi-
nition, conclusions and recommenda-
tions.
Occurrence of toxicants in wastewater
treatment plants, removals, mass
loadings, and balances. Alum addition
and the impacts of Renton sludge.
Occurrence of toxicants in various land
use types, estimates of total loadings
by land use types, toxicants in CSO's,
and evaluation of a Duwamish STP.
Occurrence of toxicants at selected
industrial locations, identification
of total industrial loads of toxicants
to West Point and Renton.
Industrial pretreatment program review
and recommendations plus other
toxicant control options.
Occurrence of toxicants, siass loadings,
and balances of pilot-scale studies on
alum assisted primary treatment,
secondary treatment of West Point
wastewaters, and anaerobic digestion.
Bench-scale alum and powdered
activated carbon studies.
Occurrence of toxicants in receiving
waters, sources of toxicants, trans-
port, and deposition.
Analysis of biological testing of bottom
sediments in Puget Sound and correlatior
with toxicant loadings.
Analysis of biological testing of bottom
sediments in Lake Washington and cor-
relation with toxicant loadings.
Source: Metro. 1984. Toxicant Pretreatment Planning Study Summary Reports Metro
Toxicant Program Report No. 3, pp. iv-v.
------- |