EPA 910/9-90-002
Puget Sound Estuary Program
The Urban Bay Action Program
Approach: A Focused Toxics
Control Strategy
January 1990
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P77 Environmental Services
15375 SE 30th Place
Suite 250
Bellevue, Washington 98007
THE URBAN BAY ACTION PROGRAM
APPROACH: A FOCUSED TOXICS
CONTROL STRATEGY
For
U.S. Environmental Protection Agency
Region 10, Office of Puget Sound
1200 Sixth Avenue
Seattle, Washington 98101
EPA Contract 68-D8-0085
PTI Contract C744-05
January 1990
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CONTENTS
Page
LIST OF FIGURES iv
LIST OF TABLES v
LIST OF ACRONYMS vi
ACKNOWLEDGMENTS vii
EXECUTIVE SUMMARY viii
INTRODUCTION 1
BACKGROUND AND OVERVIEW 3
INTERAGENCY AND INTERPROGRAM COORDINATION 10
URBAN BAY ACTION TEAMS 10
INTERAGENCY WORK GROUPS 12
CITIZENS ADVISORY COMMITTEES 14
MECHANISMS FOR ENHANCING COMMUNICATION AND
COORDINATION 14
OPTIONS FOR INCREASING COORDINATION 17
Regional Urban Bay Program Office 17
Enhancement of Program Effectiveness 17
OPTIONS FOR ENSURING ACCOUNTABILITY 18
DATA COLLECTION AND PROBLEM AREA IDENTIFICATION 20
OVERVIEW 20
SOURCES OF INFORMATION 23
IDENTIFICATION OF POTENTIAL CONTAMINANT SOURCES 23
CHARACTERIZATION OF CHEMICAL CONTAMINATION AND
BIOLOGICAL EFFECTS 25
INTEGRATION OF MULTIPLE INDICATORS OF ENVIRONMENTAL
QUALITY 27
11
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QUANTIFICATION OF RELATIONSHIPS AMONG SEDIMENT
CONTAMINATION AND BIOLOGICAL EFFECTS 27
IDENTIFICATION AND RANKING OF PROBLEM AREAS 29
ALTERNATIVE STRATEGIES FOR CHARACTERIZING PROBLEM AREAS 29
SELECTION AND IMPLEMENTATION OF CORRECTIVE ACTIONS 31
REGULATORY OPTIONS FOR SOURCE CONTROL 31
INTEGRATING SOURCE CONTROL, NATURAL RECOVERY, AND
SEDIMENT REMEDIAL ACTION 32
MONITORING 33
PUBLIC PARTICIPATION 34
CONCLUSIONS 36
REFERENCES 38
APPENDIX A - THE URBAN BAY TOXICS CONTROL PROGRAM ACTION
TEAM ACCOMPLISHMENTS - EXECUTIVE SUMMARY
APPENDIX B - EVALUATION OF REMEDIAL ACTIONS
APPENDIX C - DESIGN OF SAMPLING AND ANALYSIS PLANS TO SUPPORT
URBAN BAY ACTION PROGRAMS
111
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LIST OF FIGURES
Page
1 Overview of urban bay approach 5
2 Elements of the urban bay action program 6
3 Locations of urban bay programs in Puget Sound 8
4 Effective organizational network for an urban bay action program 11
5 Decisionmaking approach for evaluation and ranking of problem areas and
problem chemicals 21
B-l Evaluation of the need for sediment cleanup B-2
C-l Phased approach to characterizing problem areas C-6
IV
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LIST OF TABLES
Page
1 Example format of action plan summary table 16
2 Theoretical example of action assessment matrix 28
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LIST OF ACRONYMS
AET
BMP
CERCLA
CSO
EAR
Ecology
EPA
Metro
NMFS
NOAA
NPDES
PAH
PSEP
QA/QC
RCRA
apparent effects threshold
best management practices
Comprehensive Environmental Response, Compensation and Liabilities Act
combined sewer overflows
elevation above reference
Washington Department of Ecology
U.S. Environmental Protection Agency
Municipality of Metropolitan Seattle
National Marine Fisheries Service
National Oceanic and Atmospheric Administration
National Pollutant Discharge Elimination System
polycyclic aromatic hydrocarbons
Puget Sound Estuary Program
quality assurance/quality control
Resource Conservation and Recovery Act
VI
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ACKNOWLEDGMENTS
This document was prepared by PTI Environmental Services under the direction of Dr.
Lucinda A. Jacobs for the U.S. Environmental Protection Agency (EPA) Region 10, Office of Puget
Sound, in partial fulfillment of Contract No. 68-D8-0085. This project was funded by the National
Estuary Program, under the authority of the Clean Water Act as amended in 1987. The primary
authors of this report were Dr. Robert A. Pastorok, Mr. Michael A. Jacobson, Mr. Pieter N. Booth,
and Dr. Lucinda A. Jacobs of PTI Environmental Services. Dr. John Armstrong served as the
project manager for EPA Region 10. Mr. Michael Rylko and Mr. Lawrence McCrone of EPA
Region 10, Dr. Frances Solomon of the Washington Department of Ecology, and Dr. Ronald M.
Thorn of the University of Washington provided thorough and insightful review of the draft
document. In addition, the following individuals provided responses to a questionnaire evaluating
the Urban Bay Approach:
Name
Burke, Martha
Everett Harbor Action Team
members
Hubbard, Tom
Jacobsen, Nathan
Jamison, Dave
Marks, Cliff
Pierce, Doug
Thibert, Neil F.
Union Bay Action Team
members
Urabeck, Frank
Affiliation
City of Seattle, Office of Long-Range Planning
Washington Department of Ecology,
Northwest Regional Office
Municipality of Metropolitan Seattle
Snohomish Conservation District
Washington Department of Natural Resources
City of Seattle, Office of Long-Range Planning
Tacoma-Pierce County Health Department
City of Seattle, Engineering Department
Washington Department of Ecology,
Northwest Regional Office
U.S. Army Corps of Engineers
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EXECUTIVE SUMMARY
The objective of this report is to provide an overview of a strategy for controlling sources of
toxic contamination and associated biological effects in estuarine environments. Known as the
urban bay approach, this toxics control strategy has been applied in bays throughout Puget Sound.
This report is intended to serve as a guide to the urban bay approach for managers of environmen-
tal regulatory programs. The approach was developed and refined in the Puget Sound region, and
is recommended for application in other estuaries. Specific recommendations are included
throughout the report and examples from the Puget Sound region are used to illustrate the
application of the approach.
The objectives of the urban bay action program are to identify specific toxic areas of concern,
identify historical and ongoing sources of contamination, rank "problem areas" and sources in terms
of priority for corrective action, and implement corrective actions to reduce current contamination
sources. An approach similar to the one described here for controlling toxic contaminants can also
be applied to reduce microbial contamination and eutrophication.
The urban bay approach can be effective in identifying, prioritizing, and controlling many
kinds of sources, including the following:
Discharges from municipal sewage treatment plants and combined sewer overflows,
pulp mills, chemical industries, metal plating shops, and other industrial facilities
Nonpoint source runoff and groundwater seepage from industrial sites (e.g., cargo
handling areas, tank farms, and log sort yards), hazardous waste sites, and landfills
Leaks from petroleum storage tanks
Fugitive emissions (e.g., sandblast materials) from boat yards
Storm drain runoff (e.g., from city streets and highways).
The urban bay approach emphasizes taking immediate action by using available data to
prioritize toxic contamination problems. Corrective actions are developed and implemented in
phases to take advantage of new scientific data and emerging ideas about practical solutions to
environmental problems. The three basic phases of an urban bay toxics action program are 1)
compilation of available data and initial identification of problem areas; 2) description of current
agency activities, identification of management gaps, and development of an action plan (i.e.,
documentation of planned actions to control contaminant sources or clean up contaminated
sediments); and 3) implementation of source controls or sediment remedial actions and monitoring
the results of the action program.
The success of the urban bay approach results primarily from achievement of the following
objectives:
Focus assessment and regulatory efforts on specific pollutant sources and
contaminated sites
Establish action teams to work in specific geographic areas
viu
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Facilitate remedial actions (without excessive studies and delays) by use of available
data and coordination among state and local agencies
Define specific commitments of agencies for permitting, inspections, sampling, and
other remedial activities
Establish mechanisms for accountability of participating agencies (e.g., involve
citizens, business-industrial organizations, public interest groups, and scientists in
decisionmaking to maximize support and accountability for the program)
Use field inspections and personal contact with polluters to encourage cooperation
in finding innovative, cost-effective solutions to toxic contamination problems
Quickly escalate regulatory and enforcement activities if warranted
Transfer technologies and solutions to new urban bays with similar problems.
The benefits of an urban bay action program include the formation of a more efficient
environmental regulatory and management network; increased cooperation of industries, wastewater
dischargers, and other responsible parties in controlling sources of contaminants; and rapid response
by responsible parties to site-specific environmental problems. By providing a common forum for
public agencies, private industries, and informed citizens to address toxic contamination problems,
the urban bay approach also enhances the effectiveness of existing regulatory programs.
IX
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INTRODUCTION
The objective of this report is to provide an overview of a strategy for controlling sources of
toxic contamination and associated biological effects in estuarine environments. Known as the
urban bay approach, this toxics control strategy has been applied to solve water-quality and
sediment-quality problems in several bays throughout Puget Sound, Washington. The process
undertaken in each urban bay action program in Puget Sound involves 1) compilation and synthesis
of available data on water, biota, and sediment quality, 2) identification and prioritization of
potential sources of contaminants and associated environmental problems, and 3) design and
implementation of remedial actions. Remedial actions may involve control of contaminant sources
and possibly sediment cleanup (e.g., removal or capping) in selected problem areas. This report is
intended as a guide to the urban bay approach for managers of environmental regulatory programs,
and local and state agencies involved in programs to control contamination in estuaries throughout
the United States. This guidance is provided as a general introduction for anyone interested in
establishing a program to control sources of chemical contaminants in urban bays. The approach
described in this report represents a proposed ideal urban bay program based on considerable
experience with the approach used in the Puget Sound region.
Urban bays are typically the receiving waters for various wastes related to human activities
in coastal areas. Industrial facilities such as shipyards; pulp, paper, and lumber mills; oil refineries;
and chemical plants are commonly located on or near the water's edge in urban bays, in part
because of easy access to marine, rail, and highway transportation. Such facilities may release toxic
chemicals directly into urban bays via the discharge of effluent and indirectly via runoff, nonpoint
sources, or groundwater seepage from landfills, open dumps, and treatment or storage facilities.
Urban bays may also experience conditions of nutrient enrichment (i.e., eutrophication) that can
lead to algal blooms, low dissolved oxygen, and fish kills; and microbial contamination (e.g.,
contamination by bacteria and viruses). These conditions frequently result from inputs of treated
or untreated domestic waste (sewage) and other inputs of organic matter, including urban runoff.
The complex contamination problems often found in urban bays are traditionally managed by
an inefficient system of rules and regulations implemented independently by many local, state, and
federal government entities. The urban bay approach was developed for the Puget Sound region
as an integrated program for consolidating and coordinating multi-agency efforts to control
contaminant sources. The approach was developed in 1985 and was formally adopted by the Puget
Sound Water Quality Authority in 1987 for long-term implementation throughout Puget Sound
[Elements P-6, P-7, P-8, P-13, P-14, P-20, and S-8 of the Puget Sound Water Quality Management
Plan; PSWQA (1987, 1989b)].
At the core of the urban bay approach are the urban bay action teams. Each action team is
a task force that focuses on specific pollutant sources and environmental problem areas within an
urban embayment. In addition to its responsibilities in securing control of pollutant discharges,
each action team coordinates the activities of environmental regulatory and resource management
agencies to achieve practical solutions to water quality and sediment quality problems.
The scope and approach of an urban bay action program may vary with the size, composition,
and experience of the action team as well as available funding. The lowest level of effort may
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simply involve shoreline surveys to identify contaminant sources and reviews of existing National
Pollutant Discharge Elimination System (NPDES) permits. A single part-time or full-time action
team member may be sufficient staff to initiate an urban bay action program. However, additional
staff and funding allow for a more efficient use of resources by facilitating use of historical data
and preventative measures [e.g., advice to industries on best management practices (BMPs)].
Subsequent increasing levels of effort may involve (in preferred order of implementation) initiation
of a public participation program, sampling and analysis of contaminant sources (e.g., tracing
sources of contamination within storm drain systems), and detailed characterization of environ-
mental problems. Assessments of environmental problem areas are used to demonstrate adverse
effects of contamination and to focus evaluation of sources and remedial actions on the most
degraded areas.
Benefits of an urban bay action program include:
Establishing a more efficient environmental regulatory and management network
by providing a common forum for public agencies, private industries, and the
general public to address contamination problems; and by reducing duplication of
effort in regulatory, monitoring, and research programs
Increasing cooperation of industries, wastewater dischargers, and other responsible
parties by simplifying the regulatory environment and by establishing cooperative
relationships with regulatory entities
Expediting source control and environmental protection through the formation of
dedicated action teams that focus corrective actions on high priority problem areas.
This report provides a general description of the urban bay approach as a toxics control strategy.
The description of the urban bay approach in this report focuses on toxic contamination for two
reasons. First, the approach was initially developed in the Puget Sound region as a primary tool
to control sources of toxic contaminants that cause adverse environmental effects. Second, solutions
to toxic contamination problems are often extremely complex compared to other environmental
problems. Even though toxic contamination is the focus of this report, the urban bay approach has
also been used effectively to address eutrophication and microbial contamination problems.
Subsequent sections of this report describe various technical and administrative aspects of the
urban bay approach and provide a summary of the major steps of the approach. Examples from
urban bay action programs implemented in the Puget Sound region are used to illustrate the
application of the approach. Recommendations for refinements of the approach are included
throughout the report to support the broader use of this approach outside of the Puget Sound area.
Key participants of urban bay programs in Puget Sound contributed information and professional
opinions about the approach during workshops and telephone interviews and by responding to a
questionnaire.
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BACKGROUND AND OVERVIEW
In 1983, the U.S. Environmental Protection Agency (EPA) and the Washington Department of
Ecology (Ecology) identified chemical contamination of Puget Sound as a high priority problem.
Inner harbors and waterways of Puget Sound were found to be severely contaminated by toxic
chemicals discharged from industrial facilities, urban storm drains, and other sources. Scientists
of the National Oceanic and Atmospheric Administration (NOAA) and the National Marine
Fisheries Service (NMFS) documented high prevalences of liver and kidney lesions in bottomfish
such as English sole and starry flounder in the industrialized areas of several embayments in Puget
Sound (Malins et al. 1980, 1982). In 1981, the Commencement Bay nearshore/tideflats area in
Tacoma (located 30 miles south of Seattle) was designated as a National Priorities List site under
the Comprehensive Environmental Response, Compensation and Liabilities Act (CERCLA)
primarily because of sediment contamination and associated biological effects (Tetra Tech 1985).
The approach to data analysis, problem identification, and site prioritization used in the
Commencement Bay program served as a cornerstone in the development of the urban bay
approach.
In 1985, in response to widespread concern over the environmental health of Puget Sound,
EPA and Ecology joined forces to form the Puget Sound Estuary Program (PSEP). The primary
objective of PSEP is to minimize contamination of Puget Sound and to protect its living resources,
such as fish, shellfish, birds, and mammals. As one of the key elements of PSEP, the urban bay
action programs focus on site-specific pollution control measures within the well-defined bodies
of water and associated drainage basins. This toxics control strategy was first applied by PSEP in
1985 in Elliott Bay and the lower Duwamish River. It evolved partly from previous water quality
control programs of the Municipality of Metropolitan Seattle (Metro) and Ecology. Metro and
other agencies had been working to improve water quality in the Duwamish River since the early
1960s by installing new sewer lines, expanding the capacities of wastewater treatment plants, and
developing an areawide water quality management plan [i.e., the Duwamish Clean Water Plan,
developed in 1983 using a federal Clean Water Act 208 grant (Sample 1987)]. The storm drain
sampling program implemented in 1984 as part of the Duwamish Clean Water Plan (Hubbard and
Sample 1988) was especially relevant to the development of the PSEP urban bay approach.
The urban bay action programs in Puget Sound are founded on the following premises:
Chemical contamination is a threat to environmental quality. For example:
Toxic chemicals discharged in estuaries may accumulate in sediments and
may cause disturbances to bottom-dwelling populations, or liver tumors
and other abnormalities in fish.
Potentially harmful chemicals in water or sediments may accumulate in
fish, shellfish, and their predators (e.g., sea lions, killer whales, and birds).
Long-term consumption of contaminated seafood by humans may pose
health risks.
Sediment contamination and associated biological effects are reliable indicators of
environmental degradation.
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Data must be adequate to determine that particular sources are causing adverse
environmental impacts and to provide for viable enforcement.
Immediate actions may be taken even when more data are needed.
Control of point sources to prevent contamination near discharge locations (e.g.,
storm drains, sewage discharges) will minimize impacts of those sources on the entire
system.
Actions are developed and refined as part of an iterative process.
In the PSEP urban bay programs, sediment chemistry, toxicity bioassays, and alterations of benthic
macroinvertebrate assemblages have proved useful in identifying high priority problem areas and
associated sources. Sediment variables have been widely used as indicators of environmental
degradation from toxic chemicals (e.g., Malins et al. 1980, 1982, 1984; Meiggs 1980; Long and
Chapman 1985; Chapman et al. 1985, 1987; Hubbard and Sample 1988). Many toxic contaminants
discharged to urban bays (e.g., heavy metals, polychlorinated biphenyls, and polycyclic aromatic
hydrocarbons) are relatively insoluble in water and readily adsorb onto particulate matter.
Contaminated particulate matter in the water column eventually becomes incorporated into bottom
sediments. Toxic contaminants are generally present at much higher concentrations (often > 1,000
times higher) in sediments than in water. Observations worldwide have linked sediment
contamination to various environmental disorders, including liver lesions in bottomfish; bioaccu-
mulation of contaminants in several species of invertebrates, fish, birds, and mammals; and altered
communities of bottom-dwelling invertebrates. Contaminated sediments have also proven to be
directly toxic in various laboratory bioassays.
The strength of the urban bay approach comes from its geographic focus, use of action teams
in the field, and use of available data to minimize wasteful or redundant studies and maximize
immediate action. The approach uses all available regulatory and enforcement tools, including
water quality laws, land use regulations, BMPs, solid waste and hazardous waste regulations, and
air quality control laws. The efficiency of existing contaminant control programs is maximized by
focusing multi-agency actions on specific prioritized contaminated sites.
The major components of the approach for managing chemical contamination problems are
data compilation and assessment, problem area definition, source evaluation, and development of
recommendations for remedial action or additional data collection (Figure 1). In the first phase of
an urban bay action program, a preliminary assessment of potential contaminant sources may be
achieved by a shoreline reconnaissance survey. However, the efficiency of source identification
efforts can be improved by first compiling and analyzing available data on sources, sediment and
water contamination, tissue contamination, and biological effects. Available data summarized in
an action assessment matrix (Figure 1) can be used to identify priority problem areas and focus
source evaluation efforts.
The concept of an interim action plan, which has been used in some PSEP urban bay action
programs, is shown in Figure 2. An interim plan may be developed for immediate control of
known pollutant sources, inspection of industrial facilities, revision of wastewater discharge
permits, and/or coordination of further sampling and analysis. Based on available data, the interim
plan emphasizes early action to address the highest priority toxic contamination problems.
Corrective actions are developed and implemented in phases to take advantage of new scientific
data and emerging ideas about practical solutions to environmental problems. The scope of field
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DATA
COMPILATION
'"I
Area
1
2
3
A
B
C
D
ACTION
PROBLEM AREA
DEFINITION
LEVELS
Action Assessment Matrix
SOURCE
EVALUATION
ACTION PLAN RECOMMENDATIONS
Remedial Actions
Source Control L
Sediment Remediation
Monitoring
Additional Data j
Collection
I
Time
Figure 1. Overview of urban bay approach
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s
A
P
L
1
N
G
A
N
D
A
N
A
L
Y
S
1
S
^
i
H
Initial Problem 1
Identification 1
Interim 1
Action Plan |~~
Potential Action
Team Activities
Source Control
Permitting
Inspections
Enforcement
Remedial Planning
Environmental
Monitoring
, * ,
Action Program 1
Evaluation
Figure 2. Elements of the urban bay action program
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surveys depends on funding level, amount and kind of available data, magnitude of contamination
and biological effects, size of the urban bay, and complexity of contaminant sources. New data
may be collected as part of ongoing surveys and monitoring programs sponsored by agencies
participating in the action program, by wastewater dischargers or parties responsible for
contaminated sites, or by academic researchers. A baywide survey to identify priority problem
areas and sources may be warranted, especially when historical data are limited. The value of a
baywide survey in providing consistent, up-to-date information for prioritization of problem areas
and sources needs to be weighed against the cost of sampling and analysis relative to available
funding.
Finally, as new information is generated, action plans are revised to update priorities for
remedial activities. Because each action plan is a record of agency commitments to future remedial
activities and data acquisition, the action plan reflects current agency policies and funding
constraints. Corrective actions primarily involve source controls to reduce or eliminate inputs of
toxic contaminants. Efficient application of existing environmental regulations and enforcement
tools in an urban bay action program may lead to substantial reductions in pollutant loading to an
estuarine system. Subsequently, sedimentation of clean particles may result in capping of
contaminated sediments through a process of natural recovery. Sediment remedial actions may be
warranted in some areas of severe and persistent contamination, especially where the environmental
benefits outweigh the cost of sediment remediation. Examples of sediment remedial activities
include removing contaminated sediments by dredging, and capping contaminated sediments with
clean materials. Sediment remediation is an expensive and complex process that requires
considerable site-specific data and review of environmental effects during the planning process.
Generally, source controls should be implemented before sediment remedial actions are taken to
avoid recontamination of an area that has been cleaned up. Regardless of the kind of remedial
action, site-specific monitoring should be considered for evaluation of the effectiveness of remedial
efforts (Figure 2).
Urban bay action programs have been implemented in seven areas of the Puget Sound region:
Commencement Bay, Elliott Bay, Everett Harbor, Sinclair and Dyes Inlets, Budd Inlet, Bellingham
Bay, and the Lake Union/ship canal system (Figure 3). Accomplishments of the urban bay action
programs include the following:
Identification and prioritization of problem areas
Control of sources through enforcement actions or negotiation with responsible
parties, and incorporation of BMPs or limits on toxic substance loading in NPDES
discharge permits
Enhanced pretreatment of industrial wastes
Implementation of BMPs for nonpoint sources
Site cleanup activities.
Ryan (1987) provides specific examples of accomplishments of the urban bay programs in Puget
Sound (also see Appendix A). Benefits of source controls as part of the Elliott Bay Action Program
and other concurrent programs (e.g., the Duwamish Clean Water Plan) are also demonstrated by the
recent reduction in contaminant loading from the Duwamish River to Elliott Bay (Paulson et al.
1989). The urban bay approach can be effective in controlling many kinds of sources, including
the following:
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Strait ot Georgia 'f
-.BELLINQHAM
Locations of
ongoing programs
0 5 10
Imitof
1 kilomMen
0 5 10
tACOMAV
Figure 3. Locations of urban bay programs in Puget Sound
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Discharges from municipal sewage treatment plants and pulp mills, chemical
industries, metal plating shops, and other industrial facilities
Nonpoint source runoff and groundwater seepage from industrial sites (e.g., cargo
handling areas, tank farms, and log sort yards), hazardous waste sites, and landfills
Leaks from petroleum storage tanks
Fugitive emissions (e.g., sandblast materials) from boat yards
Urban storm drain runoff.
A successful urban bay action program can be achieved through effective interagency and
interprogram coordination, efficient data collection and problem identification, implementation
of cost-effective remedial actions, and effective public participation. These processes are described
in detail in subsequent sections of this report.
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INTERAGENCY AND INTERPROGRAM COORDINATION
In an urban bay action program, interagency and interprogram coordination are achieved
primarily through an action team, an interagency work group, and a citizens advisory committee
(Figure 4). This section describes the composition and function of these groups. Current mech-
anisms for enhancing communication and coordination in PSEP urban bay action programs and
options for increasing coordination and ensuring accountability are also discussed.
URBAN BAY ACTION TEAMS
An action team is a field task force composed of technical staff (e.g., environmental engineers,
resource biologists) from appropriate regulatory and planning agencies. The action team identifies
pollutant sources; performs site inspections; issues and revises discharge permits; encourages BMPs;
and initiates regulatory responses such as administrative orders, consent orders, and penalties. An
action team may require wastewater dischargers or parties responsible for contaminated sites to
characterize and control contaminant sources. Specifications of sampling and analysis designs (e.g.,
collection of data on effluent and ambient environmental conditions) may be incorporated into
discharge permits or other regulatory options. These regulatory options can range from informal
verbal requests to enforcement orders or consent decrees.
Key members of an action team should have training and/or experience with appropriate
regulatory programs, including experience with permits and enforcement actions. Ideally, an action
team should include individuals with qualifications in the following areas:
Knowledge of environmental chemistry and toxicology sufficient to identify potential
pathways of contaminant transport and fate, and potential impacts to biota and
human health
Specific experience in investigating contaminated sites
Experience with treatment technologies for stormwater, groundwater, municipal
wastewater, and various industrial processes
Training or experience with the review, design, and implementation of BMPs
Training or experience in community relations and negotiation to enhance the
effectiveness of site inspections, the potential for voluntary compliance, and public
participation and education.
The leader of an action team, as well as most of its other members, should represent lead
enforcement agencies such as state resource or environmental protection agencies, and municipali-
ties. Local jurisdictions such as health departments, city and county engineering departments,
sewer utilities, and other regulatory bodies that have permitting, source identification, and source
control programs should be included in action team activities.
The number of individuals on an action team depends primarily on the size of the embayment
and the complexity of its environmental problems. For example, in Elliott Bay and Commencement
10
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Lead State Agency
EPA Regional Office
Regional Water
Quality Planning Body
Interagency Work
Group
Citizens Advisory
Committee
- County
-City
Port Authority
- State
NOAA Resource Agencies
- Environmental Groups
Industries
- Businesses
r- Concerned Citizens
Figure 4. Effective organizational network for an urban bay action program
11
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Bay, each action team is currently composed of approximately four full-time staff members.
Experience indicates that 8-10 staff members from various key agencies may be needed to
efficiently implement the most active phases of an action program in these large urban bays that
have many diverse sources. Although fewer team members would result in a slower and perhaps
less efficient program, substantial benefits may still be achieved with a small action team and a
limited budget.
Regulatory authority for an action team stems primarily from discharge permit programs and
inspection requirements under federal and state water quality regulations (e.g., the federal Clean
Water Act), hazardous substance control regulations [e.g., CERCLA (Superfund), Resource
Conservation and Recovery Act (RCRA), and state or county regulations for solid waste and
hazardous waste, and health department regulations]. Additional regulatory authority in the state
of Washington is derived from state laws on hazardous and solid waste sites (e.g., the Model Toxics
Control Act), the state delegated NPDES program, and the state combined sewer overflows (CSO)
control statute (Washington Administrative Code 173-245). In Washington, local or regional sewer
utilities are responsible for enforcement of industrial pretreatment requirements for discharges to
sanitary sewer systems. The action teams work closely with these agencies to identify problems and
solutions related to pretreatment programs. Effectiveness of an action team is enhanced by
representation of each major regulatory agency on the team.
INTERAGENCY WORK GROUPS
At the start of an action program, an interagency work group is formed to contribute to the
scoping and technical development of the program. The role of the interagency work group is to
assist the action team in:
Securing commitments of agency resources for problem identification, and source
evaluation and control efforts (through new budget allocations or by altering
priorities)
Providing technical data and reports from related projects
Coordinating related program activities within agencies
Developing corrective actions, schedules, and funding bases
Reviewing progress, technical results, and work plans of member agencies or support
contractors.
Agency participation in the interagency work group varies among urban bays and depends
primarily on the predominant regulatory and enforcement environment (e.g., types of sources and
degree of involvement of state and local governments). At a minimum, the work group should be
composed of representatives from lead federal and state agencies (e.g., EPA, Ecology, and other
toxic substance or waste permitting agencies in the Puget Sound region) and appropriate authorities
responsible for municipal wastewater treatment (e.g., city, municipal, or county governments). In
most areas, it is also advisable to include representatives from other branches of local government,
native American tribes, and port authorities. Although the role of local government is likely to
vary greatly from one area to another, many local government activities have significant
implications for source control actions. For example, cities and counties may have surface water
management utilities responsible for stormwater runoff control; engineering departments may be
responsible for sewage collection systems; and planning departments may be responsible for
12
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implementing BMP ordinances for particular land uses. Where applicable, it is appropriate to
encourage participation of regional planning bodies. In the Puget Sound region, the Puget Sound
Water Quality Authority is represented on each interagency work group because of its role in
regional water quality planning and oversight of state programs. Other examples of potentially
important regional planning bodies are city and county associations such as county planning
departments, public works, and conservation districts. The work group should be chaired by the
leader of the action team.
The composition and size of the interagency work group is likely to change over time
depending on the kinds of contributions needed from agency representatives. For example,
technical experts within each agency may participate mainly in meetings at which technical
findings are presented, whereas a subcommittee of the work group composed of budget planners
from various agencies may contribute to development of schedules and commitments for an action
plan. An official representative should, however, be identified for each participating agency. This
representative, who serves as the point of contact for questions from other work group members
and support contractors, is the individual responsible for communication of action program
information to the participating agency. Official agency representatives should maintain consistent
attendance at all work group meetings.
The interagency work group should meet either monthly or every other month. The particular
bay, the phase of the project, the consultant's scope of work, or other factors may all affect the
frequency of work group meetings. Activities of the work group include the following:
A kickoff meeting to define objectives and review the work plan of the lead agency
or support contractor for each phase of the action program
Review of technical report(s) defining problems based on available data
Review of sampling and analysis plans and results (if further data collection is
needed)
A series of two to four workshops to develop site-specific remedial activities to be
included in an action plan, associated budgets, and agency commitments
Review of draft action plan(s).
Participation in an urban bay action program is predicated on volunteerism and the good will of
the participants in combining resources and programs for a common goal. However, the
effectiveness of the program depends in part on the regulatory presence of the lead agency and
peer pressure among agency and citizen participants. Upper-level managers within the partici-
pating agencies should attend kickoff meetings and annual review meetings of the interagency work
group. Formal agreements among agencies (e.g., memorandums of understanding or interagency
agreements) may be needed to ensure participation of key organizations or to secure resource
sharing agreements (e.g., funding or staff transfers among agencies). In the Puget Sound area,
formal agreements have been successful in some cases. Under a formal agreement in the Elliott
Bay program, Metro granted money to Ecology to hire action team staff to focus on priority
problem areas. Formal agreements may also be useful to ensure implementation of the action plan.
However, formal interagency agreements have sometimes been cumbersome and time consuming
to draft; implementation of these agreements has not always been successful; and the agreements
are not always legally binding.
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CITIZENS ADVISORY COMMITTEES
Public participation in an urban bay action program is achieved primarily through citizens
advisory committees. The role of the citizens advisory committee is to:
Provide comments to the interagency work group on program objectives and
proposed actions
Identify public concerns and issues relevant to agency roles identified in the action
plan
Disseminate action plan information to members of organizations represented on the
committee and to local, state, and federal policymakers
Help ensure the accountability of program participants responsible for performing
remedial actions or investigations.
Citizens advisory committees should be composed of representatives of public interest groups
and individuals interested in the urban bay environment. Generally, membership on citizens
advisory committees should be open to all interested participants, including:
Environmental groups such as Sierra Club, Audubon Society, Greenpeace, and
Friends of the Earth
Industrial associations such as maritime business coalitions
Representatives of private industries such as pulp mills, chemical plants, shipyards,
and marinas
Representatives of commercial and recreational groups such as fishermen and boaters
Chambers of commerce
Community clubs and neighborhood groups
League of Women Voters.
The citizens advisory committee may meet separately or jointly with the interagency work group.
In some cases, the citizens advisory committee may hold separate meetings and form subcommittees
to address key issues. Alternatively, citizens may choose to participate in work group meetings
without having a formal committee structure of their own. In several urban bay programs in Puget
Sound, citizens participated directly in the work group and no separate advisory committee was
established. At the start of an urban bay action program, the mechanism for citizen participation
should be defined by the lead agency in consultation with members of the interagency work group
and representatives from public interest and community groups.
MECHANISMS FOR ENHANCING COMMUNICATION AND COORDINATION
Interagency communication on funding commitments, field investigations, and source control
activities are essential for a successful urban bay action program. The meetings of the action team,
interagency work group, and citizens advisory committee serve as the primary forums for
communication among program participants. Proceedings of each meeting should be documented
and distributed to all program participants. Each action plan documents the planned activities and
commitments of each agency. Examples of remedial actions and data acquisition activities in an
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action plan document are shown in Table 1. Action plans should ideally be updated every other
year. The frequency of revision may vary among urban bays. Newsletters and press releases
published by the action team are particularly effective for rapid communication to other programs
and the general public. Evaluation of the action program and its accomplishments should be
documented annually by the lead agency (e.g., see Ryan 1987) and announced in press releases.
The communication link between the citizens advisory committee and the interagency work
group is established through several mechanisms. First, the citizens advisory committee chair
should be responsible for presenting the views of the committee to the work group. Second,
meetings of the work group should be open to all members of the citizens advisory committee.
Third, direct participation in the work group is an option when the citizens advisory committee is
small.
Documentation of technical and programmatic information is another important aspect of
interagency and citizen communication in the urban bay program. The documentation requirements
of any given program will depend on the complexity of environmental problems and sources, and
the status of source control actions (e.g., degree of existing interagency coordination). The
following kinds of documents have been useful in PSEP urban bay action programs:
An initial data summary and problem identification document includes all historical
data and defines problem areas and important data gaps. This document typically
includes an evaluation of potential contaminant sources. This document provides the
interagency work group and the citizens advisory committee with a basic under-
standing of the problems in the specific bay.
A current activities summary can be developed to describe current data gathering and
pollution control efforts occurring in the urban bay area. This document provides
the basis for developing additional actions during negotiations with work group
members and private parties.
An interim action plan can be developed based on the initial problem identification
and source evaluation efforts. An interim action plan may be useful in bays with
complex administrative structures (e.g., numerous agencies) and contaminant sources.
The interim action plan documents initial agency commitments for remedial activities
and additional sampling efforts.
A sampling and analysis design can be developed where additional data collection
is necessary. This document describes future sampling efforts and quality assurance/
quality control (QA/QC) procedures to address data gaps.
An analysis of toxic problem areas can be documented separately if significant
additional sampling and analysis has been completed after production of the initial
data summaries. This document assists in refining source evaluations and remedial
activities.
An evaluation of potential sources document may be useful if additional sampling
and analysis has been completed. This document refines information on potential
sources and prioritizes source control activities.
A revised or updated action plan documents commitments of agencies to implement
remedial actions or further sampling and analysis.
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TABLE 1. EXAMPLE FORMAT OF ACTION PLAN SUMMARY TABLE
North Harbor Island I Problem Area
Potential Source
llth Avenue S.W. CSO (077)
Status
Low priority. Emergency overflow/storm drain. No criteria
exceedances in offshore sediments.
Actions
Implement work plan for source investi-
gation/sediment characterization
Responsible
Entity
Harbor Island
Superfund,
EPA/City of
Seattle
Implementation
Date
10/88
Metro pretreatment permits
Metals salvage yard
Shipyard 1, Plant I
Tug and Barge Company
Oil tank farm 1
Major discharge (see West Waterway I)
Minor discharge
Pathway: groundwater, surface runoff
Superfund list (CERCLIS) site: low priority
Pathway: groundwater
CERCLIS site: low priority
EPA remedial investigation (see West
Waterway II for other investigations by
Ecology)
Harbor Island
Superfund,
EPA/Oil company
Ongoing
Oil tank farm 2
Shipyard 2
Shipyard 1, Plant II
Private storm drains
Pathway: surface runoff, groundwater
NPDES permit: surface runoff
On Ecology's hazardous site list for petroleum
Inspection report - little activity, area clean, four tanks active
Pathway: surface runoff, fugitive emissions
NPDES permit: new permit being issued
Underground Storage Tank: mineral spirits and solvent tank
leaks adjacent to West Waterway. Tanks removed 9/86.
Pathway: surface runoff (private storm drains), fugitive
emissions
Facility closed, equipment sold
Potential sources, many poorly characterized
Update bulk petroleum storage facilities
NPDES permits
Inspect/renew NPDES permit
Investigate groundwater contamination
Inspect/cancel permit
Conduct soils and groundwater investiga-
tion
Continue source identification and sam-
ple key storm drains
Ecology
Ecology
Harbor Island
Superfund/
Shipyard 2
Ecology
Harbor Island
Superfund/
Shipyard 1
Harbor Island
Superfund,
EPA/City
of Seattle
FY89a
FY89"
FY89a
1988/1989
a FY 89 = 1 July 1988 through 30 June 1989.
Note: Blanks indicate items for which actions, responsible entity, or implementation dates have not been determined.
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In addition to the above, long-term implementation of an action plan might benefit from the
development and documentation of environmental monitoring designs. Procedures and formal
interagency agreements that ensure periodic review and revision of action plans need to be
developed. Also, mechanisms for evaluation of remedial alternatives should be documented.
OPTIONS FOR INCREASING COORDINATION
Regional Urban Bay Program Office
Coordination of multiple urban bay action programs with each other and with other state
programs is an essential element of a successful urban bay approach. Based on experiences with
the urban bay programs in Puget Sound, it is recommended that a regional urban bay program
office be established within a branch of the state lead agency and be given responsibility for
administering these programs. The regional office should serve as the focal point for interagency
and interprogram coordination.
Activities of a regional urban bay program office should include informing action teams of
changes in agency programs and policies that affect their activities; coordinating CSO and
stormwater control plans, NPDES and dredging permits, grants for field investigations, and actions
of other program offices with the urban bay programs; maintaining and updating a comprehensive
BMP manual; and implementing a tracking system for field inspections. A comprehensive and
systematic decision process should be developed as an aid for inspectors to determine the following:
Regulations or programs (e.g., Superfund, hazardous waste or pesticide regulations,
federal Clean Water Act) applicable to each facility, discharge, and waste site
Violations of toxic substance regulations
Compliance or noncompliance of discharges with permit specifications
Priorities for corrective actions.
The proposed decision process should include consideration of dangerous waste generation,
handling, and disposal; underground storage tank regulations; water quality standards; discharge
permit limits; wetlands protection laws; and other water resource issues. The state water quality
program should also include a permit-training program to address typical water quality permit
inspections.
Enhancement of Program Effectiveness
Use of technology transfer workshops is one option for enhancing coordination and overall
program effectiveness. For example, the key implementing organizations could maximize
technology transfer through community outreach programs (e.g., trade shows where private
organizations can anonymously obtain advice on the handling, transport, and disposal of hazardous
materials). Also guidance manuals may be published on BMPs for specific industries, such as
shipbuilding or commercial construction.
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Staff replacement within participating agencies and organizations can affect coordination and
program continuity. An urban bay action program would benefit from requirements for
minimizing discontinuity, especially for staff who are members of the interagency work group or
urban bay action team. Requirements should include recommended reading lists and briefing of
work group members (at work group meetings or by mail) of intended staff changes and the
anticipated effects. If the urban bay action team coordinator is replaced, special care is needed to
ensure program continuity. Departing coordinators should provide a written status report of all
ongoing projects as well as outstanding issues which need to be addressed but are not identified in
any program documents (e.g., the action plan). Departing coordinators or other personnel should
also provide some training to incoming coordinators which might include information or historical
developments of the program, issues or problems in the bay, and a status of activities in the action
plan.
Some urban bay action programs may benefit from a phased approach to planning and agency
involvement. In the first phase of the program, participation by a wide range of organizations and
public interest groups would be solicited for scoping and design of the technical and institutional
aspects of the program; the membership of the interagency work group would reflect these needs.
The second phase would occur during program implementation when participation of agencies with
regulatory authority and representatives of the regulated community is most important; the
membership of the interagency work group would be refined to reflect the changing needs of the
program.
Long-term success and continuity of an urban bay action program can be fostered by
obtaining funding commitments for the program from the state legislature. This enables agencies
to hire staff and necessary technical support. State funding also increases opportunities for
initiating priority actions. The ease with which funding can be obtained for a program depends
to a large extent on the degree of public support. Therefore, mechanisms should be used to foster
public support during program implementation (e.g., public meetings, press releases, and briefing
of legislators or their staff on progress of the program). It is advisable for program managers of
participating agencies to meet annually to establish agency commitments, funding levels, and
responsibilities.
OPTIONS FOR ENSURING ACCOUNTABILITY
Accountability for implementation of an urban bay program is a critical element in the long-
term effectiveness and success of the urban bay approach. Accountability in this sense applies to
agencies making resource commitments and following through on those commitments. Often, no
formal mechanism (e.g., an enforcement order) exists to ensure accountability throughout a given
urban bay. Rather, techniques based on citizen and agency peer pressure are likely to be the main
methods available. The first step in ensuring accountability is to get an initial commitment of staff
and/or resources and address high priority problems. Once a commitment has been made, it is
essential to document this commitment in various ways. Public documentation of commitments
in an action plan helps ensure that agencies follow through on commitments by providing a public
record for later comparison with achievements.
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Some possible options for ensuring accountability for implementation include:
Public meetings could be held periodically to inform the public of the completion
of significant milestones (e.g., implementation of remedial actions for a major source
of contaminants)
A quarterly or semiannual urban bay newsletter could be published to document
intended actions, status of these actions, and successes or failures
Annual reports or articles could be published for the press, interested citizens, and
environmental groups on the status of action plan implementation
Directors or senior policymakers in participating organizations (especially those
making a commitment of resources to the urban bay action program) could sign the
action plan as an indication of good will and as a matter of public record
The lead implementing agency or lead regulatory agency could get formal or
informal agreements from agency personnel concerning intended agency activities
under the urban bay program
Awards could be given to selected industries that have implemented progressive or
innovative cleanup actions
Press releases could be issued on industries that have not met their cleanup
commitments
In some cases, a formal regulatory requirement such as a consent decree or
enforcement order may be issued by a regulatory agency.
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DATA COLLECTION AND PROBLEM AREA IDENTIFICATION
The PSEP urban bay action programs rely on a preponderance-of-evidence approach to
identify and rank toxic problem areas and contaminant sources (i.e., use of multiple indicators of
environmental quality). Study areas that exhibit high values of multiple indicators of contamina-
tion and adverse biological effects receive a ranking of "high priority" for evaluation of pollutant
sources and remedial actions. The data for environmental variables and contaminant sources are
used to target priority sources for further evaluation or remediation. Available funds can then
be allocated to the highest priority problems first to achieve cost-effective source controls and
environmental improvements.
The following sections describe the process used to evaluate contaminant sources and environ-
mental problem areas. First, the framework for the technical evaluation (i.e., the decisionmaking
or prioritization approach) is described. This is followed by descriptions of the key steps in the
decisionmaking approach. Finally, alternative approaches are described that may be used to
streamline the overall process.
OVERVIEW
The preponderance-of-evidence approach used in urban bay programs is implemented in a
step-wise manner to identify toxic problem areas and associated contaminant sources (Figure 5).
This approach focuses on sediment assessment techniques because of the value of sediment variables
as indicators of toxic chemical contamination and biological effects (for rationale, see Background
and Overview section). Nevertheless, a similar approach could be applied to water column variables.
Information is incorporated into an assessment matrix and evaluated to identify and prioritize
problem areas, problem chemicals, and potential pollutant sources. The available data are evaluated
relative to action level guidelines (i.e., criteria for defining and ranking toxic problem areas) and
sediment quality values are developed from quantitative relationships between sediment
contamination and biological effects. Problem chemicals may then be linked to specific sources.
The general approach may be applied to either a small data set derived from previous studies
or a comprehensive data set collected as part of an urban bay action program. A series of data
collection activities could be implemented in a tiered fashion to correspond with increased funding
over time. For example, Tier 1 could be a shoreline reconnaissance survey of potential sources and
initial source evaluation; Tier 2 could involve meeting with industries to discuss efficient industrial
management practices and additional data needs for source prioritization; Tier 3 could involve
inspections of industrial facilities for compliance with toxic substance regulations and an evaluation
of potential sources of contaminants; and Tier 4 might involve more extensive field sampling and
the detailed evaluation of environmental data described below.
The Tier 4 evaluation assumes that environmental degradation must be assessed for areas
within a bay to determine priorities for source evaluations and remedial actions. This approach is
most appropriate when few data on contaminant sources are available and sources cannot be easily
prioritized based on other information (e.g., information on land use and industrial processes). The
Tier 4 evaluation may also be warranted when a demonstration of environmental harm is required
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Gather
Available
Data
Assemble
Assessment Matrices
Identify and Rank
Problem Areas
Apply Quantitative
Relationships and
Action Level Guidelines
I
Identify and Rank
Problem Chemicals
Conduct Detailed
Source Evaluations
Figure 5. Decisionmaking approach for evaluation and ranking of problem areas
and problem chemicals
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to proceed with enforcement action or to elicit actions from responsible parties. Responsible
parties could either be legally forced to do further sampling and analysis or to initiate immediate
source control. In some cases, environmental data may not be needed to prioritize contaminant
sources and to implement source controls (e.g., where the most important sources of contaminants
are obvious and data on these sources are sufficient for regulatory controls).
Four major premises underlie the Tier 4 approach shown in Figure 5. First, recommendations
for evaluation of contaminant sources and remedial actions are based on several measures of
sediment contamination and biological effects. When results of these independent measures
corroborate one another (i.e., there is a preponderance of evidence showing sediment contamination
and biological effects), a problem area is defined. There may also be special circumstances where
corroboration is not needed because a single environmental indicator (e.g., sediment contamination
or adverse biological effect) provides an exceptionally strong basis for recommending source control
or sediment remedial action.
Second, the decision to evaluate potential sources of contamination and the need for possible
remedial alternatives applies only to those sites that exceed a minimum action level. An action level
is a level of contamination or biological effects that defines a problem area. It is assumed that an
area requires no action unless one of the indicators of contamination, toxicity, or biological effects
is significantly elevated above reference levels. Action level guidelines provide a consistent and
objective procedure for defining and ranking problem areas based on significant contamination
and effects. One action level guideline used in Puget Sound is based on significant elevation above
reference (EAR) levels for three or more environmental indicators (e.g., sediment toxicity, benthic
community structure, and bioaccumulation). Additional examples of action level guidelines are
provided by PTI and Tetra Tech (1988a,b). Specific guidelines developed for one urban bay action
program may be adapted and applied to other bays. Action level guidelines should be developed
in consultation with the interagency work group and the citizens advisory committee.
Third, it is assumed that adverse biological effects are linked to environmental conditions that
result from toxic chemical releases from sources and that these links may be characterized
empirically. Relationships between sources and biological effects should be quantified where
possible (e.g., by correlations of specific contaminant concentrations and distributions with the
occurrence of adverse biological effects). However, proof of specific causal agents is generally not
obtained during an urban bay action program because laboratory studies of cause-effect
relationships involving complex mixtures of contaminants are impractical in the context of short-
term regulatory response. Nevertheless, analysis for a wide range of contaminants (e.g., in
sediment) increases the probability of measuring either the causative substances or related covarying
substances from the same source.
Finally, the recommended remedial actions may vary from location to location, depending on
the nature of the water quality or sediment contamination problem. For example, removal or
capping of contaminated sediments may be recommended where biological effects are apparent and
contamination originated only from past sources (see Appendix B for information on evaluating
sediment remedial action). In contrast, source control may be recommended where contamination
originates from an ongoing source. In other cases, both sediment remediation and source control
may be recommended. To prevent recontamination of newly cleaned areas, sediment remediation
(if necessary) should usually be implemented only after major sources of contamination have been
identified and controlled. Sources of information needed to support an urban bay action program
are discussed in the next section. Because environmental data may not be needed to undertake
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source remedial actions, the following discussion addresses evaluation of contaminant sources before
characterization of environmental contamination and biological effects.
SOURCES OF INFORMATION
Compilation of existing information on sediment and water quality, biological effects, and
potential contaminant sources is the first step in evaluating contaminant sources and environmental
problem areas. The needed information may be obtained through contacts with federal, state, and
local agencies and should be collected into a project library. The following institutions, agencies,
and agency programs can provide useful information:
State agencies (e.g., departments of ecology or environmental quality, natural
resources, and health)Lists of hazardous waste generators; source information from
inspections and investigations, including NPDES permits and monitoring results;
surveys of contaminated sites
EPAEnvironmental quality surveys, STORET database, NPDES monitoring results
NOAAInformation on chemical contamination in sediments and water, bioac-
cumulation, fish pathology, and bioassays; National Oceanographic Data Center
database
U.S. Army Corps of EngineersSediment data collected by dredging contractors and
ports for dredging projects
Local health departmentsSurveys of storm drains and CSOs; studies that focus on
health-related concerns (e.g., bioaccumulation, microbial contamination)
Chambers of commerce and city and county planning departmentsLand use
information
IndustriesNPDES monitoring data, manufacturing and processing information, and
maps of facilities and drainage systems
Local colleges and universitiesStudies that focus on or include urban bays.
IDENTIFICATION OF POTENTIAL CONTAMINANT SOURCES
Potential contaminant sources in urban bays include municipal wastewater treatment effluent,
CSOs, surface runoff, contaminated groundwater infiltration, industrial discharges, boat and marina
discharges, atmospheric deposition, and accidental spills. Actual and potential contaminant sources
are identified based on existing information about past and present activities and information from
site inspections and discharge permits. Data are most commonly available from files of state
regulatory agencies for facilities with NPDES-permitted or known nonpermitted discharges,
facilities contributing to contamination due to poor housekeeping practices, and sites with
groundwater or soils contamination. Additional sources of information include consultant studies,
university studies, U.S. Army Corps of Engineers permits for dredged projects, and U.S. Coast
Guard files of oil spill occurrences.
Efforts to identify sources typically integrate a large database on potential contaminant
sources, observed contaminant concentrations in water and sediment, and ancillary information.
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Spatial gradients of contamination in surface sediments and water column
Vertical gradients of contamination in sediment cores and water column
Maps of point source discharges, storm drain systems, landfills, hazardous waste
sites, locations of relevant industries (e.g., shipyards, pulp mills, oil refineries, metal
plating shops), marinas, and potential nonpoint sources
Contaminant concentrations associated with point source effluent, storm drains (i.e.,
sediment or water within the storm drains), and nonpoint sources
Contaminant concentrations from source tracing in CSO and storm drain networks
Dredging history
Data on environmental fate processes and circulation/transport
Information on land use and industrial activities (e.g., use or production of a
particular contaminant, handling and disposal practices).
Information used for evaluation of the contaminant source can be collected during shoreline
surveys, inspections of industrial facilities, and other field investigations.
Because most persistent toxic chemicals adsorb to sediments, evaluation of spatial gradients of
contaminants in surface sediments has proved to be one of the most important components in the
source identification process for Puget Sound. However, overlap of the areas of influence of
different source discharges may complicate the interpretation of contaminant data for surface
sediments (see below for discussion of storm drain sampling as an alternative to surface sediment
sampling). Evaluation of vertical gradients of contamination in sediment cores can be used to
assess the chronology of contaminant accumulation. For example, a concentration maximum in the
uppermost sediments of a depositional area probably indicates recent input or possible historical
input exposed by dredging or ship scour. By contrast, a subsurface concentration maximum
suggests that historical input was greater than current inputs and that recent burial with cleaner
sediments has occurred.
To better characterize contaminant inputs from CSOs and storm drains, a screening-level
survey may be conducted (e.g., Tetra Tech 1988b). One technique that appears promising for
ranking contaminant sources is to collect settled sediment in CSOs and in storm drains that
discharge directly into the waters of the project area (Meiggs 1980; Hubbard and Sample 1988).
Sediments from the storm drains can be analyzed for the same contaminants measured in offshore
sediments. These storm drains and other potential sources are evaluated for their contribution of
contaminants to priority problem areas. Potential sources are identified based on the following
elements:
Proximity of the potential source to an offshore problem area
Similarity of the kinds and relative concentrations of problem chemicals in sediments
in storm drains and the receiving environment
The spatial distribution of contaminants in offshore sediments
Available information on past and ongoing practices that may contribute to observed
contamination.
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For example, in the Elliott Bay Action Program 10 priority storm drain systems were identified
for source control activities based on information developed or compiled during the problem area
analysis (PTI and Tetra Tech 1988a) and the evaluation of potential contaminant sources (Tetra
Tech 1988a).
Information on land use and drainage patterns in the watershed of an urban bay can be used
to identify likely sources of contamination. This information is typically summarized by mapping
the location of potentially contaminated facilities and storm drain networks relative to locations of
contaminated areas. If maps of storm drainage systems are not available, then obtaining the
information to prepare drainage maps should be a high priority. Land use information should
include both historic and current data. Geographic information systems provide the best format
for organizing and evaluating the interrelationships among various types of information.
CHARACTERIZATION OF CHEMICAL CONTAMINATION AND BIOLOGICAL EFFECTS
Where environmental data are available or can be collected in a cost-effective manner,
multiple indicators of sediment quality and water quality should be used to aid in prioritization of
source evaluations and remedial actions. The preponderance-of-evidence approach requires the
selection of several measurements that serve as indicators of contamination and biological effects
in the urban bay. To minimize costs, the objective should be to select the minimum number of
indicators that can adequately characterize the extent of contamination as well as enable a
prioritization of problem areas. In Puget Sound, the urban bay approach has used five kinds of
environmental indicators:
Sediment contaminationConcentrations of chemicals and chemical groups
Sediment toxicityAcute mortality of amphipods, abnormalities in oyster larvae, and
bacterial luminescence (Microtoxฎ)
Benthic infaunaAbundances of major taxa or species
BioaccumulationContaminant concentrations in English sole muscle tissue
Fish histopathologyPrevalences of liver lesions in English sole.
The number and kinds of environmental indicators used to characterize problem areas depends
on the amount of historical data available, the magnitude of a suspected problem, and data needs
specified by regulatory enforcement agencies (including level of confidence desired for problem
area identification). In the Puget Sound region, measurements of contaminant concentrations in
sediments have been especially useful for characterizing the degree of contamination and for
tracing pollutant sources. Measurements of contaminant concentrations in tissues of aquatic
organisms have been used to identify large-scale problem areas and potential human health risks
in populations of recreational anglers who consume seafood from contaminated areas. The basis
for the use of bioaccumulation and histopathology was established by the earlier work of NMFS
(e.g., Malins et al. 1980, 1982, 1984). Sediment bioassays and surveys of sediment-dwelling
organisms are valuable for characterizing effects of contamination at specific sampling locations.
Data on abundances of major taxa (e.g., Polychaeta, Gastropoda, Pelecypoda, Crustacea) are
especially useful for screening surveys. Detailed assessments of species abundance are sometimes
needed to discriminate effects of toxic substances from habitat influences (e.g., sediment grain size,
organic carbon content) on benthic communities. Measurements of sediment chemistry, bioassays,
and benthic community analyses form the triad of data used to characterize toxic problem areas in
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and benthic community analyses form the triad of data used to characterize toxic problem areas in
Puget Sound (Long and Chapman 1985; Chapman et al. 1985; PTI and Tetra Tech 1988a,b) and San
Francisco Bay (e.g., Chapman et al. 1987). A combination of chemical and biological measurements
has also been used to define sediment quality values (i.e., guidelines for chemical concentrations
expected to cause adverse biological effects; Barrick et al. 1988).
The scope of field surveys depends on funding level, amount and kind of available data,
magnitude of contamination and biological effects, size of the urban bay, and complexity of
contaminant sources. A comprehensive (baywide) field survey to identify problem areas and
contaminant sources should be performed only when recent historical data are insufficient to
conduct such an assessment. A baywide survey has several advantages. Consistent and reliable
data may be obtained from suspected problem areas and relatively clean areas, new problem areas
may be discovered, and problem areas can be ranked primarily on the basis of current data.
However, a baywide survey may not be appropriate if there is little or no funding available from
agencies participating in the interagency work group. Instead of a single comprehensive field
survey, multiple field surveys may be performed in phases at selected locations. Opportunities for
use of samples or data being collected as part of other programs should also be considered, although
QA/QC requirements may limit the use of such "opportunistic samples." Funding for a
comprehensive survey or a series of phased, smaller surveys can be solicited from participating
agencies in the work group. If available data are sufficient for regulatory action, then parties
responsible for contaminated sites may be required to perform further investigations to assess the
extent of problems and select remedial alternatives.
If a field survey is necessary, documentation of the sampling and analysis design is essential.
Cost-effective sampling and analysis strategies, with adequate QA/QC of both sampling and
analytical laboratory performance, are required for an efficient and scientifically defensible project.
Development of a sampling and analysis plan should involve evaluation of available data. Data on
potential sources and drainage patterns are especially useful for deciding where to position sampling
stations. Information on current and historical land uses should also be evaluated to identify
potential problem areas. For major point sources, the most effective strategy is generally to sample
discharge effluent and sediments in the immediate vicinity of the outfall. Where available
environmental and land use data are sufficient to define a problem area, the sampling and analysis
scheme may be almost exclusively devoted to characterization of contaminant sources. Where
historical chemical and biological data indicate a problem area exists but sources are unknown, the
emphasis of the sampling and analysis plan may focus initially on confirmation of adverse impacts
before a major survey to identify sources is performed. Information on adverse impacts is valuable
in ranking problem areas for further evaluation of sources, especially where source data are limited.
Elements of sampling and analysis plan design are described in Appendix C.
Data validation is an essential element of any sampling program. Comprehensive validation
of historical data is not always possible because QA information is not always available. Data
quality review of historical data should focus on five primary data characteristics: sample
collection, sample handling, QC samples (e.g., replicates, blanks), analytical methods, and detection
limits. The data review procedures described in Appendices E and F of Tetra Tech (1988c)
provide a good example of historical data review. Data validation of field studies conducted as
part of an urban bay action program is subject to greater control. QA encompasses every aspect
of a project, including planning, data collection, data quality review, and data use. Regional
guidelines for data QA are summarized in PSEP (1986) and PTI (1989).
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INTEGRATION OF MULTIPLE INDICATORS OF ENVIRONMENTAL QUALITY
Available chemical and biological data are used to calculate environmental quality indices.
These indices are then used to rank or prioritize areas based on observed contamination and
biological effects. The indices have the general form of a ratio between the average value of a
variable at a contaminated site and the value of the same variable at a reference area. General
objectives for reference areas and specific performance criteria for Puget Sound reference areas are
provided by Pastorok et al. (1989). The ratios are structured so that the value of the index
increases as the deviation from reference conditions increases. Thus, each ratio is termed an EAR
index. For most variables, the measured average value at the study site is divided by the average
value at the reference area to obtain the EAR index. A similar approach can be applied to water
quality assessment. Where water quality standards exist, the EAR index is simply the ratio of the
observed contaminant concentration in water to the water quality standard.
Information from multiple indicators can be integrated for an overall evaluation and
prioritization of study areas. The environmental contamination and effects indices (i.e., EAR
indices) are organized into an action assessment matrix that is used to compare study areas or
sampling stations. A simplified hypothetical example of such a matrix is shown in Table 2. For
this example, only general indices such as sediment contamination or benthic macroinvertebrates are
shown. In the application of the approach to an actual case, multiple indices based on specific
variables are used for each of the five data categories (e.g., specific chemicals for sediment
contamination and various species for benthic macroinvertebrates).
QUANTIFICATION OF RELATIONSHIPS AMONG SEDIMENT CONTAMINATION AND
BIOLOGICAL EFFECTS
In Puget Sound, sediment quality values based on the apparent effects threshold (AET)
approach (Barrick et al. 1988) have also been used to characterize the severity of sediment
contamination and to prioritize problem chemicals (PTI and Tetra Tech 1988a,b). AET values are
developed from a large historical database of the observed (i.e., empirical) relationship between
biological effects and chemical concentrations. An AET is defined as the concentration of a single
chemical (or chemical class) in sediment above which a particular biological effect has always been
observed (and thus is predicted to be observed in other areas with similar concentrations of that
chemical).
AET values are particularly useful when biological effects data for particular sites are not
available but sediment chemistry data are available, as is the case for many historical data sets.
AET for Puget Sound values have been generated for individual chemicals or chemical groups in
each of four biological effects categories: 1) benthic infauna depressions, 2) amphipod mortality
bioassay, 3) oyster larvae abnormality bioassay, and 4) Microtoxฎ bioassay. Ratios of chemical
concentrations to their respective AET values provide useful indices of the relative seventy of
contamination. Details on the AET approach and its application to other programs in Puget Sound
can be found in Barrick et al. (1988). AET should be applied only to data sets from the estuarine
or coastal region where the AET values were developed. The EPA Science Advisory Board has
recommended that AET be developed and applied on a site-specific basis only. Research is
currently in progress to develop AET in United States coastal areas other than Puget Sound (e.g.,
San Francisco Bay and the Southern California Bight). In addition, the EPA Office of Water
Criteria and Standards is investigating the use of the equilibrium partitioning theory to develop
national sediment quality criteria (U.S. EPA 1988b). Sediment quality criteria values based on the
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TABLE 2. THEORETICAL EXAMPLE OF ACTION ASSESSMENT MATRIX8
EAR Values for Study Sites
Indicator
Sediment contamination
Toxicity
A B
|l,300l Rsl
fTsl 2.0
c
1 800 1
1 io.o|
D
LH
ra
E
8
2.2
Reference Value
1,000 ppb
10% mortality
Bioaccumulation
Pathology
Benthic macroinvertebrates
9001 I 201 I 1.1001 12001 13
5.2| 2.6 I 8.01 | 2.8| 2.0
4.01 1.2 I 5lJl 1.3 1.1
10 ppb
5% prevalence
60 individuals/m2
8 EAR values for indicator variables are shown for Sites A-E. Benthic macroinvertebrate factors
represent the reduction in numbers of individuals at the study site relative to the reference site.
Factors for all of the other indices represent increases relative to the reference site values shown.
| | - Indicator value for the specified area is significantly different from reference value.
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equilibrium partitioning theory should also be useful in evaluating sediment contamination and
biological effects once they are fully developed.
IDENTIFICATION AND RANKING OF PROBLEM AREAS
Evaluation of information in the form of a matrix (e.g., Table 2) enables the decisionmaker
to answer the following questions:
Is there a significant increase in contamination, toxicity, or biological effects at any
study site?
What combination of indicators is significant?
What are the relative magnitudes of the elevated indices (i.e., which represent the
greatest relative hazard)?
The term significant as used in the urban bay approach generally indicates statistical
significance at a selected confidence level (e.g., a = 0.05). Significance of an EAR is generally
based on statistical comparisons of variables between contaminated sites and an appropriate
reference area.
The decision to evaluate potential sources of contamination and the need for possible remedial
alternatives applies only to those sites that exceed a minimum action level. An action level is a
level of contamination or biological effects that defines a problem. Individual stations that exceed
action level guidelines are grouped into problem areas based on consideration of chemical
distributions (including data from recent historical studies), the character and proximity of potential
contaminant sources, and geographic and hydrographic boundaries. The need for remediation and
the actions required to prevent further degradation should be decided on a case-by-case basis.
Problem areas are ranked using a systematic method of assigning scores to sampling sites or areas
based on the significance and severity (i.e., EAR index) of the various chemical and biological
variables. The level of EAR values for metals and organic compounds percent bioassay response,
number of marcroinvertebrate depressions, number of chemicals in fish muscle tissue, and number
of lesion types in fish were all used in Puget Sound as criteria for ranking problem areas. Further
information on the use of criteria for ranking problem areas for evaluation of sources and remedial
actions is summarized by PTI and Tetra Tech (1988a).
Problem chemicals in sediments may be prioritized to focus efforts for evaluation of
contaminant sources (e.g., Tetra Tech 1985). In Elliott Bay, chemicals within a given problem area
were identified as potential problem chemicals if their concentrations exceeded the 90th percentile
value for all observations within the bay. A contaminant was also identified as a problem chemical
if its concentration exceeded the most sensitive (i.e., lowest) value of the four kinds of chemical-
specific AET (i.e., benthic infauna depressions, amphipod mortality bioassay, oyster larvae
abnormality bioassay, Microtoxฎ bioassay).
ALTERNATIVE STRATEGIES FOR CHARACTERIZING PROBLEM AREAS
Because of the wide range of conditions represented in various urban bays, the basic approach
described above may need to be modified to fit a particular situation. An example of one approach
to streamlining the procedures for characterizing problem areas is presented in Appendix C. For
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example, this approach involves use of areawide indicators (e.g., bioaccumulation and histopath-
ology in fish) to identify selected large-scale problem areas before use of site-specific indicators
(e.g., sediment chemistry, toxicity, and benthic macroinvertebrates). The general approach, as
applied in Puget Sound, could also be modified by including information that has not been assessed
in the urban bay action programs conducted to date. Certain types of information may provide
significant insight into environmental problems and their relative importance. For example, habitat
sensitivity or economic value could be included in problem area ranking. In addition, for some
areas it may be appropriate to conduct independent evaluations of potential human health hazards
and environmental hazards. This approach would enhance flexibility in evaluating the relative
importance of these two distinct types of hazards. For example, the ultimate ranking of
contaminated areas in a protected, environmentally sensitive regime might emphasize the ecological
hazard, while the ranking of contaminated areas that are heavily used by commercial and
recreational fishermen might emphasize human health considerations.
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SELECTION AND IMPLEMENTATION OF CORRECTIVE ACTIONS
The regulation of toxic contamination of the environment includes 1) the control of
contaminated discharges and the cleanup of contaminated facilities; 2) natural sediment recovery
through burial and mixing with clean, freshly deposited material; and 3) sediment remedial action
in cases of highly concentrated or persistent contamination. Source control is addressed through
various regulatory options. The rate of natural recovery may be characterized by using a mass
balance model that links source loading, sediment contamination, benthic mixing, and sediment
accumulation. Monitoring of the extent and severity of contamination may be included in an urban
bay action program to ensure that source controls are sufficient, that sediment recovery is timely,
and that recontamination does not occur. However, in some areas of severe and persistent
contamination, sediment remediation may be required (i.e., where cost-benefit analysis shows a
definite net benefit). The need for sediment remedial action may be determined by evaluating the
balance between the rate of natural recovery after source control, the kinds and magnitudes of
existing environmental impacts, and the cost of sediment remedial action (Appendix B). In areas
with significant nonpoint sources of pollution (e.g., stormwater runoff), management strategies
(U.S. EPA 1987a, 1988a; PSWQA 1989a; LIRPB 1984) emphasizing nonregulatory approaches may
be necessary.
REGULATORY OPTIONS FOR SOURCE CONTROL
Cleanup and control strategies for sources vary widely, depending on the nature of the source.
For example, source control actions applicable to industrial dischargers include in-line process
modifications or effluent treatment. Strategies for controlling runoff from contaminated facilities
include containment, collection, and treatment options. Alternative ways of controlling
contaminated groundwater discharge range from pump-and-treat alternatives to confinement or
diversion. Nonpoint sources such as runoff from urban areas are predominantly controlled by
designing and implementing BMPs.
These diverse strategies for controlling sources are implemented through several regulatory and
management processes. Point sources that are permitted can be controlled by modifying permit
requirements. The following general types of regulatory actions are used to initiate source control
action:
Inspections
Notification of permit violation
Administrative order (e.g., to take a specified course of action within a specified
schedule)
Consent order or decree (e.g., a binding agreement between a regulatory agency and
party under enforcement)
Notice or demand letter (e.g., to accompany a consent order or decree and specify
the timeframe and procedures for negotiations)
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Permit issuance or modification
Penalties
Court action.
For illegal dumping, criminal investigation and enforcement depend heavily on apprehending the
violator in the act. Until a violator is identified, regulatory activity primarily involves monitoring
an area where illegal activity is suspected. For control of nonpoint sources, working with local
planning and utility agencies may provide effective solutions (e.g., specifications in local building
and development permits to address stormwater/runoff issues).
INTEGRATING SOURCE CONTROL, NATURAL RECOVERY, AND SEDIMENT REMEDIAL
ACTION
The selection of appropriate strategies for pollutant source control or sediment remedial action
for the highest priority problem areas is a critical part of an urban bay action program. Because
of typical budget limitations, it is unrealistic to assume that corrective actions can be implemented
in all problem areas, at least in the short term. It is important that available resources initially be
directed toward areas posing the greatest environmental hazard. Furthermore, it is important that
decisions on sediment remedial action be based on evaluation of the environmental benefits that
can be realized from the remedial costs incurred. A decisionmaking structure is needed that
enables the appropriate direction of financial resources to areas where the greatest benefit will be
realized.
In considering the need for pollutant source control and sediment remediation, it is important
to distinguish between two key characteristics of these remedial activities:
From a cost standpoint, the potential upper cost limit for sediment remediation (e.g.,
removal and treatment) is much greater than for some forms of source control (e.g.,
settling basins). The technologies for some forms of source control are also more
feasible than sediment remediation techniques.
Because sediments contaminated by historical pollutant sources or by recently
controlled sources may have the potential for natural recovery, simply allowing
natural processes to occur could substantially mitigate the environmental cleanup
costs.
Because of these and other factors, the urban bay programs in Puget Sound have emphasized
source control and natural recovery. Also, ongoing contaminant sources should be scheduled for
control once they are identified. In contrast, contaminated sediments require further evaluation
before sediment remediation is selected as an appropriate course of action. Also, the environmental
benefits, impacts, and costs of sediment remedial action need to be evaluated relative to natural
recovery and source control options. A general approach to evaluate the need for sediment
remediation and to select preferred remedial alternatives is described in Appendix B.
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MONITORING
Monitoring of sources and the receiving environment is critical to ensure that all necessary
remedial actions have been undertaken in a problem area and to determine the success of individual
remedial actions. The overall objective of monitoring is to document the level of source control
achieved and the attainment of goals for environmental quality. With respect to sediments, the
focus of source monitoring should be on determining the success of source contaminant reduction
and control efforts. Contaminant loading data provide the most important information used in a
comparative analysis of sources. Contaminant concentration data for nonpoint sources or
wastewater discharges are important for determining if sediment and water quality goals will be
attained (e.g., by modeling the relationship between source loading and environmental contamina-
tion). Monitoring of sediment and water contamination provides a basis for determining the
ultimate effectiveness of source control, the rate of sediment recovery by natural processes, and the
possibility of recontamination by new or existing sources. The recommended frequency of
monitoring depends on the documented success of instituted source controls and natural
sedimentation rates. In most cases, monitoring on an annual basis will be adequate for sediment
variables. More frequent monitoring may be required for water column variables.
Guidance for the development of a monitoring program to determine the success of source
control within drainage basins has been developed as part of the urban bay action program for
Elliott Bay (Tetra Tech 1988c). The guidance incorporates the following decision points:
Is it feasible to sample sediments from storm drains and CSOs?
Is it feasible to sample sediment in the receiving environment?
Is an effects-based monitoring approach preferred (e.g., use of biological indicators
such as toxicity bioassay responses or community structure of benthic macroinver-
tebrates)?
Are analyses of both sediment toxicity and benthic communities desired?
Appropriate monitoring locations and environmental indicators are selected based on the responses
to these questions. Additional technical considerations included in the guidance document (Tetra
Tech 1988c) include timing and frequency of sampling and siting of monitoring stations. Other
sources of monitoring guidance are cited in Appendix C of this report.
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PUBLIC PARTICIPATION
Public participation serves several important functions in the urban bay approach. Formal
public participation allows the public to become part of the process and include their concerns in
the priorities of the program. Participation by the public also serves as a method to increase
awareness of urban bay problems among citizens and other interested parties. Continuing public
participation promotes increased program effectiveness by putting pressure on interagency work
group members, action teams, and specific dischargers to be accountable for implementation of the
action plan. Additional, public involvement in the urban bay program can enhance or facilitate
fiscal commitments by local, state, and federal programs. Citizen efforts to effect fiscal and
programmatic commitments may help achieve urban bay program goals. It is important that the
public understand why the program exists, the goals of the program, and the rationale and basic
technical findings of any scientific investigations conducted in support of action plans.
Although the extent of public involvement may be different in different urban bays based on
interest, timeliness, and current public involvement opportunities, the goals of public involvement
in the urban bay approach are the same. The urban bay approach to public involvement includes
the following objectives:
Involve the public in program development and decisionmaking. Public involvement
in urban bay programs is critical because the public can bring information, expertise,
values, funding, and priorities to the decisionmaking process. Resource management
programs that fail to educate and involve the public in a substantial and meaningful
way are often met with resistance or animosity. A successful urban bay program
needs to include participation both by organized citizen groups, which are designated
as representatives of certain sectors or perspectives, and individuals who represent
segments of the general public.
Provide the public with clear and accurate information on program activities. This
objective may be especially important early in the program, when public support
may facilitate federal and state funding. A necessary element of this effort is to
develop a public education plan or strategy to provide the mechanism(s) for allowing
public access to the process and to information generated by the program.
Obtain feedback from citizens during implementation of public participation
programs. For instance, work group meetings should have time set aside to answer
questions from citizen advisory committee members. A properly designed public
involvement program will allow for feedback and should result in necessary changes
in the mechanisms and information developed under the first objective. In addition,
citizen feedback will provide important information to decisionmakers regarding the
relative merit of cleanup programs and political accountability.
Provide a forum for political or technical conflicts to arise and be resolved
positively, in a manner that will not jeopardize the overall schedule. Often there
is a tendency for minor conflicts between interest groups and agencies or among
agencies to go unrecognized until a critical point is reached, resulting in project
delays until the conflict is resolved. A public involvement program cannot ensure
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that there will be no unresolvable conflicts and resultant project delays. However,
a well designed program minimizes this prospect by bringing potential opponents
into a process that is open and responsive.
There are many available mechanisms to achieve an appropriate level of public involvement
and information exchange (U.S. EPA 1980; Howell et al. 1987). For example, the public
involvement program may include the following elements:
Citizens advisory committee
Public tours of the urban bay with an environmental scientist to explain environ-
mental problems
Press conferences, public service announcements, or public meetings at key junctures
in the process, for example:
Foster public support for the program during the early planning phase of
the process
Disseminate information about environmental conditions and priority
problems after release of the initial data summary or significant sampling
and analysis results
Obtain public and private sector responses on planned activities after
release of the draft action plan
Disseminate information about program accomplishments after release of
an annual program status report.
Periodic memos, articles, or newsletters to disseminate technical information and
record program successes
Interpretive displays (e.g., posters showing the approach and results of an urban bay
action program) at a local aquarium or at scientific conferences that are open to the
public
Mailing list of interested people who receive documents for comment or review.
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CONCLUSIONS
As part of PSEP, the urban bay action programs have been effective in reducing releases of
toxic chemicals to Puget Sound and associated adverse biological effects. The urban bay approach
should be used in estuaries throughout the United States to reduce and ultimately eliminate
contaminated discharges and runoff which cause unacceptable levels of chemical contamination and
adverse biological effects. The success of the urban bay approach results primarily from
achievement of the following objectives:
Focus assessment and regulatory efforts on specific pollutant sources and
contaminated sites
Establish action teams to work in specific geographic areas
Facilitate remedial actions (without excessive studies and delays) by use of available
data and coordination among state and local agencies
Define specific commitments of agencies or individuals for permitting, inspections,
sampling, and other remedial activities
Establish mechanisms for accountability of participating agencies (e.g., involve
citizens, business-industrial organizations, public interest groups, and scientists in
decisionmaking to maximize support and accountability for the program)
Use field inspections and personal contacts with industries to encourage cooperation
in finding innovative, cost-effective solutions to toxics problems
Escalate regulatory and enforcement activities if warranted
Transfer technologies and solutions to new urban bays with similar problems.
The decisionmaking framework for the urban bay approach enables regulatory efforts to be focused
on contaminated areas posing the greatest environmental or public health risk. The central element
of the urban bay approach is the formation of an action team with sufficient training, regulatory
authority, and funding to effectively carry out field inspections, negotiate site cleanup, and enforce
discharge permits. Source control plans should be based on input from federal, state, and local
government agencies and from representatives of industry and citizen groups. A carefully
implemented public relations effort is essential if regulatory actions are to be perceived as both
necessary and fair, and if the program is to receive continuing support at state and local levels.
The long-term success of the urban bay action programs in Puget Sound and elsewhere
requires expansion of source control to include specific effluent limitations and testing for
toxicants, investigation and permitting of CSOs and storm drains, and continued interaction with
other programs. For example, hazardous waste programs such as Superfund and RCRA are active
in some urban bays of Puget Sound, and the urban bay programs can benefit from their sampling
activities and source control actions. In the Puget Sound region, Ecology (the industrial permitting
agency in Washington state), in cooperation with EPA, is requiring industrial permittees to monitor
their storm drain systems for toxic chemicals and to conduct biomonitoring and environmental
assessments (e.g., bioassays and sediment chemistry).
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The benefits of an urban bay action program include the formation of an efficient
environmental regulatory and management network; increased cooperation of industries, wastewater
dischargers, and other responsible parties in controlling sources of contaminants; and rapid response
by responsible parties to site-specific environmental problems. By providing a common forum for
public agencies, private industries, and informed citizens to address toxic contamination problems,
the urban bay approach enhances the effectiveness of existing regulatory programs. Cooperation
among agencies and coordination of sampling and analysis programs reduce duplication of effort
and maximize the efficiency with which funds are expended for environmental protection. This
common focus also consolidates often duplicative and confusing regulatory efforts of several
agencies with the result that responsible parties are often more responsive and more willing to
voluntarily implement source control actions. The focus of the urban bay approach on site-
specific problems encourages rapid response by agencies and responsible parties, because corrective
actions can be designed for a defined discharge or runoff problem, and actions are focused on areas
of highest priority (i.e., most severe environmental problems). In Puget Sound, the urban bay
action programs are the only water quality programs other than EPA's 304(1) program to address
observed in situ contamination problems. The site-specific focus of the urban bay action programs
may also minimize the tendency of public agencies to be overcome by the inertia of areawide
management plans that address multiple sites within a region simultaneously and require long-
term, expensive outlays of public funds.
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Tetra Tech. 1988c. Elliott Bay action program: guidance for development of monitoring programs
to evaluate the success of source control within drainage basins. Final Report. Prepared for U.S.
Environmental Protection Agency Region 10. Tetra Tech, Inc., Bellevue, WA. 37 pp. +
appendices.
Tetra Tech. 1989. Commencement Bay nearshore/tideflats feasibility study. Public Review Draft.
Prepared for Washington Department of Ecology and U.S. Environmental Protection Agency. Tetra
Tech, Inc., Bellevue, WA.
URS. 1986. Southern Puget Sound water quality assessment study. Comprehensive circulation and
water quality study of Budd Inlet. Final Report. Prepared for Washington Department of Ecology.
URS Corporation, Seattle, WA. 222 pp. + appendices.
U.S. COE. 1984. Evaluation of alternative dredging methods and equipment, disposal methods and
sites, and site control and treatment practices for contaminated sediments. Commencement Bay
Nearshore/Tideflats Superfund Remedial Investigation. COES003D. U.S. Army Corps of
Engineers, Seattle, WA. 300 pp.
U.S. COE. 1985. Decisionmaking framework for management of dredged material: application
to Commencement Bay, Washington. U.S. Army Corps of Engineers, Waterways Experiment
Station, Vicksburg, MS.
U.S. EPA. 1980. Public participation concepts and skills, March 24-25, 1980. (Workshop
notebook prepared by Barry Lawson Associates, Inc., Boston, MA). 160 pp.
U.S. EPA. 1985a. Methods for measuring the acute toxicity of effluents to freshwater and marine
organisms. U.S. Environmental Protection Agency, Washington, DC.
U.S. EPA. 1985b. Short-term methods for estimating chronic toxicity of effluents and receiving
water to freshwater organisms. EPA 600/4-85-014. U.S. Environmental Protection Agency,
Monitoring and Support Laboratory, Cincinnati, OH.
40
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U.S. EPA. 1985c. Technical support document for water quality-based toxics control. EPA
440/4-85-C32 (under revision). U.S. Environmental Protection Agency, Office of Water,
Washington, DC. 74 pp. + appendices.
U.S. EPA. 1986. RCRA ground water monitoring technical enforcement guidance document. U.S.
Environmental Protection Agency, Washington, DC. 208 pp. + appendices.
U.S. EPA. 1987a. Guide to nonpoint source pollution control. U.S. Environmental Protection
Agency, Office of Water, Washington, DC. 121 pp.
U.S. EPA. 1987b. Permit writers guide to water quality based permitting for toxic pollutants.
EPA 440/4-87-005. U.S. Environmental Protection Agency, Office of Water, Washington, DC.
U.S. EPA. 1987c. Training manual for NPDES permit writers.- U.S. Environmental Protection
Agency, Office of Water Enforcement and Permits, Washington, DC.
U.S. EPA. 1988a. Creating successful nonpoint source programs: the innovative touch. U.S.
Environmental Protection Agency, Office of Water Regulations and Standards, Nonpoint Sources
Branch, Washington, DC. 12 pp.
U.S. EPA. 1988b. Equilibrium partitioning approach to generating sediment quality criteria.
Draft Briefing Report. Prepared for the EPA Science Advisory Board. U.S. Environmental
Protection Agency, Office of Water, Office of Water Regulations and Standards, Criteria and
Standards Division, Washington, DC.
U.S. EPA. 1988c. Short-term methods for estimating chronic toxicity of effluents and receiving
water to marine and estuarine organisms. EPA 600/4-87/028. U.S. Environmental Protection
Agency, Monitoring Support Laboratory, Cincinnati, OH.
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APPENDIX A
The Urban Bay Toxics Control Program
Action Team Accomplishments - Executive Summary
(Ryan 1987)
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EXECUTIVE SUMMARY
Puget Sound is an estuary of immense value and importance to the Pacific Northwest, but its
water quality is threatened by contamination from a variety of toxic and conventional pollutants.
Past pollution control efforts, while addressing some pollution sources, have lacked the system-
wide approach needed to address current and anticipated problems.
In an effort to halt degradation of the estuary and improve the quality of water sediments, the
U.S. Environmental Protection Agency and the Washington State Department of Ecology joined with
other agencies and organizations in 1985 to develop and implement the Urban Bay Toxics Control
Program. This program is designed to identify existing problems of toxic contamination; identify
known and suspected pollutant sources; outline procedures to eliminate existing problems; and
identify agencies responsible for implementing corrective actions. The Urban Bay Toxics Control
Program was incorporated into the 1987 Puget Sound Water Quality Management Plan issued by the
Puget Sound Water Quality Authority. An "action team" selected for each bay provides the link
between problem identification and source control. Regulatory actions can include permitting,
enforcement actions and negotiation with responsible parties.
Actions to date have focused on Elliott Bay, Commencement Bay, and Everett Harbor. More
recently, some initial work has begun in Budd Inlet.
Since October of 1985, action teams have:
ELLIOTT BAY:
Conducted more than 221 inspections of 124 sites and facilities
Assessed 28 penalties amounting to $44,200
Issued 36 Notices of Violation
Issued 22 Administrative Orders
Issued 2 NPDES permits with effluent limitation and monitoring requirement
modifications
Targeted 15 contaminated sites for action and achieved final cleanup at 2 sites
Continued work on cleanup negotiations at 12 sites
Continued work on permit actions at 8 sites.
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COMMENCEMENT BAY:
Conducted 134 site inspections
Assessed 7 penalties amounting to $94,000
Issued 2 Notices of Violation
Issued 6 Administrative Orders
Negotiated 1 Memorandum of Agreement
Negotiated 7 Consent Orders
Negotiated 2 Consent Decrees
Targeted an additional 8 contaminated sites for enforcement action in Fiscal Year
1988
Initiated permit actions at 9 sites.
EVERETT HARBOR:
Conducted 23 site inspections
Issued 2 Notices of Violation
Issued 4 Orders
Issued 2 permits
Completed a pentachlorophenol spill cleanup.
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APPENDIX B
Evaluation of Remedial Actions
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EVALUATION OF REMEDIAL ACTIONS
Evaluation of potential source controls and sediment remedial actions to achieve an optimal
approach to remediation is described in this section. The role of environmental modeling to support
evaluation of alternative remedial actions is also discussed.
EVALUATION PROCESS
The process recommended for evaluation of potential remedial actions is shown in Figure B-l.
The first step in this process is to evaluate the natural recovery of the sediments that would be
expected to occur under various scenarios of source control (if ongoing sources are present). The
SEDCAM model (Jacobs et al. 1988), a model recently developed for use in Puget Sound, is a
simple tool that can be used to evaluate sediment recovery. Application of SEDCAM or other tools
enables the assessment of changes in the magnitude and extent of contamination and effects under
various recovery scenarios. In the example shown in Figure B-l, the area of greatest contamination
(shaded area) was predicted to disappear over time and the total problem area to decrease
considerably in overall spatial extent. The output of this first stage of the evaluation process is a
comparison of the present magnitude and extent of problem areas with predictions of future
sediment conditions.
The next step in the evaluation process is to quantify the environmental injury that has
occurred or is predicted to occur under various sediment recovery scenarios. In this step, the
relative value of degraded habitat must be evaluated. For example, the relative importance of a
specific habitat or biological community type may be compared among various locations (e.g., the
value of reduced crustacean abundances in an industrial waterway vs. the same effects in an area
of shellfish harvesting or recreational fishing). The procedure also enables comparisons of the
relative values of different biological effects such as benthic infauna depressions vs. elevated
prevalences of fish tumors.
This information on resource value can then be integrated with the costs of various sediment
remedial action alternatives in a cost-benefit analysis. The objective of this step is to compare the
costs of sediment remediation with the environmental benefits resulting from the remediation.
Many of the procedures developed for conducting natural resource damage assessments are
appropriate for this task. These analyses can then be used in the final step to evaluate whether a
candidate remedial alternative is justified. A specific procedure for cost-benefit analysis has not
yet been developed for the urban bay action programs in Puget Sound. Implementation of this step
will require the development of a decisionmaking framework with objective criteria for determining
the justification for sediment remedial actions. The output of this step will be a decision to either
proceed with sediment remedial action planning or to conduct only source control and monitor
natural recovery of the contaminated sediments.
Techniques used in the urban bay approach for selecting and evaluating sediment remedial
technologies were developed during the Commencement Bay nearshore/tideflats Superfund
investigation. Potential sediment remedial technologies were identified in the early stages of this
B-l
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Define Problem Area
Identify and
Characterize Sources
Modeling of Source
Control and Recovery
Remedial
Alternatives
Cost Analysis
Select Optimal
Sediment Remedial
Strategy
Evaluate Natural
Recovery
Compare Present vs. |
Future Effects
Quantify
Environmental Injury
1
Cost-Benefit
Analysis
Present
Future
Time
Sediment
Remediation
Justified?
Source Control
and Monitoring
Figure B-1. Evaluation of the need for sediment cleanup
B-2
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investigation (U.S. COE 1984) and were later expanded and refined (Tetra Tech 1987). Techniques
were also developed to organize information (by response option, technology type, and process
option), to screen technologies based on site and contamination characteristics, and to evaluate
candidate alternatives (Tetra Tech 1987; Tetra Tech 1989). The U.S. Army Corps of Engineers has
developed general guidance on selection strategies for dredged material disposal options (U.S. COE
1985). Although these strategies have not yet been formally applied to any of the urban bay action
programs in Puget Sound, the techniques have broad application to the remediation of contaminated
sediments.
ROLE OF ENVIRONMENTAL MODELING
Evaluation and implementation of criteria for sediment quality, remediation, and evaluation
of remedial actions may be facilitated by using database systems such as SEDQUAL (Nielsen 1989)
or models like SEDCAM (Jacobs et al. 1988). SEDQUAL is a database system for storing,
manipulating, and analyzing environmental data such as chemical concentrations in sediments,
toxicity bioassay results, and biological effects on indigenous populations. Models can provide key
links between potential causative agents and effects such as:
Source mass emission rate vs. extent and magnitude of sediment contaminationA
model of this relationship would enable evaluation of the environmental implications
of source control scenarios [e.g., DECAL (Farley 1987)].
Contaminant levels in surficial sediments following source control or natural
recoveryThis model would be important in evaluating optimal combinations of
source control and sediment remedial actions (e.g., SEDCAM).
Relationship between sediment contamination and biological effectsThese empirical
or theoretical models are important for predicting the occurrence of problem
sediments, defining cleanup levels, and determining management options [e.g.,
apparent effects threshold (AET), equilibrium partitioning].
Relationship between nonpoint source control measures and toxics dischargesThese
models would be used to evaluate the relative importance of various nonpoint sources
and alternative control strategies for limiting nonpoint sources of pollutants (e.g.,
various models in U.S. Environmental Protection Agency National Urban Runoff
Program studies).
Localized fate of pollutants associated with water quality or biological effectsSuch
models can be applied to specific embayments to evaluate localized transport and
water quality conditions [e.g., Budd Inlet Model (URS 1986)].
These models and others are candidate tools for assessing the two key links (pollutant source
to environmental contamination, and environmental contamination to biological effects) that are
required for making water quality management decisions in Puget Sound. Sediment quality values
developed using SEDQUAL (e.g., AET) may be used to define the boundaries of problem areas
designated for remediation. SEDQUAL may also be useful for evaluating costs of alternative
remedial actions following development of a cost analysis module for SEDQUAL (scheduled for
B-3
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funding by the Washington Department of Ecology). SEDCAM may then be used to modify
priorities for remediation based on evaluation of the effects of alternative remedial actions and the
need for remediation given predicted rates of natural recovery.
B-4
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APPENDIX C
Design of Sampling and Analysis Plans
to Support Urban Bay Action Programs
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DESIGN OF SAMPLING AND ANALYSIS PLANS
TO SUPPORT URBAN BAY ACTION PROGRAMS
Collection of data to support an urban bay action program may involve sampling and analysis
of sediments, sediment dwelling organisms, and contaminant sources. Data may be collected as part
of reconnaissance surveys to identify contaminant sources or toxic problem areas, detailed
investigations to characterize sources or environmental conditions, or monitoring to evaluate source
controls and sediment remedial action. The term investigation will be used in the text below to
denote sampling and analysis for any of the purposes just described. Sampling and analysis may
be conducted by the lead state agency as part of ongoing regulatory programs, by individual
wastewater dischargers and parties responsible for contaminated sites, or by an U.S. Environmental
Protection Agency (EPA) regional office or other environmental management agency (e.g., state
resource agencies, National Oceanic and Atmospheric Administration). Design of cost-effective
sampling and analysis plans, including specification of quality assurance/quality control (QA/QC)
measures, is a prerequisite to the collection of high quality data for characterization of toxic
sediment problem areas or contaminant sources. Guidance on design of sampling and analysis
plans is provided below.
The first step in developing a sampling and analysis plan is to define the technical objectives
and their relationship to management goals and data needs. Because the cost of a program is related
to sample replication and level of analysis (e.g., screening vs. full analysis), definition of precise
data needs and data quality objectives helps to achieve cost-effective designs. Relevant data should
be reviewed to define data gaps so that redundant information is not collected.
The following should be specified in a sampling and analysis plan:
Technical objectives
Variables to be measured
Locations of sampling stations
Timing and frequency of sampling
Sampling and analysis methods
Data to be recorded by laboratories
Data analysis approach and statistical design
Data management system and procedures.
A QA/QC plan should be developed for each sampling and analysis design. Available information
that can be used directly or adapted for sampling and analysis protocols and QA/QC plans includes
the EPA toxicity-based approach to water quality controls [U.S. EPA 1985c (especially relevant to
assessment of contaminant sources)], Puget Sound protocols (PSEP 1986), documents of the federal
Clean Water Act 301(h) program (Tetra Tech 1986b), and the urban bay action programs (e.g.,
storm drain assessment approaches developed for EPA Region 10; Tetra Tech 1988b).
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CHARACTERIZATION OF CONTAMINANT SOURCES
Evaluation of contaminant sources involves defining kinds and quantities of contaminants
released to the environment. Municipal sewage treatment plant discharges, direct industrial
discharges, industrial nonpoint sources, and other nonpoint sources that eventually discharge to
waterways via well-defined channels or pipes may be included in a point source investigation. The
term effluent refers to the discharge from any point source, including storm drains.
Investigations of point sources may include collection of data on effluent chemical
concentrations and effluent toxicity. These data can be used for the following objectives:
Estimate mass loading of contaminants
Determine effectiveness of source control
Determine compliance with discharge permit specifications.
Elements of a point source investigation may include one or more of the following:
Influent chemistry and flow (where applicable)
Effluent chemistry and flow (including storm drain discharges)
Freshwater effluent bioassays
Acute (U.S. EPA 1985a)
a. Juvenile salmonid mortality
b. Daphnia spp. mortality
c. Fathead minnow (Pimephales promelas) mortality
Chronic (U.S. EPA 1985b)
a. Ceriodaphnia dubia
b. Selenastrum capricornutum
c. Fathead minnow
Saltwater effluent bioassays
Acute (U.S. EPA 1985a)
a. Microtoxฎ
b. Mysid (e.g., Mysidopsis bahia) mortality
c. Bivalve (e.g., Mytilus edulis, Crassostrea gigas) larvae abnormality
d. Echinoderm (e.g., Dendraster excentricus) sperm abnormality
Chronic (U.S. EPA 1988c)
a. Mysid life cycle
Additional National Pollutant Discharge Elimination System (NPDES) requirements and
inspections (U.S. EPA 1987b,c).
Effluent quality measurements combined with toxicity tests provide the basis for evaluation of
contaminant mass loading, source controls, and potential toxicity (U.S. EPA 1985c). Measurements
of influent quality and flow (where applicable) will provide additional information for evaluation
of treatment efficiency.
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Strategies for tiered testing of point sources are discussed by U.S. EPA (1985c). Application
of screening approaches is recommended in reconnaissance surveys and in the initial phases of
designing a long-term monitoring program to determine the appropriate approach (i.e., balance of
chemical monitoring and kinds of biological tests). If screening of storm drains is needed to
determine priorities for source control, chemical measurements on sediment samples collected from
within outfall pipes or drains (above tidal influence) are provisionally recommended. In Puget
Sound, the value of this technique has been assessed by EPA and the Washington Department of
Ecology (Ecology) as part of the Elliott Bay Action Program (Tetra Tech 1988b). Further validation
of this technique is warranted. For example, the degree to which grain size sorting influences the
results, and the correlation between concentration of contaminants in sediments and those in the
stormwater discharge has not been well studied.
In the Puget Sound region, EPA and Ecology are designing monitoring programs for point
sources (including some storm drains and combined sewer overflows) to ensure compliance of
NPDES dischargers with permit conditions. The NPDES process now includes restructuring of
permits to incorporate specific limits on toxic substances and increased monitoring, especially
biomonitoring of effluents. Guidance on sampling and analysis of contaminant sources presented
in this section is generally consistent with planned elements of the NPDES program. However, it
should be recognized that the elements of NPDES monitoring, especially the specific biomonitoring
tests, are in a process of development.
Because the characteristics of different discharges can vary substantially, a single sampling
scheme will not be applicable to all discharges. It is likely that sampling and analysis programs
will include a range of techniques. One major difference among discharges is whether the effluent
is fresh or saline water. As indicated in the list of chemical and biological tests above, the salinity
of the effluent affects the choice of biological tests. Aside from potential differences in effluent
composition, the major distinction between storm drains and other kinds of discharges is the high
variability of both effluent flow and chemical composition of stormwater discharges compared with
other point sources. Differences in recommended sampling and analysis designs for various kinds
of discharges are discussed by U.S. EPA (1985c), Bergman et al. (1986), and PTI (1988).
Groundwater investigations may be conducted at facilities where groundwater infiltration
transports contaminants offsite. Characterization of contaminant transport by groundwater is a
complex task, and requires a great deal of preliminary characterization of site geology and the
flow regime to adequately describe the physical factors controlling contaminant transport.
Superimposed on the physical flow regime are additional processes that may influence transport of
a chemical such as sorption, precipitation, or in the case of volatile chemicals, outgassing to the
soil atmosphere. Monitoring provides a means of documenting changes in contaminant loading to
the waterway. Guidance on sampling and analysis designs for groundwater investigations is
provided in the RCRA Groundwater Monitoring Technical Enforcement Guidance Document (U.S.
EPA 1986).
CHARACTERIZATION OF TOXIC SEDIMENT CONTAMINATION AND BIOLOGICAL
EFFECTS
At least five types of environmental indicators can be used to characterize sediment contami-
nation and biological effects:
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Sediment Chemistry
Contaminant concentrations for toxic chemicals and ancillary variables (e.g.,
sediment grain size, sulfides, and total organic carbon)
Bioaccumulation
Pesticide, polychlorinated biphenyl, mercury or other chemical concentrations in
muscle tissue of bottomfish or commonly harvested species
Sediment Bioassays
Amphipod (e.g., Rhepoxynius abronius) mortality
Oyster larvae (e.g., Crassostrea gigas) abnormality
Bacterial luminescence (Microtoxฎ)
Polychaete (Neanthes arenaceodentata) growth/mortality
Benthic Macroinvertebrate Abundances
Major taxa abundances (e.g., polychaetes, crustaceans, pelecypods, gastropods)
Species abundances
Fish Pathology
Lesion (e.g., tumor) prevalence in livers of bottomfish.
Although many other variables may be evaluated throughout the decisionmaking process, the
indicators listed above are recommended for problem area identification and priority ranking. The
rationale for using the five kinds of environmental indicators is provided by Tetra Tech (1985) and
PTI and Tetra Tech (1988a,b). As described in the next section, various combinations of selected
indicators can be used for different purposes (e.g., reconnaissance survey vs. detailed investigation)
or in different phases of an urban bay action program.
OPTIONAL SAMPLING AND ANALYSIS STRATEGIES TO ENHANCE COST EFFECTIVENESS
Tiered strategies of sampling and analysis should be evaluated to increase the cost effective-
ness of investigations of sources and sediments. For example, tiered strategies should be evaluated
at the following three levels in the study design process for environmental sampling:
Selection of sampling station locations and densityThe first tier of an investigation
may use widely spaced sampling locations over the whole project area, whereas the
second tier may use dense sampling within smaller selected areas identified as high
priority during the first tier.
Selection of variablesThe first tier may involve analysis of an inexpensive
screening variable [e.g., total polycyclic aromatic hydrocarbons (PAH) screen] using
all samples, whereas the second tier may involve more expensive analyses to develop
more specific information (e.g., individual PAH compounds) on selected samples
identified as the highest priority during the first tier.
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Selection of number of replicate samplesThis strategy involves sequential laboratory
analysis of replicate samples and corresponding data analysis to provide feedback on
information gained with each successive analysis. The potential benefit is realized
when the amount of information is judged adequate before all sample replicates have
been analyzed.
Cost effectiveness of a design should be analyzed to ensure that the final design meets data quality
objectives and budget constraints. Some statistical approaches to support cost-benefit analyses of
sampling designs are available from the Clean Water Act 301(h) program (Tetra Tech 1986a).
An example of one approach to streamlining the procedures for characterizing problem areas
is presented in Figure C-l. This approach relies primarily upon the areawide indicators (fish
histopathology and bioaccumulation) in an initial (Phase I) assessment of the study area. In special
cases, the site-specific variables of sediment contamination, sediment toxicity, and benthic
macroinvertebrate effects may be applied at a very few high priority stations (e.g., in depositional
areas, near major pollutant sources) to document the expected worst-case conditions in each study
area. The objective would be to define those general areas with the greatest environmental hazard
by using the relatively inexpensive areawide indicators (especially compositing of fish tissue) in
conjunction with minimal use of the relatively expensive site-specific variables as part of Phase I
studies. As previous investigations have shown, the areawide indicators correlate well with the
general locations of problem sediments (Malins et al. 1984; Tetra Tech 1985; PTI and Tetra Tech
1988a,b).
The results of these Phase I studies can be processed relatively quickly and can be used to
focus the more detailed assessments using more intensive application of the site-specific variables.
The Phase II studies could then be designed based on the Phase I results, in conjunction with
historical information on the area. The relatively expensive Phase II variables (i.e., chemistry,
bioassays, and benthic macroinvertebrate variables) should be focused only on the high priority
areas, potentially resulting in a substantial cost savings. In the final step, the areawide variables,
site-specific variables, and historical data could be integrated to prioritize problem areas.
The Phase II site-specific variables could be applied using a tiered approach. The approach
involves an increasing level of analysis that provides the lead agency with increased degrees of
confidence in the identification of problem areas. The level of analysis can be adjusted to match
specific agency objectives and cost constraints. At each station, an adequate amount of sediment
should be collected to allow potential evaluation of all Phase II indicators. The screening level
analyses should proceed immediately after field sampling. Subsequent analyses can be conducted
later (if necessary) on previously frozen subsamples for chemical analyses and preserved samples
for benthic macroinvertebrate analyses.
In the first tier, samples should be analyzed for screening chemical variables (e.g., total PAH)
and inexpensive bioassays (e.g., Microtoxฎ, amphipod mortality). If any of the screening chemical
or biological variables indicate a problem, then full chemical analyses may be recommended. In
Puget Sound, the results of these detailed chemical analyses could be compared with benthic
apparent effects threshold (AET) to determine whether effects on indigenous biota are likely. If
one or more AET are exceeded, then benthic macroinvertebrate analyses at the major taxonomic
level may be recommended to verify the predicted effects. If major taxa are found to be
depressed, then species-level benthic analyses may be desired in special cases to provide additional
information on the adverse effects to indigenous biota, (e.g., Are pollution-sensitive species
depressed and pollution-tolerant species enhanced, or are important prey species of fishes
depressed?) The strength of the tiered Phase II approach is its flexibility to allow a variable
combination of analyses to be conducted from a single field sampling effort.
C-5
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Design Phase I
Sampling Program
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