EPA 910/9-91-025
Puget Sound Estuary Program
BUDD INLET
URBAN BAY ACTION PROGRAM:

1991 Action Plan

                                 -

July 1991

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PTI
ENVIRONMENTAL SERVICES
15375 SE 30th Place
Suite 250
Bellevue, Washington 98007
BUDD INLET URBAN BAY ACTION PROGRAM:

1991 Action Plan


By
Michael A. Jacobson and Patricia A. Canterbury
Prepared for

U.S. Environmental Protection Agency
Region 10, Office of Coastal Waters
1200 Sixth Avenue
Seattle, Washington 98101
EPA Contract 68-D8-0085
PTI Contract C744-02
July 1991

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Table of Contents
      List of Figures                                                           iv
      List of Tables                                                            iv
      List of Acronyms and Abbreviations                                         v
      Acknowledgments                                                        vi
      Executive Summary                                                      ix
      Introduction	1
            Budd Inlet Action Program	3
                  Implementation of the 1991 Action Plan	6
                  Coordination with Other Areawide Plans and
                  Programs	8
                  Technical Approach for Identifying and Ranking
                  Problem Areas	10
            Overview of Budd Inlet and Associated Contamination
            Problems	14
                  General Description of Area	14
                  Description of Priority Problem Areas	16
      1991 Action Plan for Budd Inlet    	23
            Comprehensive Plans and Programs	23
                  U.S. Environmental Protection Agency	23
                  U.S. Army Corps of Engineers	24
                  U.S. Fish and Wildlife Service	25
                  Squaxin Island Tribe	26
                  Washington Department of Ecology	27
                  Washington Department of Fisheries	32
                  Washington Department of General Administration	33
                  Washington Department of Transportation	34
                  Washington Department of Health	34
                  Washington Parks and Recreation Commission	36

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            Puget Sound Water Quality Authority	37
            Puget Sound Ambient Monitoring Program	37
            Washington Department of Natural Resources	38
            City of Olympia Planning Department	39
            City of Olympia Public Works Department	40
            Thurston County Office of Water Quality and
            Resource Management	43
            Thurston County Health Department	44
            Thurston County Public Works	46
            Port of Olympia	46
            City of Tumwater Public Works Department	48
            City of Tumwater Department of Community and
            Economic Development	49
            LOTT Wastewater Treatment Program	49
      Site-Specific Action Plan	51
Data, Planning, and Contaminant Control Needs                            75
      Planning/Coordination Needs	75
      Data Needs	77
      Contaminant Control Needs	79
Glossary of Terms	81
References	85
Appendix A     Administrative Record of Agency Letters of Commitment
Appendix B     Available Funding Sources:  Urban Bay Action Plan
                Implementation
Appendix C     Summary of South Sound Reconnaissance Study
Appendix D     List of EPA Technical Studies  in Support of Urban Bay
                Action Programs
                                 in

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List of  Figures
      Figure 1.  Project location of the Budd Inlet Action Program                       2

      Figure 2.  Decision points and elements of the Budd Inlet Action Program           4

      Figure 3.  Environmental indicators used to define problem areas of
                sediment contamination and biological effects                          11

      Figure 4.  Primary and secondary problem areas in Budd Inlet                    17

      Figure 5.  Locations of known and potential point and nonpoint sources
                of contaminants in Budd Inlet                                       19

      Figure C-l.  Sampling station locations in Budd Inlet from South Sound
                  Reconnaissance Survey                                  Appendix C
List of  Tables	


      Table 1.   Criteria for prioritizing problem areas in Budd Inlet                    12

      Table 2.   Source-specific actions                                             53

      Table 3.   Planning and program development actions                           60

      Table 4.   Contaminant control actions                                        64

      Table 5.   Remedial investigations                                            67

      Table 6.   Monitoring actions                                                68

      Table 7.   Resource protection actions                                        71

      Table 8.   Educational actions                                                72
                                        IV

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List  of Acronyms  and Abbreviations
      AET           apparent effects threshold
      Authority       Puget Sound Water Quality Authority
      BMP           best management practice
      CCMP          comprehensive conservation and management plan
      CED           City of Tumwater Department of Community and Economic Development
      CERCLA       Comprehensive Environmental Response, Compensation and Liability Act
      Corps          U.S. Army Corps of Engineers
      CSO           combined sewer overflow
      CWA          Clean Water Act
      DNR           Department of Natural Resources
      DOH           Washington Department of Health
      DOT           Washington Department of Transportation
      Ecology         Washington Department of Ecology
      EIS            environmental impact statement
      EPA           U.S. Environmental Protection Agency
      FWS           U.S. Fish and Wildlife Service
      GIS            geographic information system
      LOTT          Lacey, Olympia, Tumwater, and Thurston County Wastewater
                     Treatment Program
      MGD          million gallons per day
      MOA          Memorandum of Agreement
      MTCA          Model Toxics Control Act
      NEPA          National Environmental Policy Act
      NPDES         National Pollutant Discharge Elimination System
      PAH           polycyclic aromatic hydrocarbon
      PIE            Public Involvement and Education
      ppb            part per billion
      ppm           part per million
      PSAMP         Puget Sound Ambient Monitoring Program
      PSDDA         Puget Sound Dredged Disposal Analysis
      PSEP          Puget Sound Estuary Program
      PSWQMP       Puget Sound Water Quality Management Plan
      RCRA          Resource Conservation and Recovery Act
      RCW          Revised Code of Washington
      SEPA          State Environmental Policy Act
      TSCA          Toxic Substances Control Act
      WARM         Washington Ranking Method
      WDF          Washington Department of Fisheries
      WWTP         wastewater treatment plant

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Acknowledgments
                         This document was prepared by PTI Environmental Services under
                         the direction of Mr. Michael Jacobson for the U.S. Environmental
                         Protection Agency (EPA) Region 10, Office of Puget Sound, in
                         partial fulfillment of Contract No. 68-D8-0085.  The  primary
                         authors of this report are Mr. Michael A. Jacobson and Ms. Patricia
                         A. Canterbury of PTI Environmental Services. Ms. Melany Vorass
                         of the Washington Department of Ecology contributed Tables 2-8
                         of the site-specific action plan.  Ms. Joyce  Mercuri of the Wash-
                         ington Department of Ecology contributed the Data, Planning, and
                         Contaminant Control Needs section.  The development of this
                         report was funded by the National Estuary Program, under the
                         authority of the Clean Water Act as amended in 1987.  Funding was
                         approved by the EPA Office of Marine and Estuarine Protection.
                         Mr. Michael Rylko served as the project manager for EPA Region 10.

                         The Budd Inlet Urban Bay Action Program has benefitted  from the
                         participation of members of an interagency work group and a citizen
                         advisory committee.  Duties of the work group and advisory
                         committee members include 1) reviewing program documents,
                         agency policies, and proposed actions; 2) providing data reports and
                         other technical information to EPA; and 3) disseminating action
                         program information to constituencies or interest groups. The past
                         and continuing efforts of the Budd Inlet Interagency  Work Group
                         and Citizen Advisory Committee are greatly appreciated.  Special
                         thanks are extended to Ms. Melany Vorass, the Budd Inlet Action
                         Program coordinator, for chairing the work group activities. Mem-
                         bers of the Budd Inlet Interagency Work Group and Citizen
                         Advisory Committee and other contributors are listed below.
                                Budd Inlet Interagency Work Group

                              Name	Affiliation	

                         Bob Arndt             Washington Department of General
                                               Administration
                         Doug Baker            City of Tumwater, Community and Eco-
                                               nomic Development
                         Peggy Britt/            Washington State Parks and Recreation
                         Doug Strong
                         Bill Cleland            Washington Department of Health
                         Andrea Copping        Puget Sound Water Quality Authority
                                                     VI

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A cknowledgments
                            Name
                       Affiliation
                         Linda Cox
                         Jeff Dickison
                         Gwill Ging
                         Jerry Hendricks
                         Linda Hoffman
                         Cliff Ikerd

                         David Jamison/
                         Phil Herzog
                         Marziah Kiehn
                         Tom Kolby

                         Dick Malin
                         Neil Rickard/
                         Connie Iten
                         Joanne Richter
                         Michael Rylko
                         Laura Schleyer
                         Mike Sharar

                         Melany Vorass
          U.S. Army Corps of Engineers
          Squaxin Island Tribe
          U.S. Fish and Wildlife
          City of Tumwater, Public Works
          Thurston County Office of Water Quality
          Washington  Department  of General
          Administration
          Washington  Department  of Natural
          Resources
          City of Olympia, Planning Division
          City  of Olympia;  Lacey,  Olympia,
          Tumwater, and Thurston County Waste-
          water Treatment Program
          Port of Olympia
          Washington Department of Fisheries

          City of Olympia, Water Resources Program
          U.S. Environmental Protection Agency
          Thurston County Conservation District
          Lacey, Olympia, Tumwater, and Thurston
          County Wastewater Treatment Program
          Washington Department of Ecology
                            Name
   Budd Inlet Action Plan
Citizen Advisory  Committee
                   Affiliation
                         Bruce Briggs
                         Adrian Brown
                         Bruce Fortune
                         Lon Freeman
                         Susan Markey
                         Margery Sayre
                         Larry Sidor
                         Doug Swenson
          Citizen
          Black Hills Audubon Society
          American Littoral Society
          Citizen
          Black Hills Audubon Society
          Citizen
          Pabst,  Inc.
          Sierra  Club
                                                     VII

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                                       A ckno wledgments
   Name
Budd Inlet Action  Plan
  Other Contributors
                   Affiliation
Kevin Anderson

Dan Dole
Paula Ehlers
Tim Flint
Sheila Kelly
Don Leaf
Rob Lowe

Patti Miller-Crowley

Rick Nelson

Clive Pepe
Vallana Piccolo
Dom Reale

Paul Taylor
Julia Walton
Fran Wilshusen
       Washington  Department of Ecology,
       Water Quality Program
       City of Olympia Fire Marshal
       City of Olympia Planning Division
       Washington Department of Fisheries
       Puget Sound Water Quality Authority
       Thurston County Health Department
       City of Olympia;  Lacey, Olympia,
       Tumwater, and Thurston County Waste-
       water Treatment Program
       Washington Department of Community
       Development
       Thurston County Conservation District
       and Dairymen's Federation
       Washington Department of Health
       Puget Sound Water Quality Authority
       Washington  Department of Ecology,
       Toxics Cleanup Program
       Thurston County Conservation District
       City of Olympia, Planning Department
       Squaxin Island Tribe
                           VIII

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Executive Summary
                          Previous studies of Budd Inlet have revealed widespread bacterial
                          contamination, low levels of dissolved oxygen (resulting from
                          eutrophication) in the water, and chemical contamination of sedi-
                          ment and marine organisms.  Eutrophication and chemical contam-
                          ination pose hazards to the aquatic ecosystem. For example, toxic
                          contamination may decrease the abundance and diversity of benthic
                          invertebrate organisms, increase the prevalence of tissue disorders
                          such as liver tumors in fish, and result in the accumulation of
                          chemicals in the tissue of fish and shellfish. Further, chemical and
                          bacterial contamination may result in human health problems when
                          contaminated fish and shellfish are eaten.  Chemical and bacterial
                          contamination may also reduce commercial and recreational shell-
                          fish harvesting due to beach closures.

                          The U.S. Environmental Protection Agency and the Washington
                          Department of Ecology, working with the Lacey, Olympia, Tumwa-
                          ter, and Thurston County Wastewater Treatment Program, the cities
                          of Olympia and Tumwater, Thurston County, the Squaxin Island
                          Tribe, the Port of Olympia, and others, developed the Budd Inlet
                          Action Plan to reduce water quality problems in the Budd Inlet
                          system.  A Citizen  Advisory Committee, composed of interest
                          group representatives and citizens, aided in setting  goals and
                          developing  the plan.  The Urban Bay Action Program 1) identifies
                          priority problem areas of contamination; 2) identifies current,
                          historical, and potential sources of contaminants; 3) establishes
                          schedules to take corrective actions to eliminate existing problems
                          and to investigate potential problems; and 4) identifies appropriate
                          agencies for implementing corrective actions.  Ongoing coordina-
                          tion among participating agencies and citizens will be provided by
                          the Washington Department of Ecology, which funds a full-time
                          coordinator for the Budd Inlet  Action Program.   Authority for
                          implementation of the 1991 Action Plan is derived from various
                          federal, state, and local environmental regulations and is specified
                          under the industrial and municipal discharge control element (P-13)
                          in the Puget Sound Water Quality Management Plan.

                          In 1988, the U.S. Environmental Protection Agency analyzed
                          available data on eutrophication, bacterial and chemical contamina-
                          tion,  and related adverse biological effects. Priority problem areas
                          were identified in Budd Inlet based on these  data.   For example,
                          areas received a high priority ranking for action if they exhibited
                                                      IX

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Executive Summary
                           particularly high levels of contamination or adverse biological
                           effects such as nigh mortality rates of organisms in sediment toxicity
                           tests.  The regulatory and management efforts of the 1991 Action
                           Plan focus on sources that are most directly related to priority
                           problem areas. The highest priority problem areas for eutrophica-
                           tion are all located in southern Budd Inlet.  Priority problem areas
                           for microbial contamination exist throughout Budd Inlet and include
                           areas near Moxlie Creek, Boston Harbor, Ellis Creek, and Tykle
                           Cove.  Priority problem areas  for  sediment contamination are
                           located in the southern portion of the inlet and include areas near
                           the McFarland/Cascade Pole Company, the West Bay drain, and
                           Fiddlehead Marina.

                           Actions to correct problems may include remedial (cleanup) activ-
                           ities such as source control  and sediment cleanup activities. Con-
                           trolling individual sources may be  accomplished by  revising
                           permits, licensing currently unpermitted discharges, and developing
                           specific contaminant control  techniques.   Source control efforts
                           include reducing concentrations or volumes of discharges to prevent
                           further environmental problems.  Sediment remedial actions, such
                           as removal or capping of contaminated sediments,  correct existing
                           environmental problems.

                           The action  plan  specifies  a  broad array of actions proposed to
                           improve the environmental  quality of Budd Inlet, including:

                              •  Planning and Program Development Actions—The Urban
                                 Bay Action Program, via the Initial Data Summaries and
                                 1991 Action Plan reports, integrates local planning activi-
                                 ties,  ensures consistency among the various environrr  :^tal
                                 programs, and provides a mechanism for public review to
                                 ensure accountability for implementation of agency activities

                              •  Contaminant Control Actions—The Port of Olympia will
                                 complete a log yard storm  water management project by
                                 paving log storage areas and constructing and maintaining
                                 detention swales

                              •  Remedial Investigation Actions—The Washington Depart-
                                 ment of Ecology  will conduct initial investigations of 30
                                 industrial and commercial facilities, including Dunlap Tow-
                                 ing and Reliable Steel

                              •  Monitoring Actions—The  Squaxin Island Tribe plans to
                                 conduct habitat surveys in Indian, Moxlie, Percival, Ellis,
                                 and Mission creeks

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                                          Executive Summary
   •  Resource Protection Actions—The Washington Depart-
      ments of Fisheries, Ecology, and Natural Resources will
      evaluate the impacts of nutrient loading from salmon rearing
      pens

   •  Educational Actions—The Budd Inlet Action Plan Citizen
      Advisory Committee will educate the public on cleanup
      activities at the McFarland/Cascade Pole hazardous waste
      site.

The 1991 Action Plan is a working document that will be refined
as new data are made available.  An interagency urban bay action
team, comprising technical and planning staff from local, state,
tribal, and federal agencies, will meet two to four times per year to
coordinate action plan implementation, review progress made on
implementation, resolve any problems, and refine the plan to reflect
new information and activities.  The Washington Department of
Ecology's Action Program Coordinator has responsibility for the
long-term coordination of the action plan and implementation of
source control actions.
                             XI

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Introduction
                          In response to widespread concern over the environmental health
                          of Puget Sound, several agencies with regulatory, resource manage-
                          ment, and research responsibilities initiated the Puget Sound Estuary
                          Program (PSEP) in 1985.  The primary objectives of PSEP are to
                          protect the sound and its living resources and to improve the
                          condition of contaminated areas.  As a primary element of PSEP,
                          the Urban Bay Action Program was established to address the most
                          severe contamination problems in Puget Sound, which occur in
                          embayments near urban areas.

                          The Urban Bay Action Program focuses on identifying and reducing
                          eutrophication and bacterial and chemical contamination through a
                          series of coordinated actions by government agencies and respon-
                          sible parties (e.g., owners and operators of the facilities that are
                          sources of contamination).  Contaminant control activities  may
                          include improving drainage or treatment systems for storm water
                          and sewage, developing stricter permit conditions for wastewater
                          dischargers, enforcing hazardous materials regulations, and initiat-
                          ing best management practices (BMPs) or cleanup measures at sites
                          of concern. A guidance document, The Urban Bay Action Program
                          Approach: A Focused Toxics Control Strategy (PTI1990) describes
                          the overall goals and details of the Urban Bay Action Program in
                          more detail.

                          Under the Urban Bay Action Program, Budd Inlet was identified in
                          1986 as a priority area for problem identification and corrective
                          action  planning.   Budd Inlet is an embayment in southern Puget
                          Sound; the city of Olympia is located at its southern extremity (see
                          Figure 1). In April 1988, existing data were collected and analyzed
                          to identify and prioritize problem areas (Tetra Tech 1988).  The
                          1991 Action Plan is based on this data summary report and on
                          extensive discussions with the government entities that have respon-
                          sibility for protecting the environmental quality of Puget Sound.

                          The 1991 Action Plan  describes the comprehensive plans and
                          programs that address contaminant sources and problem areas on
                          an areawide basis and the individual corrective actions developed
                          for specific sites  and sources within the Budd Inlet project area.
                          Corrective actions are described for each priority problem area and
                          potential contaminant source.  Problem  areas and sources were
                          identified by Tetra Tech (1988) and participating agencies during

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                              Cooper              Dover
                               Point PROJECT BOUNDARY Point
Figure 1. Project location of the Budd Inlet Action Program

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                                                 Introduction
the development of the 1991 Action Plan. For each priority problem
area and associated contaminant sources, the plan specifies the first
steps  toward corrective actions,  the agencies responsible for
implementing those actions, targeted implementation schedules, and
any factors that may limit effective implementation of a given task.
The remainder of this introduction provides a description of the
Urban Bay Action Program and an overview of Budd Inlet and its
associated contamination problems.
Budd Inlet Action Program

In July 1986, PSEP co-managing agencies initiated the Budd Inlet
Action Program.  The PSEP co-managing agencies are the U.S.
Environmental Protection Agency (EPA), the Washington Depart-
ment of Ecology (Ecology), and the Puget Sound Water Quality
Authority (the Authority).   Through  a process of  interagency
coordination, local government support, and public participation,
the Budd Inlet Action Program  has focused new and continuing
efforts to control contaminants in the priority problem areas within
the inlet. The objectives of the action program are to:

    •  Identify specific areas of concern based on levels of eutro-
      phication, bacterial and chemical contamination, and asso-
      ciated adverse biological  effects and natural  resource
      impacts

    •  Identify historical and ongoing sources of eutrophication and
      contamination

    •  Rank contaminated areas and sources to  set priorities for
      development of corrective actions

    •  Implement corrective actions to reduce or eliminate eutro-
      phication and sources of bacterial and chemical contamina-
      tion and restore contaminated  areas to  support natural
      resources and beneficial uses.

The major decision points and programmatic elements of the Budd
Inlet Action Program are presented in Figure 2.

The Budd Inlet Action Program has followed a process in which
cooperative efforts by federal, tribal, state, and local officials have
helped to define problem areas, focus environmental monitoring
efforts, and plan and implement corrective actions.   Interagency
coordination is fostered through an Interagency Work Group.  The

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     Sampling and
       Analysis
                                  Evaluate Available
                                     Information
                                    Initial Problem
                                     Identification
Action Plan
                                      Sediment
                                    Management
                                Potential Action
                                 Team Activities

                                Source Control
                                Permitting
                                Inspections
                                Enforcement
                                Sediment Remedial
                                Planning
                                    Environmental
                                  Monitoring Program
                                         i
                                   Action Program
                                      Evaluation
Major input and decision points for the interagency
work group and the citizen advisory committee

Elements of the Urban Bay process
      Figure 2. Decision points and elements of the Budd Inlet Action Program.

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                                                 Introduction
work group is composed of representatives from federal, state, and
local agencies and the Squaxin Island Tribe. Environmental groups
and other interest groups, neighborhood associations, area business
organizations, and interested  citizens were invited to participate in
the Citizen Advisory Committee (see Acknowledgments section for
full membership list of the work group and advisory committee).
The work group and the advisory committee are responsible for
reviewing documents, suggesting actions, and providing input to
the planning process.

The planning process for development of the 1991 Action Plan was
completed in several stages.  First, an initial data  summary and
problem identification report was completed (Tetra Tech 1988).
Next, individual meetings were  held with representatives from
agencies with jurisdiction or responsibilities pertaining to environ-
mental quality within the  study area.  These meetings provided
information concerning the current and planned activities of each
agency. Following the meetings, a source-action matrix was devel-
oped and presented to the work group and members of the advisory
committee. The matrix presented  the types of environmental prob-
lems and associated actions  that  agencies were implementing to
address contamination problems.  In addition, the matrix served to
identify gaps in management programs, contaminant source control,
and data collection efforts.

Following presentation of the matrix, agency representatives were
again consulted to cooperatively negotiate how each agency would
commit resources to help implement additional preventative or
corrective actions or gather information to fill data  gaps.  Letters
were sent by Ecology to  confirm agency commitments.   These
letters and agency replies constitute the administrative record for
the action plan and are contained  in Appendix A. A second work
group meeting was held to review and discuss the combined
commitments of each agency and to further enhance interagency
communication and coordination. The 1991 Action Plan and the
status of its implementation  will be continually reviewed as new
data become available to  refine  the definition of environmental
problem areas and contaminant sources and as agency action
agendas evolve.

The 1991 Action Plan focuses  on source control to minimize
contaminant inputs and serves as a blueprint for source control
activities, including field investigations and permit reviews. Other
corrective actions may also be specified, including alternatives for
cleaning up contaminated sediments and environmental monitoring
to evaluate the success of source control.  Examples of sediment

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Introduction
                          cleanup activities include capping contaminated sediments with
                          uncontaminated materials and removing the contaminated sediments
                          by dredging. Because sediment cleanup actions are most likely to
                          be implemented only after significant source control (to minimize
                          the probability of future recontamination and additional cleanup),
                          sediment cleanup is likely to be a long-term rather than short-term
                          component of the Budd Inlet Action Program. Monitoring is also
                          a long-term component of the action program. Existing monitoring
                          programs will be coordinated and the data will be used to evaluate
                          the effectiveness of source control and sediment remediation efforts
                          (see Figure 2).
Implementation of
the  1991  Action
Plan
In 1988, EPA formally designated Puget Sound as an estuary of
national significance under the federal Clean Water Act (CWA).
Section 320 of the CWA requires the development of a comprehen-
sive conservation and management plan (CCMP) for each desig-
nated  estuary.   The 1987, 1989, and 1991 Puget Sound Water
Quality Management Plan (PSWQMP), developed by the Authority,
meet  all  the requirements of a CCMP.  Development of the
PSWQMP is conducted under Section 90.70 of the Revised Code
of Washington (RCW).  Element P-13 of the draft 1991 PSWQMP
states that the "urban bay approach" is an essential part of a
comprehensive strategy to control sources of toxic contamination.
Implementation of the Budd Inlet Action Plan and other urban bay
action plans is part of the overall implementation of the PSWQMP.
 Regulatory Authority
Ecology, EPA, and many other agencies have regulatory authority
to implement specific elements of the 1991  Action Plan.  This
regulatory authority stems from discharge permit programs and
inspection requirements under federal and state water quality regu-
lations such as the CWA and the state Water Pollution Control Act.
Additional authority is  derived from hazardous substance control
regulations, such as the federal Comprehensive Environmental
Response, Compensation and Liability Act [CERCLA (also known
as Superfund)], federal  Resource Conservation and Recovery Act
(RCRA), federal Toxic Substances Control Act (TSCA), state
Model Toxics Control Act (MTCA), county regulations for solid
waste and hazardous waste, and health  department  regulations.
Other important laws include  the state combined sewer overflow
(CSO) control regulation, the state Shoreline Management Act, the
State Environmental Policy Act (SEPA), and the National Environ-
mental Policy Act (NEPA).

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                                                                            Introduction
                           Under the above regulations, Ecology is the agency responsible for
                           issuing and revising wastewater and industrial waste discharge
                           permits, conducting site inspections, and overseeing cleanup plans
                           for contaminated sites.  Ecology also has regulatory authority over
                           storm drains that discharge to state waters.

                           Ecology can implement formal compliance procedures such as
                           warning letters, notices of violation, penalties, consent orders, and
                           administrative orders.   However,  the  preferred approach to
                           implementing the 1991 Action Plan is to work cooperatively with
                           all involved parties. Voluntary commitment to perform the actions
                           set forth in the action plan is the most efficient and cost-effective
                           approach to addressing point and nonpoint contaminant sources in
                           Budd Inlet.  Successful  implementation  of the action plan will
                           require the cooperation of all parties within the Budd Inlet water-
                           shed.
Funding
Successful implementation of the action plan also depends on
adequate funding.   The Washington State legislature and  U.S.
Congress have passed major legislation designed to protect water
resources that includes provisions for funding.  This legislation
includes the CWA, the state Centennial Clean Water Fund, the
Aquatic Lands Enhancement Account, and the Coastal Zone Man-
agement Program.  Various grants and low-interest loans are avail-
able through programs administered through the above-mentioned
legislation.   (See Appendix  B for a more thorough discussion of
potential funding sources.)
Action Team
Development
As part of the Budd Inlet Action Program, Ecology will establish
and lead an interagency action team to guide the implementation of
the action plan.  The Budd Inlet Action Team is a subset of the
Interagency Work Group and will include technical staff from local,
state, tribal,  and federal agencies.   Agencies represented may
include the City of Olympia Department of Public Works; the
Lacey,  Olympia, Tumwater, and Thurston County Wastewater
Treatment Program (LOTT); the Thurston County departments of
Health and Public Works; the Thurston County Office of Water
Quality; the Washington Department of Health (DOH); the Squaxin
Island Tribe; and EPA. The action team will meet two to four times
per year to advise and assist in carrying out specific actions, solve
any problems that arise,  evaluate the effectiveness of the various
implementation strategies, and maximize interagency coordination.
As new data are obtained  about Budd Inlet and as the initial results

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Introduction
                          of implementation efforts are evaluated, the action plan will be
                          revised and updated.  It is anticipated that revisions and updates to
                          the action plan will be produced annually.

                          Ecology will continue to involve representatives from environmen-
                          tal, business, recreational, civic, educational, and neighborhood
                          groups through the Citizen Advisory Committee.  This advisory
                          committee will:  1) identify public concerns and issues relevant to
                          agency actions set forth in the action plan, 2) disseminate action
                          plan information to members of organizations represented on the
                          committee, 3) review work products and attend scoping meetings,
                          and 4) help ensure that agencies perform the  remedial actions or
                          investigations for which they are responsible.

                          Other agencies in addition to Ecology that have participated in
                          development of the 1991 Action Plan have specific implementation
                          responsibilities. Local governments are key participants in carrying
                          out the actions of the action plan.   City  and  county agencies
                          responsible  for source control  and remedial activities include:
                          LOTT, City of Olympia Department of Public Works, City of
                          Tumwater, Thurston County departments of Health  and Public
                          Works, and the Thurston County Office of Water Quality. These
                          agencies are responsible for a wide variety of activities that are
                          essential for the implementation of  the action plan.  Controlling
                          municipal and industrial wastewater effluent and untreated storm
                          water  are only some of the important activities to be conducted by
                          these agencies.  Other agencies (e.g., the Port of Olympia) and
                          private industries are responsible for contaminant prevention and
                          control related to their property  and  activities.
 Coordination with
 Other Areawide
 Plans and Programs
Coordination of the Budd Inlet Action Program with other planning
and management programs is essential for efficient and effective
implementation.  The PSWQMP and the watershed management
planning process are areawide programs that must be coordinated
with the Budd Inlet Action Program.
 Puget Sound Water
 Quality Management
 Plan
The Authority developed the PSWQMP, which is implemented by
state agencies, local governments, and other parties. The urban bay
approach is also explicitly supported by the PSWQMP. Activities
described in the areawide plans and programs of the 1991 Action
Plan are consistent with the PSWQMP.  The Authority has an
oversight and coordination role in implementing the PSWQMP.
Coordination of Authority-directed activities with the urban bay
program occurs through the Budd Inlet Interagency Work Group
                                                        8

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                                                                           Introduction
                          meetings.  The Authority will actively participate as an Interagency
                          Work Group member through work group and action team meet-
                          ings.
Watershed
Management
The watershed management planning process is also coordinated
with the Budd Inlet Action Program. Under a program administered
by Ecology, counties have ranked priority watersheds for nonpoint
contaminant management. Grants are given to counties to develop
management plans for controlling nonpoint contaminant sources in
these priority watersheds. Thurston County was given a  grant to
conduct monitoring in the Budd Inlet and Deschutes River water-
shed.  The data collected during the monitoring will be used for
watershed management planning.  A watershed management com-
mittee, composed of personnel from planning and implementing
agencies and other interested and affected parties, will be formed
to develop the  management plan and implement the specific actions.
Coordination of this program with the urban bay program occurs
via the Budd Inlet Interagency Work Group. Representatives from
both Ecology and the Thurston County Health Department  (the lead
planning agency for the watershed monitoring efforts) are work
group members.  In addition, Ecology representatives are on the
watershed planning technical advisory committee.
Local Plans and
Programs
In addition to the areawide plans and programs discussed above,
there are several more localized or subject-specific plans and
programs that may have an impact on Budd Inlet. These plans and
programs will benefit by coordinating with the Budd Inlet Action
Program. Of particular importance are the Olympia Urban Water-
front Plan, Thurston Regional Shoreline Master Program, City of
Olympia's basin plans, and Capitol Lake Restoration Plan. Activ-
ities associated with these plans and programs will be coordinated
with the Budd Inlet Action Program through the Budd Inlet Action
Program Coordinator and staff members of the various agencies
involved. The Budd Inlet Action Program Coordinator will attend
some meetings and will review the minutes of the other meetings.
The coordinator will also review and comment on draft plans
developed through the above programs.  In addition, some agencies
will have representatives on the Budd Inlet Action Team.  (See the
Comprehensive Plans and Programs section for a more  detailed
discussion of these plans and programs.)

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Introduction
Technical Approach      The Urban Bay Action Program relies on a "preponderance-of-evi-
for Identifying and       dence" approach to identify and rank contaminated problem areas
Ranking Problem         and contaminant sources. Selected chemical, biological, and toxi-
Areas                    cological indices are used to compare conditions at contaminated
                          sites to conditions in relatively uncontaminated embayments. The
                          contaminated sites then receive a priority ranking.  The rankings
                          are used to determine the order in which problem areas will be
                          evaluated for contaminant sources and possible remedial actions.
                          Study areas that exhibit high levels of contamination and adverse
                          biological effects receive a ranking of high priority.  The following
                          types of environmental indicators are generally used to identify and
                          rank problem areas (see also Figure 3):

                              •  Sediment Chemistry

                                 -   Concentrations of metals and organic compounds
                                 -   Conventional sediment variables (e.g., grain size distri-
                                     bution, total organic carbon)

                              •  Bioaccumulation

                                 -   Chemical concentrations in clams and fish

                              •  Sediment Bioassays

                                 -   Amphipod mortality (10-day bioassay)
                                 -   Oyster larvae abnormality  (48-hour bioassay)

                              •  Benthic Infauna Abundance

                                 -   Polychaete abundance
                                 -   Pelecypod abundance
                                 -   Gastropod abundance
                                 -   Crustacean abundance

                              •  Fish Histopathology

                                 -   Lesion (e.g., tumor) prevalence in livers, kidneys, and
                                     gills of English sole

                              •  Microbial Contamination

                                 -   Fecal coliform bacteria

                              •  Conventional Water Quality Variables

                                 -   Dissolved oxygen

                                 -   Nutrients (i.e., nitrogen, phosphorus).
                                                       10

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                           SEDIMENTS
 Chemistry

CL       Cl
Bioaccumulation
                      Bioassays
                    Infauna
                               WATER
      Fecal Coliform Bacteria
     Conventional Variables
                                            JAN
          Dissolved Oxygen
                                                                   DEC
      Figure 3.  Environmental indicators used to define problem areas of sediment
              contamination and biological effects
                                             11

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Introduction
                           Each of the above indicators is used to assess different environmen-
                           tal impacts.  Measurements of contaminant concentrations in sedi-
                           ments are used to characterize the degree of contamination and to
                           trace contaminant sources.  Measurements of contaminant concen-
                           trations in tissues of aquatic organisms are used to identify large-
                           scale problem areas and potential human health risks.  Sediment
                           bioassays and counts of sediment-dwelling organisms are each
                           valuable for characterizing effects of contamination at specific
                           sampling locations.  Measurements of lesions in fish are useful for
                           characterizing large-scale problem areas.   Measurements of sedi-
                           ment chemistry, bioassays, and benthic community analyses are
                           often used together to characterize toxic problem areas in Puget
                           Sound  (Chapman et al.  1985;  PTI and  Tetra  Tech  1988a,b).
                           Bacterial measurements are used to assess microbial contamination
                           of water and shellfish and evaluate human health risks.  Measure-
                           ments of conventional water  quality variables are used to assess
                           eutrophication.

                           The problem area identification and prioritization for Budd Inlet
                           included comparisons of existing data with elevation above refer-
                           ence values, sediment quality  criteria [i.e., apparent effects thresh-
                           old (AET)], and  regulatory standards.  Elevation above reference
                           values are generated by dividing the measured value by reference
                           values  from non-urban embay men ts.   In  addition to  the use of
                           elevation above  reference values, Puget Sound AET values were
                           used as sediment quality values to evaluate chemical data relative
                           to predicted biological effects.  AET values are chemical-specific
                           sediment concentrations above which a particular adverse biological
                           effect is always found to be statistically significant (P<0.05) for a
                           given data set.   Because AET values are predictive,  they  are
                           especially useful in interpreting  historical data on sediment contam-
                           inant levels where biological data are not available. In the future,
                           sediment management standards (Chapter 173-204 of the Washing-
                           ton Administrative Code) will be used to determine areas of
                           sediment contamination.   Microbial and water quality parameters
                           were evaluated and compared with established state and federal
                           standards to rank problem areas for microbial  contamination.

                           Criteria that were used in determining problem areas are presented
                           in Table  1.   All of the available  indicators  of eutrophication,
                           microbial contamination, and  chemical contamination in sediments
                           and biota were integrated to identify problem areas in Budd Inlet.
                           Because there were  few data on benthic infauna abundance and fish
                           histopathology, these two types of indicators were not used to
                           identify problem areas in Budd  Inlet.  These and  other data gaps
                           hindered identification of problem areas in some portions of the inlet
                                                        12

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                                 TABLE 1.  CRITERIA FOR PRIORITIZING
                                    PROBLEM AREAS IN BUDD INLET
 Data Category
   Primary Problem Area
  Secondary Problem Area
    No Immediate Action
 Eutrophication"


 Chemical contamination15

   Sediment chemistry


   Bioassays


 Microbial contaminationd
Minimum dissolved oxygen
<3.0 mg/L
Metals:  EAR0 >50
Organics: EAR >100
Minimum dissolved oxygen
3.0-5.0 mg/L
Metals:  EAR 10-50
Organics: EAR 10-100
Minimum dissolved oxygen
>5.0 mg/L
Metals:  EAR <10
Organics:  EAR <10
Amphipod  >50% mortality   Amphipod 25-50% mortality   Amphipod <25% mortality
Oyster >50% mortality      Oyster 25-50% mortality      Oyster <25% mortality
Fecal coliform bacteria
EAR >10
Fecal coliform bacteria
EAR 1-10
Fecal coliform bacteria
EAR <1
8 5.0 mg/L is the Class B water quality standard for marine waters.
b Criteria for water column chemistry,  bioaccumulation, benthic  infaunal communities, and  fish histopathology were not
established because of the lack of data for Budd Inlet.
c EAR - elevation above reference.
d Fecal coliform bacteria EAR value of 1 corresponds to the appropriate water quality standard for Class A or Class B marine
waters.

Source:  Tetra Tech (1988)
                                                                     13

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Introduction
                           and prioritization of problem areas throughout the bay.  Limited
                           data were available for all categories of data evaluated in the Initial
                           Data Summaries and Problem Identification document (Tetra Tech
                           1988). For example, the geographic extent and temporal variability
                           of low oxygen conditions is not well understood, the temporal
                           variability of microbial contamination is unknown, and limited data
                           exist concerning the spatial extent of sediment contamination or
                           bioaccumulation.  As a result of the scarcity of data, problem areas
                           in Budd  Inlet were not ranked numerically but were classified as
                          primary problem areas, secondary problem areas, or no immediate
                           action areas. Numerical ranking or prioritization of problem areas
                           would be possible with more data. The results of the problem area
                           identification are presented in the Description of Priority Problem
                          Areas section.
                           Overview of Budd Inlet and Associated
                           Contamination  Problems

                           This section describes the project area and summarizes information
                           about the eutrophication and contamination problems in Budd Inlet.


General Description       Budd Inlet is a shallow estuary located at the extreme southern end
of Area                   of Puget Sound (Figure 1).  The project area includes all of Budd
                           Inlet up to a line connecting Dover Point and Cooper Point. The
                           inlet is 11.1 kilometers long, with an average width of 2.4 kilome-
                           ters and a maximum width of 2.6 kilometers.  The average depth
                           of the inlet is approximately 9 meters at mean lower low water, and
                           the maximum depth is approximately 34 meters near the mouth.
                           The Deschutes River serves as the major source of fresh water to
                          Budd Inlet.  The freshwater inflow from the Deschutes [ranging
                          between 60-100 feet3/second (1.7- 2.8 meters3/second) in the fall to
                          5,000 feet /second (141.4 meters3/second) in the winter]  helps to
                          develop a weakly stratified, two-layer circulation pattern.  The upper
                          water layer, consisting of lower-salinity  water from the Deschutes
                          River, flows northward to the mouth of the inlet; the lower water layer,
                          consisting of higher-salinity, colder water from southern Puget Sound!
                          flows south towards the  head of the inlet.  Water in Budd Inlet is
                          estimated to take approximately 4 days to travel from the head of the
                          inlet to the mouth and to have a maximum residence time of 14 days
                          and an average residence time of approximately 8 days. Stratification
                          of the water  column (i.e., layering that reduces vertical  mixing),
                          reduced flushing rates, and algal blooms all contribute to low oxygen
                          levels near the head of the inlet in the late summer.
                                                       14

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                                                  Introduction
Sediment input to the inlet comes largely from the Deschutes River.
The river carries approximately  18,300 tons of sediment per year
to Budd Inlet, and 80 to 85 percent of this sediment is transported
in November and December.   The  sediment  load derives from
natural erosion process and land use practices in the Deschutes
watershed (e.g.,  agriculture, logging, road construction).  Capitol
Lake acts  as a settling basin for sediments transported by the river,
but sedimentation is a problem in Budd Inlet at the Capitol Lake
outfall and in East Bay.

Fish and shellfish resources in the project area include chinook,
coho, and chum salmon; sea-run cutthroat and steelhead trout; cod;
surf perch; sole; flounder; herring; surf smelt; and geoduck. Budd
Inlet also serves as habitat for a wide variety of waterfowl, especially
during the winter.

The watershed of Budd Inlet (excluding  the Deschutes River)
encompasses approximately 153 km2.  The drainage basin of the
project area is rural except in and near the city of Olympia, which
contains the bulk of residential, commercial, and industrial activity.
Industrial  facilities located in Lacey and Tumwater use the LOTT
wastewater treatment plant (WWTP)  for processing waste dis-
charges.   The Deschutes River drainage basin  includes approxi-
mately 430 km of forested, agricultural, and rural lands.

As  a result of urban and industrial influences, localized areas of
Budd Inlet are contaminated with bacteria and toxic chemicals.  The
inlet is also subject to eutrophication.  Studies have shown that the
Budd Inlet ecosystem is being stressed and that beneficial uses in
the inlet are restricted  because of low oxygen levels and bacterial
and chemical contamination.

Low oxygen levels, often below 3.0 mg/L, occur throughout the
southern portion of the inlet in the late summer.  Oxygen levels
below  5.0 mg/L can be fatal to  fish  and invertebrates.  The full
temporal and spatial extent of eutrophication and oxygen depletion
in Budd Inlet is unknown and constitutes a significant data gap (Tetra
Tech 1988).

Bacterial  contamination has resulted in the closure of the inlet to
commercial and recreational shellfish harvesting.  Concentrations
of fecal coliform bacteria, used as an  indicator of other disease-
causing organisms, were found to exceed Washington State Class B
water quality standards  in four areas in the inlet. At least nine other
areas  had highly elevated concentrations of  these bacteria.  In
                             15

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Introduction
                          addition, data collected on bacterial contamination in intertidal
                          sediments in East Bay showed elevated levels of fecal coliform
                          bacteria.

                          Chemical contamination of sediment and biota is also known to
                          occur in Budd Inlet.  Levels of polycyclic aromatic hydrocarbons
                          (PAHs) found in sediment near the McFarland/Cascade Pole site
                          (1,745,000 ppb) are among the highest concentrations of PAHs
                          found in Puget Sound.  Levels of PAHs in clams (938 ppb) near the
                          McFarland/Cascade Pole site are comparable to the high levels of
                          PAHs found in clams near Eagle Harbor (a federal Superfund site).
                          Elevated levels of copper, lead, zinc, and cadmium were found in
                          sediment near Fiddlehead Marina in West Bay.  Intertidal sediment
                          sampling for toxic chemicals in East Bay indicated elevated levels
                          of nickel and PAHs. Some indicators of sediment toxicity and biota
                          contamination have recently been investigated but do not indicate
                          significant toxicity or potential human health problems (PTI1991).
Description of
Priority Problem
Areas
This section provides a description of the known problem areas
associated with eutrophication and bacterial and chemical contam-
ination and identifies potential sources of the contaminants. Based
on the limited data available,  PAHs, cadmium, copper, lead, zinc,
and fecal coliform bacteria have been identified as problem contam-
inants for Budd Inlet.  Contaminants are considered a problem if
concentration levels are elevated more than 10 times above contam-
inant levels at reference areas  located throughout Puget Sound.
Reference areas are identified in the Initial Data Summaries and
Problem Identification report (Tetra Tech 1988). Eutrophication is
considered significant if dissolved oxygen levels fell below the state
standard of 5.0 mg/L.

Based  on the Initial Data Summaries and Problem Identification
report  (Tetra Tech 1988) and on information provided by work
group members and citizens during the plan development process,
the problem areas for each category of contaminant (i.e., eutrophi-
cation  and bacterial and chemical contamination) were prioritized
as primary or secondary using the technique explained in the
Technical Approach for Identifying and Ranking Problem Areas
section. The 9 primary and 10 secondary problem areas identified
under this process are shown  in Figure 4. Primary problem areas
are those where further source control and remedial action evalua-
tions are strongly recommended.  More studies are recommended
in secondary problem areas to better define the extent and severity
of existing problems.
                                                       16

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                                                     PUGETSOUND
                                                 oper              Dover
                                               Point PROJECT BOUNDARY
                                                        Boston •'
                                                        Harbor Q7
                                                  Budd Inlet
                                                                             Priest
                                                                             Point
                                                                             Park
     SECONDARY
   PROBLEM AREAS
   PRIMARY
PROBLEM AREAS
EUTROPHICATION   O
     1 Ecology Station BUD002  10 Fiddlehead Marina
     2 Capitol Lake outfall to    11  North of LOTT
                             30-inch outfall
                          12 Northeast of McFarlanoV
                             Cascade Pole, middle
                             of channel
CHEMICAL
CONTAMINATION
     4  McFarland/Cascade Pole 13 West Bay, near the
     5  West Bay drain            West Bay drain
                          14 Fiddlehead Marina
BACTERIAL
CONTAMINATION
    6 Moxlie Creek
    7 Boston Harbor
    8 Ellis Creek
    9 South of Tykle Cove
15 Tamoshan
16 Beverly Beach
17 Athens Beach
18 Butler Cove
19 North of Priest Point
                                                                                                   2 miles
           Figure 4.  Primary and secondary problem areas in Budd Inlet.
                                                                  17

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Introduction
                          Six major categories of point and nonpoint sources of contaminants
                          to Budd Inlet were identified in Initial Data Summaries and Problem
                          Identification (Tetra Tech 1988).  These categories are WWTPs,
                          CSOs, surface runoff, industrial sources, groundwater, and acci-
                          dental  spills.  The LOTT, Tamoshan, Beverly Beach, Seashore
                          Villa, and Boston Harbor WWTPs discharge to Budd Inlet and have
                          been  issued  National Pollutant Discharge Elimination  System
                          (NPDES) permits.  The City of Olympia currently has one CSO
                          that discharges to West Bay and one CSO that discharges to East
                          Bay via Moxlie Creek.  These CSOs are reported  to flow infre-
                          quently.  Over 50 City of Olympia storm drain outfalls discharge
                          to Budd Inlet. Except for the West Bay drain on  Port of Olympia
                          property, CSOs and storm drains have not been investigated for
                          annual flow estimates or chemical composition. In addition to the
                          five WWTPs,  one  NPDES  permit has been issued to the
                          Pabst/Olympia Brewery.  Until recently, NPDES permits were also
                          in place for Chevron U.S.A. and Delson Lumber Company/Olym-
                          pia Forest Products. Chevron has discontinued operations and the
                          Delson building burned down.  Major commercial point and non-
                          point sources include the McFarland/Cascade Pole site and the four
                          marinas located in East and West bays. Other individual potential
                          sources have been identified since 1988 by the Interagency Work
                          Group and the Citizens Advisory Committee.  All known and
                          potential point and nonpoint sources identified to date are shown in
                          Figure 5 (see Table 1 for additional discussion of these sources).
Eutrophication             Three primary and three secondary problem areas were identified
                          for eutrophication problems.   The  primary  problem  areas are
                          Ecology Station BUD002 in West Bay,  the City of Olympia
                          monitoring station at the Capitol Lake outfall, and the Port of
                          Olympia monitoring stations in the East Bay Marina (numbers 1,
                          2, and 3, respectively, on Figure 4).  Dissolved oxygen levels in
                          late summer are typically less than 3.0 mg/L  in the bottom water
                          of the primary problem areas.

                          Secondary problem areas for eutrophication are the City of Olympia
                          monitoring station at Fiddlehead Marina, the area north of the LOTT
                          30-inch outfall, and the navigation channel located northeast of
                          McFarland/Cascade Pole (numbers  10, 11, and 12, respectively,
                          on Figure 4). No problem areas were identified north of East and
                          West bays, but there is only one sampling station for dissolved
                          oxygen in this area (Ecology Station BUD005, just south of Olympia
                          Shoals).  Secondary problem areas have dissolved oxygen levels
                          between 3.0 and 5.0 mg/L in the bottom water.
                                                       18

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                                                         PUGETSOUND
                                            Cooper
                                             Point
  NPDES PERMTTED
  1  Tamoshan WWTP
  Z  Beverly Beach WWTP
  3  Seashore Villa WWTP
  4  Boston Harbor WWTP
  5  LQTT Primary Outfall
  6  .LOTT Secondary Outfall
  7  Water Street CSO
  8  State and Chestnut Streets GSO
  OTHER POINT SOURCES
  9  Port of Olympia stormwater
 10  Pabst/Olympia Brewery
 11  Delson Lumber/Olympla Forest Products
 12  Chevron
 13  Dunlap Towing/West Bay Chip Reload
 14  West Bay Pump Station
 15  Hardel Mutual Plywood Corporation
 16  Reliable Steel Fabricators, Inc.
 17  Industrial Petroleum Distributors
 18  Historical landfill
 19  Past Texaco storage facility
 20  McFartand/Cascade Pole site
 21  Petroleum-contaminated soils
 22  San Francisco Avenue stormwater outfall
 23  East Bay Drive pump station
 24  Jasper/Eastside pump station
  NONPOINT SOURCES
 25  Percival Cove salmon rearing pen
 26  Mothballed fleet
 27  Athens Beach area
 28  Olympia Country and Golf Club area
 29  French Loop Road area
 30  West Bay Marina
 31  Fiddlehead Marina
 32  One Tree Island Marina
 33  Martin Marina
 34  Olympia Yacht Club
 35  East Bay Marina
 36  Boston Harbor Marina
 37  West Bay drain
 38  Ellis Creek
 39  Moxlie Creek
 —- 4" to 19* Storm Drain Outfalls
-— 24' to 29" Storm Drain Outfalls
•—- >30" Storm Drain Outfalls
  Jf.  Chlorinators
                                                                                             OLYMPIA
                              2 miles
Figure 5.  Locations of known  and  potential point and nonpoint sources
              of contaminants in Budd Inlet.
                                                                    19

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Introduction
                          Potential sources of contaminants that contribute to eutrophication
                          include WWTPs, CSOs, marinas, and surface runoff.  Actions that
                          have been taken to control these sources include upgrading of the
                          LOTT WWTP and construction of the Boston Harbor WWTP.
                          Other actions being taken include the development of watershed
                          basin management plans, new storm water regulations, and a
                          highway runoff ordinance. These general actions and other specific
                          actions are discussed in the Comprehensive Plans and Programs
                          section.
Bacterial
Contamination
Four primary and five secondary problem areas were identified for
bacterial contamination. Elevation above reference values for areas
within Class A waters were calculated using the Class A water
quality criteria of 14 organisms/100 mL as reference.  Similarly,
the elevation above reference values for areas within Class B waters
were calculated using the Class B water  quality criteria  of 100
organisms/100 mL.   The four primary areas are Moxlie  Creek,
Boston Harbor, Ellis Creek, and the area south of Tykle Cove where
monitoring was done. Fecal coliform bacteria values in these areas
were more than  10 times higher than Class A or B water quality
standards.

Secondary problem areas for bacterial contamination include the
Tamoshan, Beverly Beach, and Athens Beach WWTPs; Butler
Cove;  and north of Priest Point.  The Thurston County  Health
Department has been conducting routine monitoring at Priest Point
and has found consistently high levels of bacterial contamination.
These  secondary priority areas had fecal coliform bacteria values
between 1 and 10 times the Class A or B water quality standards.

Potential sources of bacterial  contamination  include  WWTPs,
CSOs,  and nonpoint sources such as septic tanks.  Actions that have
been taken to control these sources include the upgrading of the
LOTT WWTP and the construction of the Boston Harbor WWTP.
Other actions being taken include the development of watershed
basin management plans and new storm water regulations.   These
general actions  and  other  specific actions  are discussed in the
Comprehensive Plans and Programs section.
Chemical
Contamination
Two primary problem areas for chemical contamination are the
McFarland/Cascade Pole site and the West Bay storm drain (num-
bers 4 and 5, respectively, on Figure 4). Concentrations of organic
chemical compounds at these stations exceeded chemical concen-
trations at reference areas by a factor of 100 or  more.  Primary
                                                       20

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                                                 Introduction
problem areas are those where metals concentrations are more than
50 times higher than reference areas and organic chemical concen-
trations are more than 100 times higher than the reference areas.

Secondary problem areas for chemical contamination are located in
the Fiddlehead Marina and in West Bay offshore from the West Bay
storm  drain (numbers 13 and  14,  respectively, on Figure  4).
Fiddlehead Marina had metals concentrations elevated between 10
and SO times above reference values, and the offshore area in West
Bay had organic compounds at levels that are 10 to 100 times above
reference values. Secondary problem areas are those where metals
concentrations are between 10 and 50 times higher than in reference
areas and organic chemical concentrations are between 10 and  100
times higher than in reference areas.

In addition to data collected for the Initial Data Summaries and
Problem Identification report (Tetra Tech 1988), EPA has com-
pleted a recent study of Budd Inlet, Reconnaissance Survey of
Chemical Contamination and Biological Effects in Southern Puget
Sound  (FIT 1991).  The executive summary of this report and maps
showing sampling stations are presented in Appendix C. While data
from the report have not been statistically integrated with the data
from the initial data summaries, the new data indicate that there are
several additional areas with chemical contamination of sediments
and associated potential adverse biological effects. However, none
of the chemicals found in either clams or fish pose a potential human
health problem, based on a qualitative health risk evaluation.

Sources of chemical contamination in Budd Inlet include the McFar-
land/Cascade  Pole site, marinas,  the West Bay storm drain, and
storm  water from  urban streets and  industrial facilities.   Other
sources include permitted discharges, contaminated groundwater
seeps,  accidental spills, and contaminated discharges from past
activities.  Actions that are being taken to help control these sources
include cleanup actions being conducted by the Port of Olympia at
the McFarland/Cascade Pole property, issuing storm water dis-
charge permits to industrial operations,  education programs aimed
at industries and the general public, and the development of storm
water regulations.   These actions and  other specific actions  are
discussed in the Comprehensive Plans and Programs section.
                             21

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22

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1991  Action Plan for  Budd  Inlet
                         Many planned or ongoing actions to control eutrophication and
                         contaminant inputs to the project area are part of comprehensive
                         programs or planning activities of federal, state, and local govern-
                         ment agencies.  The first part of  this section provides a brief
                         summary of the programs affecting Budd Inlet and the agencies
                         involved.   The second part of this section, which consists of
                         Tables 2-8, presents a detailed action plan for controlling eutrophi-
                         cation and contaminant discharges to problem areas and imple-
                         menting other relevant actions.
                         Comprehensive Plans and Programs

                         Comprehensive plans and programs apply to a large portion of the
                         study area (e.g., basin plans or the geographic area within a local
                         government body's jurisdiction) or a category or grouping of
                         sources or activities (e.g., storm water management programs or
                         development of BMPs for an industrial category).  The following
                         programs and plans are described in terms of actions that can be
                         taken to identify or control ongoing sources of eutrophication and
                         contamination in the project area. Programs and plans are discussed
                         according to major implementing agency, local government body,
                         or tribe.
U.S. Environmental
Protection Agency
EPA, in conjunction with Ecology and the Authority, co-manages
the Puget Sound Estuary Program. EPA oversees state-delegated
programs and ensures that federal minimum standards are attained.
EPA also provides technical support to state and local agencies in
the planning and development of environmental protection pro-
grams.  EPA has initiated several technical studies in support of
Urban Bay Action Programs in Puget Sound.  These studies are
listed in Appendix D.
Storm Water
Regulations
In November 1990, EPA issued the final rule for permit application
requirements for storm water discharges under the NPDES program
of the CWA.  Under this rule, EPA will regulate both individual
industrial facilities that discharge storm water to storm sewer
systems and municipalities (with populations greater than 100,000)
                                                     23

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1991 Action Plan for Budd Inlet
                          that have separate municipal storm sewer systems.  Storm water
                          discharges from municipalities such as Olympia and Thurston
                          County, as well as other cities whose populations are under 100,000,
                          will be covered by rules that are expected to be issued by October
                          1992.

                          Under the storm water rule, facilities discharging storm water from
                          industrial areas into storm sewer systems or waters of the state will
                          be required to obtain NPDES permits from EPA or an NPDES-
                          authorized state agency (i.e., Ecology). Permits will be phased in
                          under a four-tiered system. General permits will be developed that
                          cover many facilities at once in the initial stage.  General permits
                          will be followed by watershed-, industry-, and/or facility-specific
                          permits.  Industrial facilities  must submit a permit application for
                          discharges covered by the rule to the regulating agency within 1
                          year after promulgation of the rule (December 1991). There are
                          three ways of becoming covered  under a permit.  A facility may
                          apply for an individual permit, apply as part of a group  (or
                          industry-wide permit), or submit a Notice of Intent to be covered
                          by an agency-issued permit.  The first two methods are used if
                          general or industry-specific permits have not yet been initiated by
                          the agencies or if the discharge(s)  in question would not be
                          adequately addressed by the more general permit.

                          These regulations are in addition to rules Ecology is preparing for
                          minimum requirements for storm water management programs for
                          Puget Sound (see Comprehensive Plans and Programs, Washington
                          Department of Ecology).  The cities of Olympia,  Tumwater, and
                          Lacey and the surrounding unincorporated areas will be affected by
                          these Ecology storm water regulations and requirements.
Permit Review
EPA reviews and comments on all significant permits for dredging
and fill operations in navigable waters under Section 404 of the
CWA and Section 10 of the Rivers and Harbors Act. While the
programs are implemented by the U.S. Army Corps of Engineers
(Corps), modifications suggested by EPA concerning environmen-
tal protection and wetlands impacts may be included as stipulations
of the final permits.
U.S. Army Corps of
Engineers
The Corps issues and enforces Sections 10 and 404 permits.  The
Corps is the lead agency for the potential navigation improvement
project in West Bay.
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                                                           1991 Action Plan for Budd Inlet
Navigation
Improvement Project
The Corps is evaluating potential improvements to the existing
navigation channel in West Bay.   Because of the findings of an
economic feasibility study, expansion of the turning basin next to
the navigation channel is no longer being considered.  Plans to
widen the channel are still being considered, but will be postponed
until the improvements are economically necessary. The Port of
Olympia and the Corps will meet during the summer of 1991 to
evaluate the project and make a decision. The final feasibility report
for possible improvements was completed in April 1991, but if
dredging  occurs, it will not begin before 1993.
East Bay Marina
Pursuant to the conditions of a Section 404 permit, aerators in East
Bay are to be turned on when the dissolved oxygen concentration
in the water at the marina falls below 5 parts per million (ppm).
The Corps has data on dissolved oxygen conditions in East Bay from
1984 to the present. Dissolved oxygen is measured on a daily or
weekly basis in August and September, depending on conditions.
U.S. Fish and
Wildlife Service
The U.S. Fish and Wildlife Service (FWS) is responsible for the
protection of fish and wildlife resources.  FWS reviews and pro-
vides recommendations on projects that require federal permits or
involve federal funding and that may affect fish and wildlife
resources.
East Bay Marina
FWS has recommended to the Corps that funding be provided to
mitigate impacts on fish and wildlife caused by the East Bay Marina
construction.  FWS would support measures such as the replace-
ment of monitoring and aerating equipment (if the existing equip-
ment is inadequate) through available funding from the Water
Resources Development Act.  FWS believes it is inappropriate to
use former intertidal areas of East Bay that were filled during the
construction of the project for non-water-dependent purposes and
is opposed to any additional filling of wetlands and intertidal and
shallow subtidal habitats. FWS has requested clarification from the
Corps on what type of developments are appropriate on the fill areas
originally created for water-dependent uses (i.e., cargo handling
and storage).
Navigation
Improvement Project
FWS has been reviewing the Port of Olympia's navigation improve-
ment project for possible impacts to fish and wildlife resources,
specifically the anadromous fish runs in the Deschutes River.
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1991 Action Plan for Budd Inlet
                          Because the project has a federal lead (i.e., the Corps), FWS can
                          request studies to determine potential impacts.  The Corps has the
                          final approval on whether or not the studies will be conducted.

                          FWS will continue to have input to the project through planning aid
                          letters submitted to the Corps. During fiscal year 1992, FWS will
                          negotiate with the Corps to determine how many planning aid letters
                          and  what  additional  studies  the FWS will require.   FWS may
                          determine that the risks to resources are great enough to recommend
                          that the project not be approved by the Corps.
Log Raft Storage
FWS is concerned about storing log rafts over intertidal habitats
along West Bay.  During low tidal periods, the log rafts lay on the
intertidal zone and probably crush or smother benthic and epibenthic
invertebrates.  The decomposition of bark and leaching from the
stored logs may also adversely impact water quality (e.g., result in
low dissolved oxygen levels and increased chemical toxicity) and
eliminate important rearing and acclimation areas for juvenile
salmonids.  FWS plans to initiate discussions with  the Port of
Olympia concerning log storage practices.
Squaxin Island Tribe
The Squaxin Island Tribe has usual and accustomed fishing areas
supported by treaty rights in Budd Inlet and manages several fish
resource enhancement projects.  The tribe reviews plans and per-
mits for development projects that could affect the tribe's usual and
accustomed fishing areas.
Resource Management
The tribe operates salmon incubation facilities on Adams Creek and
Gull Harbor and co-manages [with the Washington Department of
Fisheries (WDF)] salmon fisheries located in the Deschutes River
and Capitol Lake.  The tribe is very concerned about eutrophication
and supports the need for a study to assess the effects of a nutrient
abatement program at LOTT.  Additionally, the tribe is concerned
about how the problems in Black Lake, such as high nutrient levels,
low dissolved oxygen, algae blooms, and flooding, will affect fish
production in the Capitol Lake and Budd Inlet systems. The tribe
is also concerned about sediment loading into the Deschutes River
and Capitol Lake.
Planning
The Squaxin Island Tribe is involved in many local, state, and
federal planning processes related to shoreline development and
environmental degradation (e.g., LOTT outfall placement, McFar-
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                                                           1991 Action Plan for Budd Inlet
                          land/Cascade Pole negotiations, and Port of Olympia dredging
                          projects). The tribe provides technical and policy support to various
                          agencies on fisheries, water quality, sediment loading, and water
                          resource-related issues.
Monitoring
The tribe monitors stream and habitat quality in the Deschutes River
watershed as part of the state Timber/Fish/Wildlife agreement.
This monitoring information is contained in the tribe's geographic
information  system.   The  tribe,  in conjunction  with Thurston
County, is also conducting sampling in the Deschutes watershed
under the watershed management process.  Sample parameters are
limited to conventional analyses (e.g., nutrients, fecal coliform
bacteria, and pH).

The tribe  has also worked with the City of Olympia in the city's
basin planning process by surveying fish habitat in Indian, Moxlie,
Percival, Ellis, and Mission creeks and an  unnamed stream.
Washington
Department of
Ecology
In addition to the Budd Inlet Action Program, Ecology has numerous
ongoing programs and planning activities related to eutrophication,
bacterial and chemical contamination, and nonpoint contamination
in the project area.
National Pollutant
Discharge Elimination
System
EPA has delegated authority to Ecology to issue and enforce NPDES
permits for nonfederal facilities.  Ecology generally issues NPDES
permits on a site-by-site basis, and a permit for one site may include
more than one discharge or source of contaminants.  Permits for
municipal WWTPs authorize discharges throughout the plant's
service area,  including CSOs.  Industrial permits may include a
storm drain component for surface runoff as well as the wastewater
discharge component. NPDES permits may require effluent limi-
tations (concentration or total loading) for toxic contaminants and
may include provisions for instituting BMPs to reduce nonpoint
contaminant inputs.  EPA's new  NPDES  regulations  for storm
water require property owners and tenants in certain  industrial
categories to submit data to Ecology regarding surface water runoff
(see U.S. Environmental Protection Agency section).

The Efficiency Commission, formed by the governor's office to
review programs of state agencies, evaluated Ecology's wastewater
discharge permit program. The commission released a final report
in late 1990  that recommended an increase in permit fees and
improvements to the program's efficiency.
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1991 Action Plan for Budd Inlet
                          Ecology currently maintains six NPDES discharge permits in the
                          Budd  Inlet project area.   These  permits  are  for  the LOTT,
                          Tamoshan, Seashore, Boston Harbor, and Beverly Beach WWTPs
                          and the Pabst/Olympia Brewery. Former NPDES-permitted facil-
                          ities in the Budd Inlet watershed that may be potential contaminant
                          sources include Delson Lumber and a Chevron bulk petroleum
                          storage facility. The Port of Olympia is part of a group application
                          to EPA for a storm water NPDES permit for its six outfalls on the
                          peninsula between East Bay and West Bay. Ecology has inspected
                          some  facilities that lack permits and  will continue to conduct
                          inspections and sampling, issue permits, enforce NPDES regula-
                          tions,  and  require the implementation of BMPs in the Budd Inlet
                          project area.
Watershed Planning
for N on point Source
Pollution
Under the state nonpoint source pollution planning rule (WAC
400-12), Ecology is administering a grant program that enables local
agencies to develop plans for controlling nonpoint source contam-
ination on a watershed basis.  The first part of a three-phase
watershed management program for Budd Inlet and Deschutes River
was funded by Ecology's Water Quality Financial Assistance Pro-
gram in 1990. The Thurston County Health Department is the lead
agency for Phase One of the watershed management program. This
phase involves water quality monitoring and watershed character-
ization.  A watershed management committee made up of local
entities will be the lead group for Phase Two.  During this phase,
a nonpoint source pollution action plan will be developed.  The
Ecology Coordinator for the Budd Inlet Action Program will attend
watershed management committee meetings to coordinate the Budd
Inlet Action Program with the watershed management program. In
addition, the Ecology program manager for the watershed grants
will receive all written materials distributed to the Interagency Work
Group and the Citizen Advisory Committee of the Budd Inlet Action
Program, including  meeting minutes and draft documents.  The
watershed management program is discussed in detail in the Thur-
ston County Health Department section.
Monitoring
As part of its ambient monitoring program, Ecology is currently
monitoring two water quality stations in Budd Inlet. These stations
are BUD005, located east of the Olympia shoal just north of Butler
Cove, and BUD002, located in West Bay near the south end of the
port dock.  Data are provided to the Puget Sound Ambient Moni-
toring Program (PSAMP).  Puget Sound Ambient Monitoring Pro-
gram  1989:  Marine  Sediment  Monitoring  (Tetra Tech 1990)
includes data from two sediment ambient monitoring stations in
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                                                          1991 Action Plan for Budd Inlet
                          Budd Inlet (one station mid-channel near Priest Point Park and one
                          station 1 nautical mile south of Cooper Point). Through these two
                          ambient monitoring programs, data from marine water column
                          sampling have been collected on toxic contaminants in marine
                          sediments and conventional constituents.  Ecology also  conducts
                          short-term monitoring during critical times (e.g., summer), when
                          necessary. The Ambient Monitoring Section monitors conventional
                          constituents (e.g., nutrients and oxygen) at two stations in the
                          Deschutes River.   These stations are located on Highway  507
                          between the towns of Tenino and Rainier and at the "E" Street
                          Bridge in Tumwater.  Metals are also monitored at the "E" Street
                          Bridge station.


Storm Water              As part of the PSWQMP, Ecology's  Water Quality Program
Management              Stormwater Unit is developing a basic  storm water program that
                          focuses on prevention and a long-term comprehensive urban storm
                          water program that focuses on controlling storm water quality and
                          quantity.  The basic storm water program will apply to all counties
                          and cities in the Puget Sound watershed.  The long-term com-
                          prehensive urban storm water program will apply first to the six
                          largest cities and four other urbanized areas in the Puget Sound
                          region by November 1991 and then to all cities and urbanized areas
                          by the year 2000. Based on the 1990 census, Olympia is not likely
                          to be one of the six largest cities. In support of both the basic storm
                          water program and the long-term urban storm water program,
                          Ecology will issue rules, guidelines, and model ordinances for storm
                          water management programs by November 1991. Ecology will also
                          produce a technical manual for use in storm water management
                          planning. The manual will include BMPs for the control of erosion
                          and sedimentation from construction sites, design operation and
                          maintenance standards for public and private retention/detention
                          facilities, and techniques for the reduction or elimination of con-
                          taminants in runoff from problem land  uses. An interim review
                          draft of the manual will be available in 1991 for public review. The
                          final manual will be released concurrently with Ecology's storm
                          water rule.  In addition to requirements for municipal storm water
                          programs, Ecology is working with the Washington Department of
                          Transportation (DOT) and other interested parties to draft an
                          administrative rule that will require DOT to control the quality and
                          quantity of highway runoff in the Puget Sound basin. The rule is
                          currently undergoing public review and will be finalized by July
                          1991.
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1991 Action Plan for Budd Inlet
Pretreatment
Ecology's Water Quality Division is delegating the management of
sewage pretreatment programs to local jurisdictions.  The LOTT
jurisdictions have submitted a proposal for a pretreatment program
to Ecology.  It is anticipated that the program will be approved and
be implemented by the end of 1991.
Combined Sewer
Overflows
In 1988, Ecology required the City of Olympia to develop a CSO
reduction plan.  Olympia is currently complying with the plan, and
an additional plan showing how the city will maintain compliance
has been submitted to Ecology for review and comments.
Shellfish Protection
Ecology's Shorelands Program Shellfish Unit is co-chairing, with
DOH, an interagency committee that is producing a recreational
shellfish plan for Puget Sound.  A draft of the plan is under review
and should be finalized by the fall of 1991. The plan addresses the
protection of shellfish resources and human health issues. The plan
focuses on 146 recreational beaches throughout Puget Sound and
includes provisions for site-specific monitoring, public notification,
public involvement and education, community outreach, and beach
restoration actions. Monitoring actions will be conducted by DOH
and will include sampling shellfish for paralytic shellfish poisoning
and fecal coliform bacteria, conducting water quality sampling for
fecal coliform bacteria, and conducting upland surveys to identify
probable contaminant sources.  If any potential chemical sources
are identified during the upland surveys, shellfish will also be tested
for the chemicals of concern at the particular site.  Responsibilities
of Ecology's Shellfish Unit include 1) implementing public involve-
ment and education actions, 2) administering grants for beach
restoration and cleanup activities, and 3) coordinating with urban
bay action teams on recreational shellfish issues.

As a result of the development and findings of the recreational
shellfish plan, it is likely that the southwest end of Budd Inlet and
Burfoot County Park will be closed to recreational shellfish harvest-
ing.
Hazardous Waste Sites
Ecology inspects state hazardous waste sites and negotiates cleanup
plans under MTCA.  Ecology, McFarland/Cascade Pole, and the
Port of Olympia signed a negotiated consent decree for the cleanup
of the contaminated McFarland/Cascade Pole site on Port of C   n-
pia property. Under the consent decree, a final cleanup plan s     j
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                                                           1991 Action Plan for Budd Inlet
                          be completed by mid-1992.  Ecology has provided an $856,000
                          grant to the port to pay for about 50 percent of its project costs over
                          the next 2 years.

                          McFarland/Cascade Pole and the port have initiated a series of
                          activities that will be used to identify and begin eliminating contam-
                          inants in the groundwater, soils, and tideflats on and near the 13-acre
                          McFarland/Cascade Pole site.  The  first phase was completed
                          during the summer of 1990 and entailed disposal of more than 100
                          barrels of wood-preserving sludges and 45 cubic yards of heavily
                          contaminated dirt and sludges recovered from beneath the plant. In
                          addition, approximately 1 million pounds of equipment were decon-
                          taminated and dismantled.

                          Pumping  and treatment  of contaminated groundwater  located
                          beneath the site is scheduled to begin in December 1991. All water
                          discharged from this operation to Budd Inlet must meet state water
                          quality standards or other criteria established by Ecology, which-
                          ever are more stringent.

                          The Unocal/Hulco site near Percival Landing in Olympia has also
                          been identified as a contaminated site through the MTCA process.
                          The site received a score of 4 according to the Washington Ranking
                          Method (WARM) and was placed on the Hazardous Sites List in
                          March 1991. Sites with WARM scores of 1 and 2 usually receive
                          first priority for cleanup through Ecology's Toxics Cleanup section.
                          A site may be reevaluated and receive a new rank if new information
                          is received or additional risks are identified. Private parties may
                          also initiate site cleanup.
Shoreline Development
Ecology's Shorelands Division is responsible for reviewing shore-
line master plans for consistency with the state Shoreline Manage-
ment Act. In addition, Ecology reviews shoreline master permits
and SEPA documents. Ecology will be adding requirements to all
new shoreline master permits for marine sewage pumpout facilities
throughout Puget Sound.
Sediment Standards
Development
Ecology has been a lead agency or key participant in several efforts
to develop tools for evaluating and managing contaminated sedi-
ments in Puget Sound.  These efforts have included the Commence-
ment Bay Superfund project, the Puget Sound Dredged Disposal
Analysis  (PSDDA), the Urban Bay Action Program, and the
PSWQMP.  Ecology has developed sediment quality standards, a
process for managing sources of sediment contamination,  a sedi-
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1991 Action Plan for Budd Inlet
                          ment cleanup decision process, and criteria for confined disposal of
                          dredged material.  In addition, guidelines for unconfined disposal
                          of dredged material have been developed under PSDDA.  These
                          sediment standards and guidelines affect sediment remedial actions,
                          wastewater discharges, and dredging operations in Budd Inlet.
Education
Ecology is involved in educational activities for Budd Inlet regard-
ing MTCA and waste reduction and recycling.  Activities focus on
the general public, industry, and small businesses and include the
issuance of MTCA public awareness grants, other public education
grants, and the distribution of brochures and educational posters
published by each program within Ecology.
Enforcement and
Complaint Response
Staff  members  from Ecology's  Southwest Regional Office in
Tumwater respond to  water quality complaints and work with
violators of the state water pollution laws to address water quality
problems.   Ecology actions  include site visits,  correspondence,
education, notices of violation, administrative orders, penalties, and
other enforcement actions.
Washington
Department of
Fisheries
WDF is primarily responsible for maintaining and enhancing fish
resources for commercial and recreational use and enhancing public
access to fishing areas. The department reviews and comments on
SEPA and NEPA documents and NPDES permits as they pertain
to fish habitat.  WDF also issues hydraulic permit approvals.
Resource Management
WDF is involved in fish rearing projects to support recreational
fisheries.  The department is involved in the management and
enhancement of chinook, coho, and chum salmon runs in Adams,
Ellis, Gull Harbor, Mission, Indian, and Moxlie creeks. WDF and
the Squaxin Island Tribe co-manage the chinook salmon fishery in
the Deschutes River and Capitol Lake.
Permits
WDF issues hydraulic project approvals for any construction activ-
ities in fresh and marine waters under the Hydraulic Code Rules
(Chapter 220-110 WAC).  WDF is particularly concerned about
development activities near herring and surf smelt spawning areas
and nearshore juvenile salmonid habitat and will review all propos-
als on a case-by-case basis to adequately protect these sensitive
resources. WDF is also in the process of revising hydraulic  permit
approval guidelines for storm water.
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                                                            1991 Action Plan for Budd Inlet
                           WDF is a participant in PSAMP. There is one fisheries monitoring
                           station in Budd Inlet located about 1.25 miles north of Gull Harbor.
                           English sole are sampled for metals, pesticides, polychlorinated
                           biphenyls, and other EPA priority pollutants. Fish histopathology
                           is also examined.
Washington
Department of
General
Administration
The Department of General Administration is responsible for the
operation  and maintenance of the dam at Capitol  Lake.  The
department is also responsible for management of the lake's water
level for water quality and flood control purposes.  The department
coordinates with WDF in regulating the water level of the lake.
Water Quality
During the summer, the bottom water in the northern basin of
Capitol Lake sometimes reaches very low oxygen levels  (below
3 ppm). The department installed a siphon to move water to Budd
Inlet from a deep area behind the Capitol Lake dam where low
dissolved oxygen conditions were most likely to occur.  The siphon
system appears to effectively prevent anoxic conditions in this
problem area.  The  department monitors  oxygen and hydrogen
sulfide levels in the lake from June to September to ensure adequate
water quality.
Wetlands and Erosion
Studies
The department recently conducted a wetlands feasibility study for
the middle and south basins of Capitol Lake.  The study evaluated
the feasibility of developing wetlands in the basins in order to
minimize the need to dredge sediments transported by the Deschutes
River. The study was presented to the state legislature during the
1991  session.  The legislature decided not to pursue the wetlands
option and subsequently appropriated funds to dredge the lake. The
department will begin planning the dredging project this year and
dredging is expected to occur in the winter of 1993-1994.

Also included in the appropriation from the legislature is $200,000
to fund stream bank stabilization projects in the Deschutes basin to
reduce the need for future dredging. The department also conducted
an erosion study for the north basin of Capitol Lake and determined
that bank stabilization is needed in some areas.  Bank stabilization
projects are expected to be completed by the end of 1991.
Petroleum Storage
Tanks
The department manages a bulk diesel storage tank and a 1,000-gal-
lon underground storage tank  on the state capitol campus.  The
department will be upgrading the bulk diesel storage tank at the
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1991 Action Plan for Budd Inlet
                          powerhouse facility by installing an oil separator system in the
                          enclosure perimeter, thus prohibiting oil from entering Capitol
                          Lake. A Spill Prevention, Control, and Countermeasure Plan will
                          be developed in conjunction with the oil separator project.  These
                          projects are expected to be completed by 1992. The contents of the
                          1,000-gallon underground storage tank adjacent to the powerhouse
                          facility have been removed, and the department plans to remove the
                          tank in March 1993.
Washington
Department of
Transportation

Storage Site
DOT is responsible for highway runoff management.
DOT, until recently, maintained a highway construction storage
area at the south end of Capitol Lake's middle basin.  The area is
located in a wetland and may have contaminated soils.  DOT is
interested in conducting a joint effort with Ecology to minimize
contamination at the storage site.  However, DOT cannot commit
resources for mitigation efforts until liability for the contamination
has been determined. If it is determined that DOT's contractors are
liable, DOT will seek restitution for damages and/or costs incurred
in cleaning up the site.
Highway Runoff
Program
The 1991 PSWQMP directs DOT to develop a program to control
runoff from highways in the Puget  Sound basin.   Ecology has
drafted guidelines for the program that will be adopted as an
administrative rule by July 1991.  Under this program, DOT will
draft and adopt a storm water management manual, develop a
vegetation management program, and institute other measures to
control the quality and quantity of runoff from highways in the Puget
Sound basin. The administrative rule will govern the runoff pro-
gram and includes a requirement that the department shall comply
with standards  identified in watershed actions plans, even if they
are more stringent than DOT's manual.
Washington
Department of
Health
The DOH, formerly part of the Department of Social and Health
Services, is responsible for regulating commercial shellfish harvest-
ing and is also involved in regulating recreational shellfish harvest-
ing.  Currently, there are no areas certified  for the commercial
harvesting of intertidal shellfish in Budd Inlet, and all public beaches
in inner Budd Inlet should be posted to prevent recreational harvest-
ing.
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                                                           1991 Action Plan for Budd Inlet
Recreational Shellfish
Program
As described in the Washington Department of Ecology Shellfish
Protection section above, the recreational shellfish program is
currently under development.   A draft program plan has been
developed and is currently under review.  A final plan should be
issued by the fall of 1991.  The plan addresses the protection of
shellfish resources and human health and includes proposed water
quality and shellfish tissue monitoring at major recreational shellfish
harvesting locations throughout Puget Sound. Another element of
the program is to develop maps with information on recommended
harvesting classifications for recreational areas. Major recreational
harvesting areas in the vicinity of Budd Inlet are Priest Point Park
and Burfoot County Park south of Boston Harbor.  The Thurston
County Health Department has closed Priest Point Park to shellfish
harvesting.  Some shellfish harvesting occurs in inner Budd Inlet,
possibly for use as bait. Shellfish are also harvested in several areas
of Budd Inlet by  waterfront property owners.  Specific  DOH
responsibilities for shellfish protection are discussed below.
Recreational Shellfish
Regulations
On 13 September 1989, the Washington State Board of Health
approved  new regulations for recreational shellfish harvesting.
These regulations give DOH and local health departments the
authority  to monitor and classify beaches as open or closed for
recreational shellfish harvesting based on bacterial counts, concen-
trations of toxic contaminants, and surveys of bacterial contaminant
sources. Recreational harvesting of shellfish could be prohibited
on beaches that have conditions that would pose unacceptable health
hazards.

In response to the regulations on recreational shellfish harvesting,
DOH will develop a Memorandum of Agreement (MO A) with the
Thurston  County Health Department.   The MOA will specify
guidelines for implementing and enforcing the proposed regula-
tions, including provisions for ambient water and shellfish monitor-
ing and ensuring laboratory reliability. The MOA will also establish
a procedure and criteria for defining areas in which the county health
department must post health warnings regarding shellfish consump-
tion.   DOH  will also provide assistance to the county health
department in conducting shoreline and watershed sanitary surveys
to identify sources of bacterial and chemical contamination.
Monitoring
DOH is scheduled to perform annual tissue chemistry sampling at
Priest Point Park under PS AMP. DOH samples water and shellfish
from Burfoot County Park for fecal coliform bacteria under the
recreational shellfish program. Once a sufficient number of water
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1991 Action Plan for Budd Inlet
                          samples have been collected (i.e., 15 samples at 5 stations) to
                          classify the Burfoot County Park area, ambient monitoring for fecal
                          coliform bacteria will be conducted annually.
Washington Parks
and Recreation
Commission
The Washington Parks and Recreation Commission has a Boater
Environmental Education Program to provide information and
services to the recreational boating community.   The  education
program addresses boater waste disposal and boater environmental
education.
Sewage Pumpouts
The Parks and Recreation Commission established the Boaters Task
Force to help educate boaters regarding waste issues and to sponsor
legislation to fund new sewage pumpouts. The task force sponsored
legislation that was passed in 1989 to fund sewage pumpouts and
environmental education efforts.  As a result of the new legislation,
between $100,000 and $300,000 per year will be set aside from the
watercraft excise tax for purchasing and installing pumpout stations
in Washington State over the next 5 years.  Up to 100 percent of
the  money may be used to purchase and install pumpout facilities.
Twelve new pumpout facilities were funded in 1990.  The City of
Olympia Parks and Recreation Department received a grant for
installing a new pumpout facility at Percival Landing. The Port of
Olympia did not  receive a grant during the last round of funding.
The current application period will end in October 1991.  The Parks
and Recreation Commission notifies all marina and boat launch
owners and operators of the availability of grant funds.

The Parks and Recreation Commission conducted a survey regard-
ing  the use of sewage pumpouts.  The commission will be conduct-
ing  another survey of boaters regarding the availability and use of
pumpout facilities in approximately 1 year.
Education
The Boater Environmental Education Program will provide three
educational signs to the marinas in Budd Inlet that have pumpout
stations.  These signs consist of a logo for the pumpout station, an
instructional  sign for pumpout use, and an interpretive sign con-
cerning the environmental impacts of improper waste disposal.

The Parks and Recreation Commission is participating in an EPA-
sponsored high school video contest called Video Visions.  Students
from selected schools in the Puget Sound area produced educational
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                                                         1991 Action Plan for Budd Inlet
                          videos on the environmental impacts of boating. These videos were
                          judged in early 1990 and are available from the Parks and Recreation
                          Commission for group presentations.
Puget Sound Water
Quality Authority
The Authority is responsible for developing the PSWQMP for water
quality protection in Puget Sound.  A comprehensive plan was
developed in 1987, revised in 1989, and was finalized in 1991. The
PSWQMP is currently being implemented by state agencies and
local governments.
Public Involvement
and Education Fund
The Public Involvement and Education (PIE) Fund was created by
the Washington State legislature in 1987 to sponsor model projects
for public involvement and education, community cleanup activi-
ties, and environmental monitoring by members of the general
public. An initial $1,000,000 was distributed in January 1988 and
June 1988.  The 1988 legislature appropriated another $1,000,000
to sponsor two more rounds of funding in 1989 and 1990. Approx-
imately $700,000 was granted in the third round in October 1989
and another $300,000 was distributed in the fourth round in April
1990. The Thurston County Resource Fair, City of Olympia, and
the Conservation Commission (Moxlie Creek)  were all recipients
of 1988 PIE fund grants. Trout Unlimited was a recipient of a 1989
PIE fund grant to restore salmon habitat on Indian Creek and educate
local businesses about BMPs and habitat restoration.
Puget Sound
Ambient Monitoring
Program
Staff at the Authority provide technical and administrative support
to PSAMP.  PSAMP provides a comprehensive, long-term moni-
toring program for Puget Sound. PSAMP was designed to 1) assist
agencies in their pollution control efforts by characterizing and
interpreting spatial and temporal trends and identifying problem
areas, 2) take measurements to support specific program elements
and measure the success of the Puget Sound plan by providing a
permanent record of significant natural and human-caused changes
in key environmental indicators over time, and 3) provide an
ongoing assessment of the health of Puget sound and the risk to
human health from consuming seafood from the sound.

The management structure of PSAMP includes the PSAMP Steering
Committee,  the  Monitoring Management Committee, and the
Authority.  The  Authority will act as the chair for  the steering
committee and the Monitoring Management Committee and will
facilitate agency cooperation among the state agencies implementing
PSAMP.  Other functions the Authority will carry out include
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755 7 Action Plan for Budd Inlet
                          providing arbitration for interagency disagreements concerning
                          PSAMP, providing and housing staff members, managing data, and
                          distributing reports of PSAMP results.
Washington
Department of
Natural Resources

Leasing Program
The Department of Natural Resources (DNR) is responsible for
managing state-owned aquatic lands.
DNR leases state-owned aquatic lands in Budd Inlet (and throughout
the state) for periods ranging from 5 to 30 years.  The aquatic lands
leasing program is being evaluated to incorporate procedures for
addressing contaminated sediment liability issues, including site
identification, investigation, and remediation.  New and recently
signed leases include provisions concerning lessee liability for
contaminated  sediments.  DNR attorneys hold the opinion that if a
facility or  activity is affecting state-owned lands, DNR can sue for
damages (e.g.,  cleanup costs and natural resource damages) on
behalf of the people of the State of Washington.
Contaminated
Sediments
DNR established the Sediments Management Section in the Division
of Aquatic Lands in January 1991. The new section will encourage
DNR leaseholders to investigate and remediate contaminated sedi-
ments on state-owned aquatic lands. The sediments section will also
represent DNR when the agency is identified as a potentially liable
party for sites containing contaminated sediments.

With funding from EPA, DNR has developed a screening process
to identify state-owned aquatic lands in Puget Sound (including
Budd Inlet) that may contain contaminated sediments.  The screen-
ing process includes the evaluation of existing uses on both leased
and unleased lands to determine the potential for sediment contam-
ination. If time and resources are adequate, historical uses of these
lands will also be assessed during the screening process.

A Puget Sound-wide list of sites that require further investigation
and possible cleanup was prepared by DNR. If a site contains
sediments that may be contaminated, it will be scored, ranked, and
placed on the list. Further investigation of these sites will determine
if they need  to be added to the state hazardous sites list.

DNR and Ecology are developing a MOA regarding contaminated
sediments on state-owned aquatic lands under which DNR will carry
out provisions of the MTCA (e.g.,  remedial investigations and
cleanups).
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                                                          1991 Action Plan for Budd Inlet
                          DNR has also been involved with developing guidelines for identi-
                          fying sediments too contaminated for unconfined, open-water dis-
                          posal under PSDDA. While no disposal sites are located within the
                          Budd Inlet project area, any sediments requiring disposal would be
                          subject to PSDDA guidelines.
Waste water
Treatment Plant
Outfalls
DNR is involved with the surface water regulations of local
jurisdictions when sewage outfall structures lie on DNR lands.
DNR regulates the placement of structures that may contaminate or
affect state-owned lands (e.g., the LOTT WWTP outfall pipe).
Resource Management
DNR is responsible for issuing leases for geoduck harvesting. DNR
has been conducting experimental planting of juvenile geoducks in
commercial beds in Budd Inlet, but will discontinue the planting if
natural recruitment (i.e.,  larval development and  maturation)
appears to be occurring at the site.

DNR manages the Aquatic Lands Enhancement Account.  This
account has money  available for funding projects to acquire land
for public recreational access and public education. Account funds
are not available for cleaning up contaminated sediments or improv-
ing water quality.
Habitat Mapping
DNR is involved in a project to inventory nearshore habitat using
remote sensing techniques (e.g., aerial and satellite photographs).
Habitat information has been gathered and will be entered into a
geographic information system (GIS) by December 1991. New data
will be collected every 3 years by the EPA and will be added to the
GIS.  When the project is complete, comprehensive habitat maps
for Budd Inlet wUl be available.
City of Olympia
Planning Department
The planning department manages shoreline development and issues
shoreline permits, develops land use regulations, and reviews
projects to be conducted within the city limits for compliance with
SEPA.
Shoreline Management
The planning department has added stricter environmental protec-
tion standards for new marinas to its Shoreline Master Program.
The new standards include a requirement for installing  sewage
pumpouts in all new marinas and existing marinas that are to be
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1991 Action Plan for Budd Inlet
                          expanded. In addition, the city recently received a $5,500 grant
                          from the Washington Parks and Recreation Commission to replace
                          the marine sewage pumpout facility located at Percival Landing.

                          The planning department is a member of the Urban Waterfront Task
                          Force.  The task force is responsible for determining requirements
                          for over-water building (e.g., piers and buildings on pilings) on the
                          nonresidential marine shorelines within the city of Olympia and for
                          implementing revisions to the Thurston Regional Shoreline Master
                          Program, the Olympia  Comprehensive Plan, and the Port of Olym-
                          pia Comprehensive Plan.  The draft Olympia Urban Waterfront
                          Plan was jointly prepared by the planning department and the Port
                          of Olympia in August  1990 under the direction of the task force.
                          The goal of the plan is to designate locations and standards for urban
                          waterfront development. In addition, a series of recommendations
                          for changes to the Olympia Comprehensive  Plan, the Port of
                          Olympia Comprehensive Plan, and the Shoreline Master Program
                          for Thurston County are included in the plan. Specific actions that
                          can be taken by the City Council, Port Commission, and other
                          jurisdictions  are also  identified.  The Budd Inlet Action Plan
                          Coordinator will attend meetings and hearings and review the draft
                          urban waterfront plan  to help ensure coordination with the Budd
                          Inlet Action Plan.  The plan  is currently  under  review by  the
                          Olympia Planning Commission and the Port Commission.   The
                          Olympia City Council and the port will review and adopt the plan
                          in the summer of 1991  after joint public hearings are held.
City of Olympia
Public Works
Department
The public works department, in conjunction with Thurston County
and the City of Tumwater, is involved in regional storm water
management.
Water Quality Policies
and Ordinances
The public works department supports adopting stricter standards
for aboveground storage tanks. If Ecology provides background
information that justifies the need for stricter standards, the city will
commit resources from within its water resources program to pursue
adoption of the standards by the Olympia City Council.

The city enforces an ordinance to protect environmentally sensitive
areas.  The ordinance was amended in May 1989 to incorporate
policy recommendations from the Thurston County Regional Plan-
ning Council concerning wetlands and stream corridors.
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                                                           7537 Action Plan for BuddInlet
Storm Water              The public works department, in conjunction with the City of
Management              Tumwater and Thurston County, produced a regional drainage
                          manual that was adopted as a city ordinance.  The city has been
                          implementing various aspects of the manual since June 1990,
                          including enhanced storm water storage and treatment requirements
                          and improved erosion and sediment control practices.  The manual
                          addresses operations and maintenance requirements for both private
                          and public facilities.  In addition, the city has developed a new Storm
                          and Surface Water Management Program that includes an enhanced
                          operations and maintenance program for storm water facilities (e.g.,
                          drains and culverts). A staff person will be hired to enforce storm
                          water ordinances, develop standards and policies, and inspect public
                          and private facilities.

                          The City of Olympia has combined sewers for sanitary sewage and
                          storm water in some older areas of the city. The storm water from
                          these areas is routed to the LOTT WWTP for treatment. In addition,
                          excessive infiltration of groundwater in the sanitary sewer lines can
                          occur during wet weather.  This water is also routed to the LOTT
                          WWTP for treatment.  When the combined volume of storm water,
                          sewage, and groundwater  exceeds the capacity of the LOTT
                          WWTP, the combined sewers can overflow into Budd Inlet. When
                          this happens, the storm water, sewage, and groundwater flow into
                          Budd Inlet untreated. The public works department is in the process
                          of separating the combined sewers where possible (e.g., disconnect-
                          ing roof drains and catch basins from the sanitary sewer lines). The
                          department is also working to eliminate infiltration and inflow into
                          sanitary sewer lines. By eliminating  storm water and groundwater
                          going to the WWTP, these measures will allow more sewage to be
                          treated at the LOTT WWTP and decrease the frequency of combined
                          sewer overflows.

                          The public works department does  not plan to separate the large
                          combined storm and sanitary sewers located in the urban area, and
                          the combined wastewater will continue to be routed to the LOTT
                          WWTP.

                          The department is developing plans for storm water control and
                          pollution abatement in the Indian/Moxlie creeks and Percival Creek
                          drainage basins.  The basin planning process includes public par-
                          ticipation, basin characterization, problem identification, develop-
                          ment of a water quality monitoring plan, and production of a basin
                          storm water management plan. In addition to the two basin plans
                          currently underway, the City of Olympia intends to conduct basin
                          planning for the East and West bay drainages if money becomes
                          available.  The Budd Inlet Action  Program and basin planning
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1991 Action Plan for Budd Inlet
                          activities are coordinated through the involvement of the City of
                          Olympia Water Resources Program staff on the Budd Inlet Action
                          Team.

                          The city is currently working on an interlocal agreement with the
                          City of Tumwater and Thurston County to maintain permanent flow
                          and water quality monitoring stations in the Indian/Moxlie creeks
                          and Percival Creek drainage basins.
Sediment Sampling
The city conducted intertidal sediment sampling northwest of the
Moxlie Creek outfall for an environmental impact statement for the
proposed Olympic Academy project.  It has recently been decided
that this project will not be pursued. Sediments were analyzed for
priority pollutants, and sediments and surface water were analyzed
for fecal coliform bacteria. Levels of nickel and PAHs in samples
from some locations were found to exceed AETs (Entrance 1990).
Fecal coliform bacteria concentrations were considered high; how-
ever, there is no standard for fecal coliform bacteria in sediments.
Capitol Lake
Restoration
The city participated in the development of the Capitol Lake
Restoration Committee Report and Proposed Action Plan and
currently hosts an interagency committee to implement the proposed
action plan.  The action plan includes proposed restoration actions
related to lake management and point and nonpoint contaminant
sources.  The purposes of the committee are 1) to provide a forum
to track the activities of the jurisdictions and agencies involved in
Capitol Lake, 2) to coordinate actions affecting Capitol Lake, and
3) to ensure implementation of the Capitol Lake Restoration Plan.
Current  members of the interagency  committee  include the
Governor's  Office;  the Washington departments of  General
Administration, Fisheries, and Transportation; the cities of Olympia
and Tumwater; Thurston County; and the Squaxin Tribe. A staff
member from Ecology's Water Quality Financial Assistance Pro-
gram is also on the committee.  The committee's activities will be
coordinated with the Budd Inlet Action Plan through the following
means:

    •  Communication between the Ecology staff member who is
      on the committee and the Ecology Budd Inlet Action Plan
      Coordinator

    •  Attendance by the Ecology Budd Inlet Action Plan Coordi-
      nator at committee meetings, or review of meeting minutes
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                                                           1991 Action Plan for Budd Inlet
                              •  Involvement by the City of Olympia on the Budd Inlet Action
                                 Team.
Education
The department recently received funding from Ecology to carry
out a 2-year storm water education project targeting local businesses
and the construction industry.  The city has recently hired a staff
person who will conduct site visits, hold educational workshops,
and inform business operators about storm water and erosion
regulations. These activities will be coordinated with the Thurston
County Moderate Risk Waste Program and the Budd Inlet Action
Plan.  Ecology's Budd Inlet Action Plan Coordinator will attend the
city's steering committee meetings for the storm water project, and
the Water Resources Program supervisor will be involved in the
Budd Inlet Action Team.

The city will be developing informational brochures covering its
storm water policies, BMPs, storm water facility design standards,
water quality educational programs,  and other topics. The flyers
will be distributed to staff, private developers (e.g., construction
companies), and others. The city is also developing a storm drain
stenciling program to label drains that discharge to streams so that
pollutants are not put in  the drains.  Twelve stenciling kits and
training materials are available through the city for use by interested
groups.  Through its Stream Team Program, the city is working
with neighborhood groups interested in specific stream restoration
and cleanup activities.

The city is considering televising a city council meeting during
which environmental issues regarding Budd Inlet will be discussed.
Potential issues include general water quality and watershed man-
agement efforts.
Thurston County
Office of Water
Quality and Resource
Management
The Office of Water Quality has coordination and management
responsibility for storm water and groundwater programs, water-
shed planning, and other environmental programs.

The Office of Water Quality is responsible for implementing the
regional drainage requirements, as specified in the regional drainage
manual (discussed in the City of Olympia Public Works Department
section), in areas under county jurisdiction.  The manual will be
adopted as an ordinance by Thurston County and will be in use by
mid-1991.
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1991 Action Plan for Budd Inlet
Water Quality Policies
and Ordinances
An erosion control ordinance is expected to be adopted by the county
commissioners by  August 1991.   The ordinance will provide
enforcement authority to the county for controlling erosion prob-
lems. Funding for the enforcement activities has not been secured
and sources are currently being examined.
Groundwater
The county administers the groundwater program and is in the
process of characterizing aquifers located in northern Thurston
County.  The characterization includes location, flow, depth, and
water quality information. Over 350 wells have been sampled.  A
final report, detailing the results of the groundwater characteriza-
tion, is to be completed by July 1991. A North Thurston  County
Groundwater Management Plan will be developed as a product of
the groundwater management program and groundwater character-
ization study. A draft plan will be completed by August  1991, and
the final plan will be adopted by January 1992.
Sewage Plan
The Office of Water Quality has developed a sewage plan for the
unincorporated area around the cities of Lacey, Olympia, and
Tumwater. The plan details how additional sewer facilities will be
developed in the future.
Education
The Office of Water Quality has a Centennial Clean Water Fund
grant to implement a water quality education program.  The pro-
gram will fund a water quality agent to educate citizens about BMPs,
expand the stream rehabilitation program by using more volunteers,
and establish a water quality educators' network for sharing educa-
tion resources and information.  A quarterly newsletter addressing
water quality activities and programs will also be produced.
Thurston County
Health Department
The Thurston County Health Department is the lead agency for
conducting an information assessment for the Budd Inlet and
Deschutes River watershed. The county health department is also
involved in environmental monitoring, solid and hazardous waste
programs, and health-related programs.
Watershed
Management
In support of watershed planning activities, the county health
department received a $315,000 grant from Ecology to conduct
monitoring, data gathering and evaluation, and an information
assessment in  the  Budd Inlet  and Deschutes River watershed.
Existing water quality data were analyzed and are being used to
develop a work plan for additional data collection and analysis.  The
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                                                            1991 Action Plan for Budd Inlet
                           county is now collecting conventional data (i.e., temperature) at
                           water quality stations and chemical data at selected sediment quality
                           stations. Throughout all data collection activities, the county plans
                           to identify upland sources of contamination.
Monitoring
The county health department has been conducting a limited sam-
pling program for shellfish and marine water quality along private
property and Priest Point and Burfoot County parks in Budd Met.
The sampling has occurred each year from June through August
since 1987.  Sample locations and analytical results are published
yearly.  Under this program, marine water at Priest Point Park was
repeatedly  found to have  high fecal coliform  bacteria levels.
Consequently, the health department and the City of Olympia posted
the beach off-limits  for shellfish harvesting.  Marine water at
Burfoot County Park was found to have high bacterial counts during
one sampling event; however, these results could not be reproduced
with subsequent sampling.  Therefore, the health department did
not limit recreational shellfish harvesting in this area.

In addition, the county health department will encourage citizens to
collect shellfish to be sampled for fecal coliform bacteria, specific-
ally targeting residents  living near small WWTPs.  The county
health department and DOH will conduct the bacteriological analy-
ses.
Nonpoint Pollution
Ordinance
The Thurston County Health Department is currently developing
an ordinance that will help control pollution from nonpoint sources.
The ordinance is presently in the scoping stage and categories of
nonpoint sources and operating practices of concern have been
identified.  Nonpoint sources include animal waste, marinas, mod-
erate risk wastes (i.e., household wastes), and  hazardous wastes.
Operating practices include ongoing activities and specific incidents
that cause pollution.  This ordinance is unique to the Thurston
County Health Department and is primarily concerned with public
health.
Moderate Risk Waste
The Thurston County Moderate Risk Waste Plan was developed by
the health department as a response to requirements of the 1985
amendments to the state Hazardous Waste Management Act. The
plan addresses potential human health and environmental problems
associated with household hazardous waste and generators of small
quantities of hazardous waste. Health department staff will provide
recommendations on how to reduce hazardous waste after conduct-
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753 7 Action Plan for BuddInlet
                          ing surveys of existing waste generating activities. In addition, staff
                          from this program will be invited to participate in the Budd Inlet
                          Action Plan.  The Budd Inlet Action Plan Coordinator will coordi-
                          nate, where appropriate, site visits and inspections with the moder-
                          ate risk waste program's surveys.
Sewer Systems
The health department is currently revising the health code and
policies regarding onsite sewage systems.   The revisions will
include a provision for issuing renewable or revokable sewage
system permits, a management and maintenance program, a certi-
fication system, and education regarding onsite sewage system
maintenance.
Thurston County
Public Works
The Thurston County Public Works Department is responsible for
storm water management in the unincorporated county and for
public works construction projects.
Storm Water
Management
The public works department has developed a storm water utility.
The Thurston County commissioners agreed to establish a surface
water utility charge to fund storm and surface water activities in
northern Thurston  County.  Activities of the storm water utility
include contributing to the Budd Inlet and Deschutes River moni-
toring effort and developing basin plans.

The department is also responsible for implementing the regional
drainage requirements as specified in the regional drainage manual
(discussed in the City ofOlympia Public Works Department section)
in areas under its jurisdiction.  The manual will be adopted as an
ordinance by Thurston County and will be in use by mid-1991.
Boston Harbor
Wastewater
Treatment Plant
Construction of the Boston Harbor WWTP was recently completed
by the county public works department. The plant has been on-line
since August 1990. This plant provides secondary sewage treatment
and has a capacity of 60,000 gallons per day.
Port of Olympia
The Port of Olympia operates the East Bay marina, which includes
a boat sewage pumpout facility.  The port maintains log storage
areas on the peninsula located between East Bay and West Bay.
Shipping activity in this area is predominantly log loading.  The
port also leases land for other commercial and industrial develop-
ment.
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                                                          1991 Action Plan for Budd Inlet
Storm Water
The port has paved the southwest corner of the property on the
peninsula that is used for log storage, and the remaining log storage
areas will be paved as funds permit.  The paving of the log storage
areas allows storm water to be collected and treated before being
discharged to Budd Inlet.  The port is applying, as part of a group
application, to EPA for an NPDES permit for six storm water
outfalls that are  located on the port's peninsula property.  The
application will be submitted by September 1991.  Phase 1 of the
permit will include monitoring information on storm water quality.
The port has hired a contractor to prepare a sampling and analysis
plan and conduct sampling during the winter of 1991-1992.  The
sampling plan will be submitted to EPA for review.  The sampling
results will be used to determine the long-term permit limitations.
East Bay Water Quality
The port's application in 1990 to the Washington State Parks and
Recreation Commission for a grant to replace the existing East Bay
Marina sewage pumpout facility was not funded. The port has taken
interim measures (e.g., adding a booster pump) to improve the
performance of the existing facility until it can be replaced.   The
port will reapply to the Parks and Recreation Commission for grant
funds to be awarded in 1991.  The deadline for application is
October 1991.

The port conducts sampling in the East Bay Marina moorage area
to monitor dissolved oxygen  levels.  The port has installed 21
aerators in East Bay that are used when dissolved oxygen levels at
the bottom of the bay fall below 5 ppm.
Shoreline Management
As discussed in the Gty of Olympia Planning Department section,
the port and the City of Olympia formed an Urban Waterfront Task
Force and developed an urban waterfront master plan in August
1990.  The plan focuses on regulating waterfront development
within the city boundaries. In addition, a series of recommendations
for changes to the Olympia Comprehensive Plan,  the Port of
Olympia Comprehensive Plan, and the Shoreline Master Program
for Thurston County are included in the plan. Specific actions that
can be taken by the City Council, Port Commission, and other
jurisdictions are also  identified.  The Budd  Inlet Action Plan
Coordinator will attend meetings and hearings and review the draft
urban waterfront plan to help ensure coordination with the Budd
Inlet  Action Plan.  The  plan is currently under review by the
Olympia Planning Commission  and  the Port Commission.   The
Olympia City Council and the port will review and adopt the plan
in the summer of 1991, after joint public hearings are held.
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1991 Action Plan for Budd Inlet
                          The port requires lessees to provide a list to the port of all petroleum,
                          dangerous, toxic, and hazardous materials.  The lessees also agree
                          to abide by all applicable environmental laws and cleanup provis-
                          ions.
Remedial Activities
The port, McFarland/Cascade Pole, and Ecology have signed a
consent decree for the cleanup of the McFarland/Cascade Pole site.
The consent decree requires preparation of a final cleanup plan by
mid-1992.

The port received an $856,000 grant from Ecology to pay for about
50 percent of its project costs over the next 2 years (see discussion
under Washington Department of Ecology).

The last two underground tanks on port property were removed in
September 1990.
Dredging
The port and the Corps are evaluating potential improvements to
the existing navigation channel in West  Bay.  Because  of the
findings of an economic feasibility study, expansion of the turning
basin next to the navigation channel is no longer being considered.
Plans to widen the channel are still being  considered, but will be
postponed until the improvements are economically necessary. The
port and the Corps will meet during the summer of 1991 to evaluate
the project and make a decision.   The final feasibility report for
improvements was completed in April 1991, but if dredging occurs,
it would not begin before 1993.

The port has also collected sediment chemistry data for Berth 3.
City of Tumwater
Public Works
Department

Storm Water
The city of Tumwater Public Works Department has responsibility
for storm water management.


The Public Works Department is responsible for implementing the
regional drainage requirements as specified in the regional drainage
manual that was drafted by the cities of Olympia, Tumwater, and
Lacey and by Thurston County. The city will adopt the manual by
ordinance.
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                                                         1991 Action Plan for Budd Inlet
                          The department, in conjunction with the City of Olympia, conducted
                          a storm drain study for Percival Creek that focused on water quality.
                          The study was completed at the end of 1990.  The data will be used
                          to prioritize capital improvement needs.   High-priority  capital
                          improvements will be addressed beginning in 1992.

                          The department has also prepared storm drainage master plans for
                          the north and south Tumwater Hill areas.   These master plans
                          evaluate and recommend plans for conveying, detaining/retaining,
                          treating, and discharging storm water in these two rapidly develop-
                          ing basins.  Both plans focus on improving water quality.
Education
The Public Works Department will help to educate citizens about
the hazards of dumping wastes in storm drains that connect to
waterways. The department will begin  storm drain stencilling in
1991.
City of Tumwater
Department of
Community and
Economic
Development
The City of Tumwater Department of Community and Economic
Development (CED) processes shoreline permits and reviews devel-
opment projects for consistency with construction codes, land use
and environmental regulations, and SEPA. CED is also responsible
for the construction and maintenance of parks.

CED will be examining potential funding sources that could be used
to increase inspection and enforcement activities related to SEPA
conditions, building codes, and erosion and sedimentation require-
ments.
LOTT Wastewater
Treatment Program
The LOTT WWTP treats wastewater from the cities of Lacey,
Olympia, and Tumwater and Thurston County.  LOTT is respon-
sible for plant maintenance and improvements, CSOs, and industrial
discharges.
Plant Improvement
Under a current NPDES permit and enforcement order from
Ecology, the LOTT WWTP must increase its capacity and make
other improvements by 1993.   LOTT WWTP jurisdictions will
construct a nitrogen-removal facility that will significantly decrease
the amount of nitrogen being discharged to Budd Inlet  and will
switch from a chlorination disinfection system to an ultraviolet
disinfection system.
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1991 Action Plan for Budd Inlet
                          The current combined average flow for all outfalls at the WWTP is
                          13 MGD in the winter and 9 - 10 MOD in the summer. The highest
                          recorded flow in any 24-hour period was 65 MGD during a 100-year
                          storm. Improvements required by Ecology will increase the overall
                          plant treatment capacity for peak flows from 35 to 55 MGD.  The
                          monthly average for peak flows  during wet weather  will be
                          22 MGD.

                          The WWTP currently operates  two outfalls (see Figure 5).  The
                          primary outfall has a capacity of 9-13 MGD and is located north
                          of the peninsula owned by the Port of Olympia.  The secondary
                          outfall (48-inch pipe) is located near Fiddlehead Marina and dis-
                          charges  to  West Bay.  A portion of  the  WWTP's effluent is
                          discharged  daily  through  this secondary outfall.   The primary
                          outfall will be upgraded, and the use of the secondary outfall will
                          be discontinued.  The upgrade  will include a new above-ground
                          section of pipe that will follow the perimeter of the McFarland/Cas-
                          cade Pole site to reach the outfall location.  The new pipe outfall
                          location  will be near the current outfall location.  When cleanup
                          activities at the McFarland/Cascade site are completed, the above-
                          ground pipe will be buried.

                          All improvements required under  Ecology's enforcement order
                          must be completed by April 1993 or a general construction mora-
                          torium within the LOTT service  area (i.e., the Urban Growth
                          Management Area) will be imposed. This deadline may be revised
                          to accommodate mitigation requirements for impacts to a small
                          wetland that the new above-ground  outfall pipe will cross.
Combined Sewer
Overflows
The plant has an average of less than one CSO event per year.
Urban storm water from some parts of the existing system will not
be processed separately and will probably always pass through the
plant. In its service areas, LOTT is trying to reduce storm water
inflow and infiltration of groundwater to sewer lines, to increase
plant capacity during wet weather.

As required by its NPDES permit, LOTT recently installed locked
valves on the overflow structures at the East and West bay pump/lift
stations.  When an overflow occurs, LOTT personnel must man-
ually open these valves and report the overflow event to Ecology.
Industrial Discharges
A proposed pretreatment program for industries that discharge to
LOTT has been submitted to Ecology for comment and approval.
The program is expected to be approved and in place by December
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                                                          1991 Action Plan for Budd Inlet
                          1991. The pretreatment program will include facility inspections,
                          a permitting system, and enforcement activities (e.g., fines). LOTT
                          jurisdictions jointly established a uniform program enforceable by
                          each jurisdiction (i.e., Lacey, Olympia, Tumwater, and Thurston
                          County) and coordinated and directed by LOTT.  After Ecology
                          approves the program, it will be adopted individually by each
                          jurisdiction.   Two major industries that discharge to  LOTT are
                          planning pretreatment activities. The Pabst/Olympia Brewery plans
                          to reduce the quantity of nitrogen in its effluent to limit surcharges
                          imposed by LOTT. The Weyerhaeuser plant will be pretreating its
                          effluent when it connects to LOTT within the next year.

                          LOTT has completed an industrial survey of the service area. Plant
                          influent is occasionally sampled for organic and metal contaminants.
                          Plant personnel perform regular inspections and spot checks at most
                          industries that discharge to the plant.


Monitoring                LQTT monitors five sites in Budd Inlet for dissolved oxygen and
                          chlorine in water and metals in sediments. LOTT will also conduct
                          ambient baseline and routine monitoring at the north end of Budd
                          Inlet peninsula due to placement of the new outfall.
                          Site-Specific Action Plan

                          The site-specific action plan addresses areas with known eutrophi-
                          cation, known bacterial and chemical contamination, and potential
                          contaminant sources.  The site-specific action plan is intended to
                          prioritize source identification, source control, and remedial activ-
                          ities according to priority problem areas.  Source-specific actions,
                          presented in Table 2, identify specific contaminant sources and
                          source-specific control  actions that  will be taken to improve
                          environmental conditions in Budd Inlet.  Sources listed in Table 2
                          are those identified in Tetra Tech (1988) and by the members of the
                          Interagency Work Group and Citizen Advisory Committee (see also
                          Figure 5).  Source characteristics and status were identified in the
                          data summaries document and by work group members. Actions
                          are those activities specifically related to source control or contam-
                          inant remediation that have been agreed upon by the individual
                          agencies in the work group. The implementation date lists actual
                          and projected start and finish dates for each action. Limiting factors
                          represent requirements  needed by agencies to implement specific
                          actions.  Blank  areas indicate gaps in knowledge of the source
                          characteristics or actions to limit or remediate contamination
                                                       51

-------
19S  Action Plan for Budd Inlet
                          problems. One of the ongoing tasks of the work group is to further
                          refine priorities and secure commitments from participating agen-
                          cies to perform additional source identification and implement
                          source control measures.

                          Tables 3 through 8 summarize general programmatic actions that
                          will be taken to improve environmental conditions in Budd Inlet.
                          There is some overlap among  the programmatic action tables
                          (Tables 3 through  8) and between the programmatic action tables
                          and the source-specific action table (Table 2). Table 3 lists areawide
                          planning and program development actions; Table 4 lists contami-
                          nant control actions; Table 5 lists remedial (cleanup) investigations;
                          Table 6 lists monitoring activities occurring in the project area;
                          Table 7 lists resource protection  actions; and Table 8 presents the
                          various  educational activities  and  programs that will  be
                          implemented. Each of these tables gives a brief description of the
                          action, lists the agencies involved,  and notes the starting or ending
                          target dates when known.  More  detail concerning activities in the
                          action column can be found in the Comprehensive Plans and
                          Programs section of this report.
                                                      52

-------
                                                        TABLE 2.  SOURCE-SPECIFIC ACTIONS"
Potential Source
    Source Characteristics and Status
          Action
    Agencies Involved
Target Dateb
   Limiting Factors
Tamoshan wastewater
treatment plant (WWTP)
Beverly Beach WWTP
Seashore Villa WWTP
Boston Harbor WWTP
LOTT outfalls; primary
and secondary
Water Street Combined
Sewer Overflow (CSO)
State and Chestnut
streets CSO
Secondary  WWTP;  limitations  include
0.035 MOD, 30 mg/L (916 Ib/day)  BOD,
3O  mg/L (916 Ib/day) SS,  200 colonies
fecal coliform bacteria per 100 mL effluent;
NPDES permit expires 10/91
        s,"'
Secondary WWTP; average flow £3,000
gallons/day;  limitations include 3O  mg/L
(1.25 Ib/day) BOD, 30 mg/L (1.25 Ib/day)
SS, 20O colonies fecal coliform bacteria per
1OO mL effluent; NPDES permit expires
3/96

Secondary WWTP; average flow ^3,600
gallons/day;  limitations include 30  mg/L
(3.8 Ib/day) BOD, 30 mg/L (3.8 Ib/day) SS,
2OO colonies fecal coliform bacteria per
1OO mL effluent; NPDES permit redraft in
process

Secondary WWTP; average flow (see per-
mit); NPDES permit expires 3/95
Secondary WWTP; 16.3 MGD; limitations
include  30 mg/L  (4,000  Ib/day)  SS and
BOD, 2OO colonies fecal coliform  bacteria
per 1OO mL effluent; NPDES permit expires
9/92

Untreated sewage and stormwater runoff;
limitations  for LOTT WWTP  apply  (see
above);  inflow and infiltration  (l&l) to be
addressed as required by  permit;  covered
under NPDES permit for LOTT

Untreated sewage and stormwater runoff;
limitations  for LOTT WWTP  apply  (see
above); l&l to be addressed as required by
permit; covered under NPDES permit for
LOTT
Review and reissue permit
Review and reissue permit
Review and reissue permit
Set permit limits and issue per-
mit
Review and reissue permit
Washington Department
of Ecology (Ecology)
Ecology
    6/91
 (to begin)
    3/91
(completed)
Ecology
    5/91
Ecology
Ecology
                                                                  Comply  with  administrative   LOTT
                                                                  order amending current permit
LOTT-Ecology meeting to reach   LOTT
agreement on any further CSO
and l&l reduction plans
LOTT-Ecology meeting to reach   LOTT
agreement on' any further CSO
and l&l reduction plans
   3/96




   9/92

  Ongoing
                              To be
                            determined
                              (TBD)
                               TBD
Implementation of
recommendations by
Efficiency Commis-
Implementation of
recommendations by
Efficiency Commis-
Implementation of
recommendations by
Efficiency Commis-
sion
Implementation of
recommendations by
Efficiency Commis-
sion

Implementation of
recommendations by
Efficiency Commis-
sion

-------
TABLE 2. SOURCE-SPECIFIC ACTIONS (Continued)
Potential Source
Port of Olympia


Pabst/Olympia Brewery
Delson Lumber/
Olympia Forest Products
Chevron
Dunlap Towing/West Bay
Chip Reload
West Bay Pump/Lift Sta-
tion
Hardel Mutual Plywood
Corporation
Reliable Steel Fabricators
Inc.
Industrial Petroleum Dis-
tributors
Historical landfill
Past Texaco storage
facility
Source Characteristics and Status
Stormwater runoff


Stormwater runoff; NPDES permit adminis-
tratively extended to 1 2/99
Stormwater runoff; potential soil and sedi-
ment contamination from past activities;
facility burned in 1990, NPDES permit
canceled
Potential soil and groundwater contamina-
tion from past activities
Stormwater runoff
Untreated sewage and Stormwater runoff
Stormwater runoff
Stormwater runoff
Stormwater runoff
Effluent characteristics unknown; closed
prior to regulations for landfill closure
Petroleum-contaminated soils
Action
Complete group application for
Stormwater NPDES permit
Conduct runoff sampling
Issue permit
Incorporate storm water runoff
limits into revised permit
Evaluate sediment and water
sample data gathered 9/90;
WARM ranking if necessary
TBD; WARM ranking if neces-
sary
Require Stormwater NPDES
permit application or Notice of
Intent (NOI)
CSO/I&I reduction plan
Require Stormwater NPDES
permit application or NOI
Require Stormwater NPDES
permit application or NOI
Require Stormwater NPDES
permit application or NOI
Sampling
WARM ranking
Agencies Involved
Port of Olympia
Port of Olympia
Ecology or EPA
Ecology
Ecology
Ecology
Ecology
Ecology
LOTT
Ecology
Ecology
Ecology
Ecology
Ecology
Target Dateb Limiting Factors
9/91
Winter 1991-92
TBD
TBD
6/91
9/91
11/91
Ongoing
11/91
11/91
11/91
TBD
6/91

-------
   TABLE 2.  SOURCE-SPECIFIC ACTIONS (Continued)
Potential Source
McFarland/Cascade Pole
site
Petroleum-contaminated
soils at south, end of East
Bay
San Francisco Avenue
stormwater outfall
East Bay Drive pump/lift
station
Jasper/Eastside pump/lift
station
Percival Cove salmon
Source Characteristics and Status
Soil and sediment contaminated with creo-
sote; state-listed hazardous waste site;
cleanup under consent decree
Petroleum-contaminated soils
Untreated stormwater runoff
Untreated sewage and stormwater runoff
Untreated sewage and stormwater runoff
Nutrient loading, BOD
Action
Conduct remedial investigation
and feasibility study
Enforce consent decree require-
ments
Initial investigation
WARM ranking
Sample runoff
CSO/I&I reduction plan
CSO/I&I reduction plan
Determine amount of nutrient
Agencies Involved
McFarland/Cascade Pole
Port of Olympia
Ecology
Ecology
Ecology
City of Olympia
Ecology
LOTT
Ecology
LOTT
Ecology
Target Dateb Limiting Factors
Ongoing
Ongoing
9/91
TBD
TBD
Ongoing
Ongoing
TBD
Ol
Ul
     rearing pen
     Mothballed fleet
     Athens Beach area
     Olympia Country & Golf
     Club area
     French Loop Road and
     Butler Cove area
                                        loading to Capitol Lake
                             Fisheries
                             Washington Department
                              of General Administration
Former site of mothballed Navy fleet; po-
tential  contaminants  include  solvents,
waste oils, and metals

Fecal coliform bacteria;  specific sources
unknown

Fecal coliform bacteria,  nutrient loading,
pesticides; specific sources unknown
Fecal coliform bacteria,  nutrients; specific
sources unknown.
Characterized sediments and   Ecology
rank for cleanup


Monitor water quality; identify   TBD
sources
Require runoff sampling

Conduct sediment sampling
Ecology

Thurston County Health
Department
Monitor  water  quality  and   Thurston County Health
identify sources               Department
 TBD



 TBD


12/92

10/91


12/91

-------
TABLE 2.  SOURCE-SPECIFIC ACTIONS (Continued)
Potential Source
West Bay Marina


Fiddlehead Marina
One Tree Island Marina

Martin Marina
Source Characteristics and Status
Fecal coliform bacteria from boat sewage;
boat repair and painting activities at upland
boatyard; no sewage pumpout


Fecal coliform bacteria from boat sewage;
no sewage pumpout; boat repair and paint-
ing activities
Fecal coliform bacteria from boat sewage;
boat repair and painting activities; no sew-
age pumpout
Capped contaminated sediments site
Fecal coliform bacteria from boat sewage;
Action
Sample runoff/sediments
Follow up on water quality in-
spection
If marina is expanded, require
pumpout
Require stormwater NPDES
permit or NOI
Require implementation of best
management practices
If marina is expanded, require
pumpout
Require implementation of best
management practices
If marina is expanded, require
pumpout
Monitor effectiveness of cap
Require implementation of
Agencies Involved
Thurston County Health
Department
Ecology
City of Olympia
Ecology
Ecology
City of Olympia
Ecology
City of Olympia
TBD
Ecology
Target Dateb Limiting Factors
TBD
6/91
12/92
11/91
12/92
TBD
12/92
12/92
TBD
12/92
 Olympia Yacht Club
                          no sewage pumpout; boat repair and paint-
                          ing activities
Fecal coliform bacteria from boat sewage;
boat repair and painting activities; no sew-
age pumpout
best management practices

If marina is expanded, require    City of Olympia
pumpout

Require implementation  of       Ecology
best management practices
                                       If marina is expanded, require    Olympia
                                       pumpout

Painting and scraping in intertidal area at   Require implementation of
low tide (tide grid)                        best management practices      Ecology
12/92
                                                                                                                            12/92

-------
  TABLE 2. SOURCE-SPECIFIC ACTIONS (Continued)
Ol
Potential Source
East Bay Marina



Boston Harbor Marina
West Bay drain
Ellis Creek drainage
Moxlie Creek drainage
Small drainages flowing
into East and West bays
Tumwater Valley Golf
Club area (Deschutes)
Source Characteristics and Status
Fecal coliform bacteria from boat sewage;
boat repair and painting activities
Low dissolved oxygen


Fecal coliform bacteria from boat sewage;
boat repair and painting activities; no sew-
age pumpout
Untreated stormwater runoff and contami-
nants from McFarland/Cascade Pole site
Fecal coliform bacteria; specific sources
unknown
Fecal coliform bacteria; specific sources
unknown
Fecal coliform bacteria, nutrients; specific
sources unknown
Pesticides, nutrient loading; specific sourc-
es unknown
Action
Repair/replace pumpout
Conduct regular dissolved
oxygen monitoring
Repair/replace dissolved oxy-
gen monitoring equipment
Place signs on aerators to
discourage boaters from turn-
ing them off
Require implementation of
best management practices
Supply pumpout grant infor-
mation and encourage applica-
tion
Sample runoff
Identify sources
Develop basin plan, conduct
monitoring, and identify
sources
Develop basin plan, conduct
monitoring, and identify
sources
Develop basin plan, conduct
monitoring, and identify
sources
Require runoff sampling
Agencies Involved
Port of Olympia
Port of Olympia
U.S. Army Corps of Engi-
neers
Port of Olympia
Ecology
Washington Parks and
Recreation Commission
Port of Olympia
Ecology
Ecology
City of Olympia Public
Works
City of Olympia Public
Works
City of Olympia Public
Works
Ecology
Target Dateb Limiting Factors
Completed
Ongoing during
critical periods
TBD
TBD
12/92
TBD
Winter 1991-92
TBD
TBD
1 992 Basin planning fund-
ing
TBD
1 992 Basin planning fund-
ing
12/92

-------
TABLE 2.  SOURCE-SPECIFIC ACTIONS (Continued)
Potential Source Source Characteristics and Status
Other industrial and com- Stormwater runoff
mercial businesses in the
Budd Inlet/Deschutes
River Basin0





Industrial and commercial Stormwater runoff
businesses located on
Olympia's west side






Industrial and commercial Stormwater runoff
businesses located in East
Olympia/lndian Creek
<£J drainage basin
00




Industrial and commercial Stormwater runoff
businesses located in the
Action
Prioritize inspections and sam-
pling efforts

Conduct inspections and
sampling
Require Stormwater NPDES
permit application or NOI
Require implementation of
best management practices
Prioritize inspections and sam-
pling efforts

Conduct inspections and
sampling
Require Stormwater NPDES
permit application or NOI
Require implementation of
best management practices
Prioritize inspections and sam-
pling efforts

Conduct inspections and
sampling
Require Stormwater NPDES
permit application or NOI
Require implementation of
best management practices
Conduct site visits; enforce
local Stormwater policies;
Agencies Involved
Ecology


Ecology

Ecology

Ecology

Ecology


Ecology

Ecology

Ecology

Ecology


Ecology
Ecology

Ecology

City of Olympia Public
Works
Target Dateb Limiting Factors
8/91


Ongoing

11/91

Ongoing

8/91


Ongoing

11/91

Ongoing

8/91


Ongoing
11/91

Ongoing

6/91
(begin)
 City of Olympia

 Industrial and commercial
 businesses located in
 Thurston County
Improper storage and disposal of moderate-
risk wastes
educate local businesses

Conduct site visits; survey
waste-generating activities;
recommendations to reduce
waste
Thurston County Public
Works
Ongoing

-------
    TABLE 2.  SOURCE-SPECIFIC ACTIONS (Continued)
    •   BOD - biochemical oxygen demand
        MGD - million gallons per day
          SS - suspended solids
      WARM - Washington Ranking Method (for hazardous waste investigations)
      NPDES - National Pollutant Discharge Elimination System
       LOTT - Lacey, Olympia, Tumwater, and Thurston County

    b End date for action, except where noted.

    0 Industrial and commercial businesses in the Budd Inlet/Deschutes River Basin include:
    A1  Rentals
    Advanced Automotive
    Allen's Wrecking Yard
    AM/PM Minimart and Gas Station
    Amick Martin 4x4
    Arco Gas Station
    ARO Glass
    Automotive Specialties Service
      Center
    B&B Auto Repair
    Bernie's Garage
    Betschart Electric
    The Boat Company
    Bob's Automotive
    BP Gas Station
Budget Car & Truck Rental
Buffalo Signs
Capital Marine
Capitol Body & Fender
Capitol City Press
Delson Lumber/Olympia Forest Products
  (former)
Dunlap Towing/West Bay Chip Reload
Earl Sheib Auto Painting
Eric's Automotive
Fast Fuel
Gordon's Radiator
Hardel Builder's Center
Hardel Mutual Plywood
Howard's 76 Station
Hoy Sign Company
Industrial Petroleum Distributors
Intercity Transit Station - Columbia St.
Ken's Tire
Lessen Electric
Pete Lea Automotive Medical Center
Lee Schwab Tires
Lloyd's Transmission
NW Limo Auto Detailing
Olympia Auto Service
Olympia Autobody
Olympia Electric
Olympia Glass
D.G. Parrott & Sons - Machinists and
  Manufacturers
Port of Olympia (including all lessees)
Puget Power parking lot
Quality Muffler & Brakes
Raudenbush
Reliable Steel Fabricators
Safelite Auto Glass
Solid Wood Inc.
Stop & Go Auto Repair
Superior Linen Service
Tom's Outboards
Unocal
Walt's Muffler & Brakes
West Bay Marina Boatyard
Western Sheet Metal
Whit Reading Motor Sales
York Air Conditioning & Refrigeration
Zeigler's Welding
Oi
CD

-------
                                     TABLE 3.  PLANNING AND PROGRAM DEVELOPMENT ACTIONS
                             Action
         Agencies Involved
Target Date8
Limiting Factors
Implement Budd Inlet/Oeschutes River watershed management program
for nonpoint source contaminant control
   Phase 1:

   -  Data collection and analysis plan

   -  Water quality data collection and analysis

   -  Upper Deschutes Channel characterization (data collection and
      continuing development of geographic information system)

   Phase 2:

   -  Development of nonpoint source watershed action plan for Budd
      Inlet/Deschutes River basin

   -  Continue water quality monitoring

   Phase 3:

   -  Implement watershed action plan


Adopt stormwater management operation and maintenance, storm
drain sediment disposal, and complaint response policies

Increase funding for enforcement of Shoreline Master Program, State
Environmental Policy Act (SEPA), building codes, erosion policies

Develop erosion control ordinance (including enforcement provisions
and funding mechanisms)

Administer volunteer recreational shellfish tissue sampling and followup
sampling
Thurston County
Washington Department of Ecology
  (Ecology)
Thurston County                         Completed

Thurston County                           12/91

Thurston County                           9/91
Squaxin Island Tribe


Thurston County                          1992-93


Thurston County                          1993-94


Implementing agencies                   1993 onward


Thurston County                           7/91


Thurston County                           TBD


Thurston County                           8/91


Thurston County                          Ongoing
                Centennial Clean Water Fund
                (CCWF) grant

                CCWF grant
                Development of watershed
                action plan
                County Commission approval
                County Commission approval
                Funding
- Target residents in areas of concern
Administer Storm and Surface Water Management Program (including
funding for enforcement and education elements)
Develop Indian/Moxlie Drainage Basin Plan
- Phase 1 (data collection)
- Phase 2 (capital improvement plan)
City of Olympia
City of Olympia
(Thurston County)
TBD
Ongoing
12/90
12/91
Completed
City Council adoption

-------
      TABLE 3. PLANNING AND PROGRAM DEVELOPMENT ACTIONS (Continued)
                                   Action
                                                                           Agencies Involved
                                       Target Date*
      Limiting Factors
0>
      Hire staff to enforce erosion and sediment requirements of Stormwater
      Management Program

      Revise shoreline master plan and City Comprehensive Plan (to reflect
      Urban Waterfront Plan recommendations and other changes)

      Develop basin plans for East and West bays
      Identify funding sources to increase inspection and enforcement activ-
      ities related to Shoreline Master Program. SEPA. building code, and ero-
      sion/sedimentation requirements

      Schedule meeting to reach concurrence on requirements of Combined
      Sewer Overflow/Infiltration and Inflow Reduction Plan
      Submit Combined Sewer Overflow/Infiltration and Inflow Reduction
      Plan if required

      Administer pretreatment program; issue industrial discharge permits
Revise Port Comprehensive Plan (to reflect Urban Waterfront Plan rec-
ommendations)

Develop, adopt, and implement Regional Drainage Design and Erosion
Control Manual (adoption by ordinance)


Ensure funding for implementation of Regional Drainage Design and
Erosion Control Manual, including enforcement and education elements
      Develop nonpoint source control ordinance

      Develop regional geographic information system for basin planning and
      other projects

      Develop Percival Creek Drainage Basin Plan
      Develop interlocal agreement to jointly fund permanent water quantity
      and quality monitoring stations in Indian, Moxlie, and Percival drainage
      basins
                                                                  City of Olympia                             4/91


                                                                  City of Olympia                             TBD


                                                                  City of Olympia                            12/91
                                                                                                            (begin)

                                                                  City of Tumwater                           TBD
                                                                  Lacey, Olympia, Tumwater, and              12/90
                                                                    Thurston County (LOTT)
                                                                  Ecology

                                                                  LOTT                                      TBD
                                                                  LOTT                                      1/92
                                                                         Port of Olympia                             TBD
Thurston County                           4/91
City of Olympia
City of Tumwater

Thurston County                           TBD
City of Olympia
City of Tumwater

Thurston County Health Department           TBD

Thurston County                         Underway
Squaxin Island Tribe

City of Olympia                            12/91
City of Tumwater
Thurston County

City of Olympia                            6/92
City of Tumwater
Thurston County
                                                       City Council adoption


                                                       CCWF grant
                                                       Ecology comments and
                                                       approval of local proposal

                                                       Port Commission adoption
County Commission adoption
City Council adoption
City Council adoption

Separate utility budget pro-
cesses
                                                                                                                         In scoping stage

                                                                                                                         County and tribe systems
                                                                                                                         not compatible

-------
      TABLE 3.  PLANNING AND PROGRAM DEVELOPMENT ACTIONS (Continued)
o>
ro
Action
Propose adoption of stricter standards for aboveground storage tanks
(ASTs)
Document existing problem ASTs
Develop and approve local Comprehensive Habitat Management Plan
Agencies Involved
City of Turn water
City of Olympia
Ecology
Washington Departments of
Genaral Administration*
Target Date8
TBD
6/92
12/91
TBD
Limiting Factors
City Council approval

Approval of Urban Water-
front Plan bv local iurisdic-
      Begin planning process for 1993 Capitol Lake dredging project
Complete study of erosion in Capitol Lake's North Basin; complete
bank stabilization projects

Develop rules, guidelines, and model ordinances for stormwater man-
agement in Puget Sound

Develop best management practices manual for stormwater manage-
ment in Puget Sound

Develop sediment quality standards, dredge disposal criteria, and reme-
dial action criteria

Develop memorandum of agreement between Thurston County Health
Department and the Washington Department of Health to sample shell-
fish and post signs at contaminated recreational shellfish beaches

Implement interim policy for stormwater management guidelines (for
use in hydraulic project approval issuance)

Administer boat sewage pumpout grants
      Develop marine sewage disposal requirements and enforcement stra-
      tegy

      Finalize Puget Sound Water Quality Management Plan

      Develop, adopt, and implement companion stormwater rule in conjunc-
      tion with Ecology adoption of stormwater standards

      Enhance coordination of review of urban bay National Pollutant Dis-
      charge Elimination System permits
  Ecology; Fisheries
City of Olympia
City of Tumwater
Squaxin Island Tribe

Washington Department of General           1991
  Administration

Washington Department of General           12/91
  Administration

Ecology                                   11/91
Ecology                                   11/91


Ecology                                 Completed


Washington Department of Health             TBD
Thurston County Health Department


Washington Department of Fisheries         Ongoing


Washington Parks and Recreation            Ongoing
  Commission

Washington Parks and Recreation           7/91-7/92
  Commission

Puget Sound Water Quality Authority        Completed

Puget Sound Water Quality Authority          11/91


Puget Sound Water Quality Authority         Ongoing
Ecology
U.S. Environmental  Protection Agency
                                                                                                                               tions
                                                                                                                               Legislative budget process
                                                                                                                               Funding for local participa-
                                                                                                                               tion
                                                                                                                         Implementation of Efficiency
                                                                                                                         Commission report

-------
TABLE 3.  PLANNING AND PROGRAM DEVELOPMENT ACTIONS (Continued)
•..•   •  -	   Action	Agencies Involved	Target Date*	Limiting Factors

Adopt stormwater management requirements for cities with popula-      U.S. Environmental Protection Agency        1992
tions less than 100,000

Provide Port of Olympia and City of Olympia with policy interpretation     U.S. Army Corps of Engineers
defining appropriate uses of Clean Water Act Section 404 dredged
sediment fills

* End date for action, except where noted.

-------
TABLE 4. CONTAMINANT CONTROL ACTIONS
Action
Implement Storm and Surface Water Management Program operating
and maintenance procedures; hire inspection and enforcement staff
Replace failing marine sewage pumpout facility at Percival Landing
Implement Indian/Moxlie Drainage Basin Plan Phase 2 (capital improv-
ement plan)
Implement Percival Creek Drainage Basin Plan (capital improvement
plan)
Adopt and implement Regional Drainage Design and Erosion Control
Manual (adopt by ordinance)
Maintain oil/water separators, catch basins, and stormwater systems
Build regional catch basin sediment disposal facility
Require construction and maintenance of retention/detention basins and
oil/water separators for all new permitted construction
Encourage use of constructed biofiltration swales for processing storm-
water runoff in unincorporated areas
Begin implementing best management practices for stormwater man-
agement
Improve sewers, separate stormwater, reconstruct sewers (per Sani-
tary Sewer Comprehensive Plan, Phase 1)
Correct failed septic systems on north Cooper Point
Implement stricter standards for aboveground storage tanks
Agencies Involved
City of Olympia
City of Olympia
City of Olympia
City of Olympia
City of Tumwater
Thurston County
City of Olympia
City of Tumwater
City of Olympia
City of Tumwater
Thurston County
Thurston County
City of Olympia
City of Tumwater
Thurston County
City of Olympia
City of Tumwater
Thurston County
City of Olympia
City of Tumwater
Thurston County
City of Olympia
Thurston County
City of Tumwater
City of Olympia
Target Date8
Ongoing
To be determined
(TBD)
12/91
12/91
8/91
4/91
4/91
Ongoing
1991
Ongoing
Ongoing
1/91
1989-1993
Areawide strategy
by 12/91
TBD
6/92
Limiting Factors




County Commission adoption
City Council adoption
City Council adoption


Adoption of regional drainage
manual; Ecology guidance
12/91
Adoption of regional drainage
manual; Ecology guidance
12/91





-------
    TABLE 4.  CONTAMINANT CONTROL ACTIONS (Continued)
                                   Action
        Agencies Involved
   Target Date"
       Limiting Factors
o>
cn
      Conduct enforcement inspections and permitting activities via water
      quality, dangerous waste and hazardous waste cleanup laws

      Fund purchase of boater sewage pumpout stations
      Implement enforcement program for Marine Sewage Disposal Require-
      ments

      Initiate discussions with Port of Olympia about log storage practices

      Complete log yard stormwater management project (pave yards, con-
      struct retention swales)

      Resurface and regrade port loading dock to eliminate direct runoff to
      inlet

      Complete and submit permit application

      Conduct sampling for permit application

      Remove abandoned underground fuel tanks

      Minimize or remove log rafts over tideflats in West Bay
      Repair or replace marine sewage disposal pumpout at East Bay Marina
      Ensure uninterrupted operation of East Bay Marina aerators during
      critical periods

      Upgrade bulk diesel storage tank at powerhouse on Capitol Lake (install
      oil/water separator within containment)

      Develop Spill Prevention, Control, and Countermeasure Plan
      Remove regulated 1,000-gallon underground storage tank from Capitol
      grounds

      Remove unregulated underground storage tanks from Capitol grounds
Ecology


Washington Parks and Recreation
  Commission

Washington Parks and Recreation
  Commission

U.S. Fish and Wildlife Service

Port of Olympia


Port of Olympia


Port of Olympia

Port of Olympia

Port of Olympia

Port of Olympia
Washington Department of
 Natural Resources

Port of Olympia
Washington Parks and Recreation
  Commission
Port of Olympia
U.S. Army Corps of Engineers

Washington Department of General
  Administration

Washington Department of General
  Administration

Washington Department of General
  Administration

Washington Department of General
  Administration
      TBD
Annually beginning
   spring 1990

      7/92
      TBD

     Ongoing


      6/91


      9/91

 Winter 1991-92

    Complete

      TBD



      TBD
   1991-1993


      TBD


      3/93


      TBD
As funds are available
Jurisdiction depends on own-
ership of tidelands
Repair is complete, replace-
ment depends on funds from
Washington State Parks and
Recreation Commission

-------
     TABLE 4.  CONTAMINANT  CONTROL ACTIONS (Continued)
                                  Action
        Agencies Involved
Target Date8
      Limiting Factors
O)
o>
      Conduct soil sampling at the Washington Department of Transporta-
      tion's storage area on the southwest shore of Capitol Lake

      Inspection of Department of Transportation storage area on the south-
      west shore of Capitol Lake

      Removal of storage area on the southwest shore of Capitol Lake
      Implement Combined Sewer Overflow/Infiltration and Inflow Reduction
      Plan requirements


      Nitrogen Removal Facility completion and other plant improvements
Washington Department of
  Transportation

Ecology
Washington Department of
  Transportation

Lacey, Olympia, Tumwater, and
 Thurston County (LOTT)
Ecology

LOTT
Ecology
    TBD


    6/91


    TBD


  Ongoing



    9/93
Determination of liability for
possible contamination

Meeting between LOTT and
Ecology
Renew expired permit for Pabst/Olympia Brewery
Clarify regulations about chlorinated sewage systems and develop
strategy for homeowner compliance
Renew expired permit for Tamoshan wastewater treatment plant
Renew expired permit for Seashore Villa
Renew expired permit for Beverly Beach
Administer Boston Harbor wastewater treatment plant permit
Review, renew, or terminate expired permit for Olympia Forest Prod-
ucts/WTD
Issue stormwater NPDES permit for Port of Olympia
Implement monitoring requirements at One Tree Island capped aquatic
disposal site near Fiddlehead Marina
Conduct initial investigations targeting industrial facilities
Encourage implementation of best management practices and issue
enforcement actions as source control measures
Ecology
Thurston County Health Department
Ecology
Ecology
Thurston County
Ecology
Ecology
Ecology
Ecology
Ecology
TBD
Ecology
Ecology
TBD
TBD
5/91
5/91
3/91
Ongoing
TBD
TBD
TBD
Ongoing
Ongoing
     8 End date for action, except where noted.

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                                                         TABLE 5.  REMEDIAL INVESTIGATIONS
Action
Characterize sediments beneath historical mothballed naval fleet
Agencies Involved
U.S. Environmental Protection Agency
Target Date"
4/91
Limiting Factors

o>
Monitor One Tree Island capped sediment disposal site


Begin cleanup of Unocal/Hulco site

Conduct expedited seep investigation at McFarland/Cascade Pole site

Identify interim product recovery actions for McFarland/Cascade Pole
site

Design feasibility study and select final cleanup remedy for McFarland/
Cascade Pole site

Conduct Model Toxics Control Act, water quality, and dangerous waste
initial investigations of industrial facilities including, but not limited to :
    Port of Olympia
    Hardel Lumber
    Olympia Forest Products/WTO, Delson
    Reliable Steel
    West  Bay Marina

Conduct sampling to identify and characterize sources of contaminants
to West Bay drain
                                                                         Washington Department of Ecology
                                                                           (Ecology)

                                                                         Ecology
                                                                         Ecology

                                                                         Ecology

                                                                         Ecology


                                                                         Ecology


                                                                         Ecology
Ecology
Port of Olympia
                                      To be determined
                                           (TBD)

                                           TBD

                                           TBD

                                          Ongoing


                                           6/92
                                       Ongoing - fiscal
                                         year 1992
     TBD
Winter 1991-92
                  Low WARM ranking
                  Hydraulic project approval
                  and shoreline permits
      a End date for action, except where noted.

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                                                             TABLE 6.  MONITORING ACTIONS
                                    Action
                                                                                    Agencies Involved
                                                                                                                  Target Date8
                                                                   Limiting Factors
0>
00
 Watershed management plan for nonpoint source contaminant control

   Phase 1 monitoring (Centennial Clean Water Fund (CCWF) grant]

   -  Conduct water and sediment data collection  and analysis

   -  Conduct upper Deschutes channel characterization (data collec-
      tion and development  of mapping system)

 Administer volunteer recreational shellfish  tissue  sampling and followup
 sampling
   -  Target residents in areas of concern


 Conduct stormwater monitoring for fecal coliform bacteria and metals

 Monitor effluent from Lacey, Olympia, Tumwater, and Thurston County
 (LOTT) Wastewater Treatment Program
   -  Monitor receiving waters (5 stations)
   -  Monitor sediments (2 stations)

 Monitor industrial source sewers for conventional contaminants and
 some toxic chemicals

 Sample selected industrial effluent prior to discharge to LOTT

 Develop Indian/Moxlie Drainage Basin Plan
   -  Phase 1 (data collection)

 Develop Percival Creek Drainage Basin Plan
   -  Phase 1 (data collection)

 Develop East Bay and West Bay Drainage Basin Plans

   -  Phase 1 (data collection)

Station permanent water quantity and quality monitoring  stations  in
Indian, Moxlie, and Percival creeks
     Assess the need to develop and implement enhanced sediment and
     water sampling program for Budd Inlet receiving waters
                                                                          Thurston County

                                                                          Thurston County

                                                                          Thurston County
                                                                          Squaxin Island Tribe

                                                                          Thurston County

                                                                          Thurston County


                                                                          Thurston County

                                                                          LOTT
                                                                          LOTT
LOTT

City of Olympia
Thurston County

City of Olympia
City of Tumwater
Thurston County

City of Olympia
City of Olympia
Thurston County
City of Tumwater

LOTT
Ecology
                                                 12/91

                                                 12/91

                                                 9/91


                                                Ongoing


                                            To be determined
                                                 (TBD)

                                                Ongoing

                                                Ongoing
Ongoing


Ongoing

 12/90


 12/91



  TBD


  6/92
                                                                                                                1992 (upon permit
                                                                                                                    revision)
                                                                                                                                            CCWF grant
     Conduct stormwater sampling off Port of Olympia peninsula
                                                                    Port of Olympia
                                                 11/91

-------
     TABLE 6.  MONITORING ACTIONS (Continued)
                                    Action
                                                                             Agencies Involved
                                             Target Date*
                       Limiting Factors
O>
CD
       Implement Puget Sound Ambient Monitoring Program (2 annual and 2
       triannual sediment sampling stations; 2 annual fish tissue sampling sta-
       tions)

       Complete study of erosion in Capitol Lake's North Basin
       Develop Memorandum of Agreement for sampling and posting recrea-
       tional shellfish beaches
Implement monitoring requirements for One Tree Island capped aquatic
disposal site near Fiddlehead Marina

Conduct nutrient loading/abatement study of Budd Inlet

Provide dissolved oxygen monitoring equipment to Port of Olympia

Correct dysfunctional East Bay dissolved oxygen monitors; determine
efficiency of portable probes

Conduct dissolved oxygen monitoring in East Bay


Conduct further sediment sampling prior to dredging navigation channel

Monitor  McFarland/Cascade Pole site
   -  Sediment sampling
   -  Groundwater sampling
   -  Soil sampling

Survey streamwalks/habitat and fish populations in Indian/Moxlie, Perci-
val, Ellis, and Mission creeks and unnamed stream
       Conduct biological sampling (habitat inventory) in West Bay to deter-
       mine mitigation for potential dredging/widening of Olympia Harbor turn-
       ing basin and navigation channel

         -  Benthic infauna
         -  Epifauna
         -  Macroinvertebrates
         -  Demersal fish
Washington Department of Fisheries
Ecology
Puget Sound Water Quality Authority

Washington Department of General
  Administration

Washington Department of Health
  (DOH)
Thurston County

TBD
                                                                          TBD

                                                                          U.S. Army Corps of Engineers

                                                                          U.S. Army Corps of Engineers
                                                                          Port of Olympia

                                                                          Port of Olympia


                                                                          U.S. Army Corps of Engineers

                                                                          Ecology
                                                                          Squaxin Island Tribe
                                                                          City of Olympia
                                                                   U.S. Army Corps of Engineers
    Ongoing



      1/91


 Summer 199O
 (not completed)


      TBD


      TBD

 Summer 1991

 Summer 1991


    Ongoing
(summer months)

      TBD

      6/91
                                            First year done
                                                5/90
                                                                                                                                    Funding for local
                                                                                                                                    participation
                                                                 Funding
                      Ongoing to the
                      extent possible
                      with limited fund-
                      ing

                      Funding to finalize
                      report

-------
TABLE 6.  MONITORING ACTIONS (Continued)
                               Action
          Agencies Involved
      Target Date"
Limiting Factors
  Identify existing data and/or need for recent data documenting impacts
  of lografting over tidelands
  Develop ranked list of sediment sites requiring further investigation and
  possible cleanup, including sites in Budd Inlet

  Sample water and shellfish for fecal coliform bacteria at Burfoot County
  Park
  Conduct tissue sampling of shellfish from Priest Point Park under the
  direction of the Puget Sound Ambient Monitoring  Program

  Document sandlance spawning habitat for use in  developing adequate
  construction requirements

  Incorporate necessary changes to hydraulic permit approval standards

  Document nutrient loading/impacts to percival Cove from salmon rearing
  pens
 Prioritize inspections and conduct initial investigations, including sam-
 pling of water, sediment, and soils at industrial facilities

 Complete South Sound Reconnaissance Survey (triad sediment sam-
 pling)
Washington Departments of
 Natural Resources; Fisheries
U.S. Fish & Wildlife Service
Port of Olympia

Washington Department of
 Natural Resources

DOH
DON
Washington Department of Fisheries
Washington Department of Fisheries

Ecology
Washington Department of General
  Administration

Ecology
U.S. Environmental Protection Agency
          TBD
         6/91
 Complete 15 samples to
classify recreational shell-
 fish beds, then annually

    Annually (spring)
        Ongoing


          TBD

          TBD



      1/9O- 6/92


        Complete
8 End date for action, except where noted.

-------
                                             TABLE 7.  RESOURCE PROTECTION ACTIONS
                              Action
          Agencies Involved
  Target Date*
Limiting Factors
Conduct State Environmental Policy Act reviews
Manage and protect shellfish in Budd Inlet

Classify recreational shellfish beds in Budd Inlet
Issue hydraulic project approvals
Protect habitat and maintain salmon enhancement facilities

Construct and operate fishways
Review Section 1O/4O4 permits
Issue Section 10/404 permits
Issue shoreline permits, review building and rezoning permits for devel-
opment projects
All agencies
Washington Departments of Health;
  Ecology; Natural Resources
Thurston County
Washington Department of Health
Washington Department of Fisheries
Washington Department of Fisheries
U.S. Fish & Wildlife Service
Squaxin Island Tribe
Washington Department of Fisheries
U.S. Environmental Protection Agency
U.S. Fish & Wildlife Service
Washington Departments of Fisheries;
  Ecology; Game
U.S. Army Corps of Engineers
Thurston County
City of Olympia
City of Tumwater
Washington Department of Ecology
    Ongoing
    Ongoing

To be determined
    Ongoing
    Ongoing

    Ongoing
    Ongoing
    Ongoing
    Ongoing
' End date for action, except where noted.

-------
                                                            TABLE 8.  EDUCATIONAL ACTIONS
                                    Action
                                                                              Agencies Involved
                                          Target Date8
                        Limiting Factors
ro
      Organize and provide ordinances, policies, educational information, best
      management practices (best management practices), and building code
      information

      Televise environmental educations programs focused on Budd Inlet/Des-
      chutes River basin
Post shellfish harvest advisory signs


Post signs provided by Parks and Recreation Commission at Percival
Landing marine sewage pumpout

Hire staff to provide technical assistance/best management practices to
ensure erosion and sedimentation requirements are met at construction
sites

Implement Stream Team Program

Develop information flyers on stormwater policies, best management
practices, stormwater facility design standards, water quality education-
al programs

Develop storm drain stencilling program for use by groups within the
city

Televise discussion by Olympia City Council of key environmental issues
in Budd/Deschutes basin
      Develop storm drain stencilling program for use by groups within the
      city

      Provide best management practices/technical assistance to ensure prop-
      er operations and maintenance of public and private stormwater sys-
      tems

      Sewage treatment plant tours provided to interested public

        -  Continue to provide information to local schools, colleges,  and
           interested citizens
        -  Increase public education on plant operation and upgrades
Thurston County
City of Olympia


Thurston County
Washington Department of Ecology
  (Ecology)

Thurston County
Washington Department of Health

City of Olympia
                                                                          City of Olympia



                                                                          City of Olympia

                                                                          City of Olympia



                                                                          City of Olympia
City of Olympia
City Energy and Utilities
  Commission
Ecology

City of Tumwater
                                                                    Thurston County
                                                                    City of Tumwater
                                                                    City of Olympia

                                                                    Lacey, Olympia, Tumwater, and
                                                                     Thurston County Wastewater
                                                                     Treatment Plant
                                                                                                                Ongoing
To be determined
     (TBD)


      TBD


      TBD


      9/91
    Ongoing

    Ongoing



    Ongoing


      8/91




      1/91


    Ongoing



    Ongoing
                                                                                                                                       Under Memorandum of
                                                                                                                                       Agreement

-------
TABLE 8.  EDUCATIONAL ACTIONS (Continued)
                               Action
         Agencies Involved
   Target Date8
Limiting Factors
  Post interpretive signs provided by Parks and Recreation at East Bay
  Marina marine sewage pumpout

  Post signs near aerator switch boxes at East Bay Marina to discourage
  boaters from turning them off

  Support of Port/Cascade Pole Citizen Advisory Committee public edu-
  cation activities

  Distribute boating survey summary flyers
  Continue providing spill prevention and response educational programs
  Provide educational signs to marinas with pumpout stations


  Present boater education programs


  Develop educational materials on shellfish contamination


  Distribute grants to local agencies for public involvement and education
  projects

  Distribute Aquatic Land Enhancement Account grants to local agencies
  for public education and interpretive projects

  Hold workshops to  inform agencies of available monies to provide public
  access to shorelines
Port of Olympia


Port of Olympia


Port of Olympia
Port of Olympia
Washington Parks and Recreation
  Commission

Port of Olympia
Ecology
Olympia Fire Department

Washington Parks and Recreation
  Commission

Washington Parks and Recreation
  Commission

Washington Department of Health
Puget Sound Water Quality
 Authority

Washington Department of Natural
  Resources

Washington Department of Natural
  Resources
  Distribute grants for public involvement under Model Toxics Control Act   Ecology
  Review activities and educate citizens on McFarland/Cascade Pole
  cleanup operations

  Carry out Business Education Project under Centennial Clean Water
  Fund grant
Budd Inlet Action Plan Citizens
  Advisory Committee

City of Olympia
       TBD
       TBD
 Ongoing through
     cleanup

   TBD; ongoing
     Ongoing
(continued schedule
 to be determined)

     Ongoing
     Ongoing


       199O
  (as requested)

  1990; ongoing


     Ongoing


     Ongoing


     Ongoing

   3/91 (begin)


   4/91 (begin)
8 End date for action, except where noted.

-------
1991 Action Plan for Budd Inlet
                                                          74

-------
Data, Planning, and Contaminant Control  Needs
                         The Site-Specific Action Plan tables present a summary of many
                         ongoing and needed activities to improve water quality in Budd
                         Inlet.  Several data, planning, and contaminant control needs either
                         are not addressed in the action plan or are found in the action plan
                         but have no committed agency or timeframe for completion. This
                         section of the action plan summarizes these additional water quality
                         needs for Budd  Inlet.  This section will provide a beginning
                         framework for Interagency Work Group discussions and individual
                         agency actions for addressing unmet needs for data, planning and
                         coordination, and control of contaminant inputs to Budd Inlet.
                         Planning/Coordination Needs

                         A long-term monitoring program for water and sediment quality in
                         Budd Inlet is needed to gauge the success of water quality improve-
                         ment programs (Budd Inlet Action Program,  Budd/Deschutes
                         Watershed Planning, City of Olympia Basin Planning).  It may be
                         possible to modify or coordinate the existing monitoring programs
                         (e.g., LOTT permit monitoring and Ecology's Ambient Monitoring
                         Program) to provide information on water  quality conditions.
                         Future  monitoring  programs developed through the Budd/
                         Deschutes Watershed Planning  process or the Olympia Basin Plan-
                         ning process could be the basis of an integrated long-term monitor-
                         ing program for Budd Inlet.

                         Federal,  state,  and local agencies  need to coordinate habitat
                         enhancement activities in the inlet.  Habitat in the inlet has been
                         degraded through water quality impacts, dredge and fill projects,
                         and development of waterfront areas. Nevertheless, the nearshore
                         shallow waters of the western shore of lower West Bay provide
                         critical habitat for migrating juvenile salmon, and the port-owned
                         wildlife lagoon  provides valuable habitat for waterfowl.  In the
                         Draft Urban Waterfront Plan, the joint city/port Urban Waterfront
                         Task Force recommends that the City of Olympia adopt a Com-
                         prehensive Habitat Plan that would provide guidelines for local
                         actions to restore Budd Inlet fish and wildlife habitat.  The draft
                         Urban Waterfront Plan will be considered by the Olympia City
                         Council and the Port of Olympia Commissioners during  summer
                         1991. If the plan is adopted  with the Comprehensive Habitat Plan
                                                     75

-------
Data, Planning, and Contaminant Control Needs
                          element intact, resources will need to be allocated to carry out the
                          program.  The Comprehensive Habitat Plan element can also stand
                          alone and should be pursued even if other aspects of the Urban
                          Waterfront Plan are delayed.

                          The Squaxin Tribe and Thurston County should develop a way to
                          share information between their GISs. Both the county and the tribe
                          are currently using GISs to manage Budd/Deschutes watershed
                          information, but the two systems are not compatible.  If information
                          could be easily shared between the tribe and county, the information
                          that is now on the separate systems could be overlaid and compared.

                          A system for interjurisdictional data management is needed.  Thur-
                          ston County, City of Olympia, Port of Olympia, LOTT, DOH,
                          Ecology, and Department of Fisheries all conduct some monitoring
                          activities within the Budd Inlet watershed.  A centralized, coordi-
                          nated data management system of information from  the various
                          agencies would provide an overview of Budd  Inlet water quality
                          conditions.   While some  of the entities already  collaborate on
                          monitoring projects, an interjurisdictional system would provide
                          more opportunities for coordination of monitoring projects and
                          could provide a more complete strategy for evaluating water quality
                          throughout the Budd Inlet watershed.

                          Local and state agencies should coordinate enforcement activities
                          regarding water quality and hazardous substances.  Water quality
                          in Budd Inlet can be affected by sources originating in Olympia,
                          Tumwater, or Thurston County.  While each jurisdiction has its
                          own ordinances and policies for dealing with water quality prob-
                          lems, coordination is important because upstream activities can
                          affect water quality in downstream jurisdictions.  Coordination of
                          local enforcement activities with the state (i.e.,  by Ecology) could
                          provide additional support in local water quality efforts.

                          Planning for  the future development of the urban waterfront should
                          include enhancement of water quality and aquatic habitat as key
                          elements.   The lower Budd Inlet area currently has a  mix of land
                          and water uses, including industry, shipping, marinas, recreation,
                          and residences. As the City of Olympia continues to grow and as
                          port activities change in response to changing economic conditions,
                          land uses along the urban shoreline will inevitably change.  There
                          is a recognized need for the city and port to develop a common
                          vision for the future of the community's waterfront.  The Urban
                          Waterfront Plan partially  addresses this need  through its goal of
                                                       76

-------
                   Data, Planning, and Contaminant Control
governing over-the-water uses.  Future plans for the overall de
opment of the waterfront should provide for protection and enhance^
ment of water quality and aquatic habitat.

The Thurston County Health Department and DOH should develop
an  MOA to identify  the responsibilities of each  agency in
implementing the requirements of the Recreational Shellfish Rule
(Chapter 248-52 WAC).  The rule states that a "joint plan of
operation" between the two entities should be developed to outline
how recreational shellfish beaches  will be managed.  However,
Thurston County has limited funds to take on additional responsi-
bilities such as public notification or increased sampling activities.
This issue should be resolved and the requirements of the recreation-
al shellfish rule should be carried out.
Data Needs

Information about the geographic extent and seasonal variability of
low  levels of dissolved oxygen is  needed.   Dissolved  oxygen
conditions should be monitored throughout the water column and
at the sediment interface to gain a full understanding of the nature
of the problem.   Also, monitoring  of the geographic extent of
nutrients and dissolved oxygen depletion should be increased to
determine how much of the southern portion of the inlet is affected
by eutrophication.

Data is needed on nutrient inputs to Capitol Lake and Budd Inlet
from sources throughout the basin.  Comparative information on
nutrient contributions would help to target state and local staff
resources  to priority areas and sources.  The Thurston  County
Health Department is making some  progress in this area  through
their Budd/Deschutes watershed characterization project.

Information about water quality impacts of salmon rearing pens in
Percival Cove is needed.  This facility is located in the small cove
adjacent to Capitol Lake and  may be contributing significant
amounts of nutrients and biochemical oxygen demand to the lake.

Better information about the water  quality impacts and sediment
contribution to Budd Inlet from the Deschutes River and Capitol
Lake is needed.  Capitol Lake often experiences algal blooms and
decreased levels of dissolved oxygen during the summer  months;
                             77

-------
ata, Planning, and Contaminant Control Needs
                         high fecal coliform bacteria levels have also been recorded.  The
                         oxygen-depleted waters and fecal coliform bacteria can enter Budd
                         Inlet and negatively impact marine water quality.

                         The environmental condition and relevance of the area known as
                         the "mothballed fleet site"  should be further investigated and
                         evaluated.  This site is located near Gull Harbor and was used for
                         storage of over 100 military vessels between the end of World War
                         II and the early 1960s. Solvents, waste oils, and unknown objects
                         were reportedly dumped into the  inlet from the ships (Tetra Tech
                         1988).  High concentrations of copper, lead, and zinc were detected
                         in sediments in this vicinity (PTI1991).

                         The Budd Inlet Initial Data Summaries and Problem Identification
                         report (Tetra Tech 1988) identified several areas of elevated fecal
                         coliform bacteria along the Budd Inlet shoreline.  The Thurston
                         County basin characterization monitoring efforts have also found
                         high bacterial counts in these areas. Monitoring stations should be
                         established  to track  fecal coliform levels in the  outer inlet,
                         particularly in the vicinity of the Tamoshan, Beverly Beach, and
                         Seashore Villa wastewater treatment plants; Athens Beach; French
                         Loop Road; north of Priest Point Park; and Tykle Cove.

                         Bioassay tests are needed for sediments in East and West bays, north
                         of the Port of Olympia peninsula,  near Priest Point, and near Gull
                         Harbor. The sediments near the Cascade Pole Company are known
                         to be highly contaminated with organic chemicals, but no toxicity
                         data are available on these  sediments. Similarly, no toxicity data
                         are available for sediments near NPDES-permitted discharges,
                         CSOs, and storm drains. Bioassay tests of sediments collected near
                         known  and suspected  contaminant sources would provide important
                         information about the magnitude  of environmental degradation at
                         those locations.

                         There are no acceptable data concerning benthic infaunal communi-
                         ties  in  Budd Inlet. An understanding of the composition of the
                         benthic community in Budd Inlet would help determine the effects
                         of sediment contaminants and the effects of low dissolved oxygen
                         on the resident biota.  A survey north  of the Port of Olympia would
                         be sufficient to identify the extent of benthic  degradation to the
                         north.

                         A study is  needed to determine the effects of log-rafting on habitat
                         and water quality in Budd Inlet. Storage of logs in floating rafts is
                         common along the west shore of Budd Inlet. The same nearshore
                         shallow water area where  the logs are rafted is very important to
                                                      78

-------
                   Data, Planning, and Contaminant Control Needs
migrating juvenile salmon.  The log rafts are likely to negatively
impact habitat by shading and disturbing the substrate during low
tides. Water quality can be affected by oxygen depletion caused by
decaying bark.  In addition, bark that drops to the bottom may
impact fauna  living in sediments by smothering organisms or
degrading habitat. The full extent of this problem in Budd Inlet is
not known.
Contaminant Control  Needs

An inventory of industrial and commercial businesses in the study
area is needed.  The inventory should identify locations of busi-
nesses with the potential to contribute pollutants directly or indi-
rectly to the inlet. This inventory would be used for planning state
and local strategies for business inspections and source control
activities.  A  coordinated strategy should be developed between
local and state jurisdictions to reduce pollution loading to the inlet
from these businesses. Enlisting local industries in a voluntary
environmental audit and pollution reduction program could be a
very effective way to achieve source control, in combination with
general education and enforcement of water quality laws.

Enforcement and control of contaminants from chlorinated sewage
systems is needed. There are numerous privately owned chlorinated
sewage systems in Budd Inlet.  These systems consist of a septic
tank and a  system for dousing the effluent with chlorine before the
effluent is  directly discharged  into Budd Inlet.  In many cases,
chlorinator systems do not work and result in discharge of raw or
minimally treated sewage.

Tracing of sources of pollution from Budd Inlet tributaries and storm
drains should be conducted. While Thurston County and the City
of Olympia are conducting intensive monitoring on several streams
to identify pollution sources, source tracing work is needed for
storm drains, CSOs, and other tributary streams. Thurston County
will take sediment samples from several storm drain outfalls during
the summer of 1991 as a starting point for pollution source tracing.
An understanding of the storm water drainage systems throughout
the urban area is needed to  trace pollutants to their sources. The
City of Olympia has already completed drainage system maps for
some areas and is working on others.  Locations  of businesses
identified in the inventory  would be correlated with the drainage
maps and water quality information to identify problem areas.
                             79

-------
Data, Planning, and Contaminant Control Needs
                           Characterization of the runoff and drainage systems of industries
                           along West Bay Drive is needed to determine sources and routes of
                           pollution from those businesses to the inlet.

                           By the fall of 1991, Thurston County and the cities of Olympia and
                           Tumwater will  adopt the Regional Drainage Design and Erosion
                           Control Manual to govern storm water and erosion management for
                           new construction. A system of enforcement of these regulations
                           should be developed in each jurisdiction, including  regular inspec-
                           tion and maintenance of publicly and privately owned oil/water
                           separators and retention/detention basins. The City of Olympia has
                           recently added a staff person who will, in part, enforce storm water
                           regulations.

                           The Unocal/Hulco site in downtown Olympia has been identified
                           as a contaminated site in need of cleanup. An initial investigation
                           was completed and the  site was ranked in relationship to other
                           contaminated sites throughout the state.  The site did not rank with
                           the highest priority sites for Ecology-directed cleanup activities,
                           although the site owner may initiate cleanup activities indepen-
                           dently.   The full extent  of contamination at this site needs to be
                           determined, and cleanup activities  should begin. Other potential
                           contaminated sites need to be investigated and ranked.  These sites
                           include petroleum-contaminated  soils at  the south end of East Bay
                           and in the vicinity of Percival Landing, a historical landfill at the
                           LOTT plant, and the old Delson Lumber/Olympia Forest Products
                           site on the West Bay shoreline.

                           A statewide enforcement strategy is needed to ensure proper dis-
                           posal of marine sewage.  The Washington Parks and Recreation
                           Commission and DOH have agreed that this is an important need,
                           but funding is not currently available.

                           Contaminated sediment sites in Budd Inlet should be identified and
                           prioritized for cleanup.   Based on the sediment management stan-
                           dards (Chapter  173-204 WAC), the process for cleaning up con-
                           taminated sediment sites includes the following steps: screening
                           sediment station clusters of potential concern; conducting hazard
                           assessments to  identify  cleanup sites; ranking sites for cleanup;
                           determining appropriate site cleanup authority; conducting a site
                           cleanup study; and selecting a site  cleanup action.  Ecology will
                           begin this process but may not focus on Budd Inlet. Also, additional
                           characterization data for sediments within Budd Inlet are needed.
                                                        80

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Glossary of Terms
      Amphipod
      Apparent effects threshold
      Benthic
      Benthic community
      Best management practice
      Bioaccumulation
      Bioassay
      Biochemical oxygen demand
       Combined sewer overflow
       C ontaminant
Small shrimp-like crustaceans, such as sand fleas, that
are often benthic dwellers and feed  on algae and
detritus.

Chemical-specific sediment concentrations above
which a particular adverse biological effect is always
found to be statistically significant (P<0.05) for a
given data set.

Pertaining to the bottom of a water body.

A group of interacting species populations found within
the benthic zone.

A method, activity, maintenance procedure,  or other
management practice to reduce the amount of contam-
inants entering a water body.

The accumulation of a substance in tissues of an
organism. Bioaccumulation of toxic substances may
lead to disease or other health problems and may render
organisms unfit for human consumption.

A laboratory or field test used to evaluate the toxicity
of a material (commonly sediments or water) by measur-
ing behavioral, physiological, or population response of
organisms.

A measure of the amount of oxygen consumed in the
biological processes that break down organic matter in
water.

A discharge of raw  sewage and stormwater, which
occurs when the hydraulic capacity of a combined
sewer line is exceeded.

A substance that is not naturally present in the environ-
ment or is present in amounts that can, in sufficient
concentration, adversely affect the environment.
                                         81

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Glossary of Terms
       Crustacean
       Diversity
       Effluent
       Elevation above reference
       Erosion
       Gastropod
       Geographic information
       system
       Groundwater

       Habitat


       Hazardous waste
       Histopathology
A group of primarily aquatic invertebrate animals
(phyllum Arthropoda, class Crustacea) with a hard
exterior skeleton, segmented body, and paired jointed
limbs, including crabs, lobsters, and amphipods.

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

The liquid that flows out of a facility (e.g., treated
wastewater).

An index of toxic contamination or biological effects
that is equal to the measured value of a variable (e.g.,
chemical concentration) at a study site divided by the
measured value of the same variable at a relatively
clean reference area.  For measuring impacts on ben-
thic organisms, this index is inverted so that a depres-
sion below reference is measured.

Wearing away of rock or soil by the gradual detach-
ment of soil or rock fragments by water, wind, ice, and
other mechanical and chemical forces.

A group of invertebrate animals (phyllum Mollusca,
class Gastropoda) with a shell, including snails, lim-
pets, and abalone.

A computerized database  system used to integrate
geographic or natural resource information and pro-
duce maps.

Water found in permeable rock layers underground.

The specific area or environment in which a particular
animal or plant lives.

Any solid,  liquid, or gaseous substance which, because
of its source or characteristics, is classified under state
or federal law as hazardous and is subject to special
handling,  shipping,  storage, and disposal require-
ments.

Study of tissue lesions.
                                          82

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                                                                Glossary of Terms
Hydrocarbon


Infauna

Influent


Invertebrates

Larvae
Lesion
Loading
National Pollutant Discharge
Elimination System

Nonpoint source contaminants
Nutrients
Organic compound


Pelecypod



Point source contaminants


Polychaete
An organic compound composed of hydrogen and
carbon (e.g., petroleum compounds).

Animals living within the bottom sediments.

The liquid that flows into a facility (e.g., sewage into
a wastewater treatment plant).

Animals without backbones.

(Singular:  larva)-A juvenile stage of fish or inverte-
brates with a body form that differs greatly from the
adult stage (e.g., an oyster larva is a small, free-floating
organism).

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

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

A part of the federal Clean Water Act which requires
point source dischargers to obtain discharge permits.

Contaminants that enter water from dispersed and often
uncontrolled sources (such as  stormwater runoff)
rather than through pipes.

Essential chemicals needed by plants  and animals for
growth. Excessive nutrients may lead  to water quality
problems by promoting excessive growth and subse-
quent decay of plants such as algae.

Chemical compounds that contain carbon (e.g., petro-
leum hydrocarbon).

Also known as bivalves, pelecypods are molluscs that
have  two  shells, are  generally filter feeders, and
include  clams, oysters, and mussels.

Contaminants from a single source such as a pipe (e.g.,
discharge from a sewage treatment plant or factory).

A large group of segmented worms found in the marine
environment (e.g., feather dusters).
                                    83

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Glossary of Terms
      Polychlorinated biphenyls
      Polycyclic aromatic
      hydrocarbons
       Sediment
       Toxic
       Toxic contamination
A group of manufactured chemicals including 209
different but closely related chlorinated hydrocarbons.
These compounds are toxic, persistent in the environ-
ment, and are probable human carcinogens.

A class of complex organic compounds, formed by the
combustion of organic material, that are persistent and
widespread in the environment and are known to cause
cancer.  Low molecular weight polycyclic aromatic
hydrocarbons have up to three carbon rings.  High
molecular weight polycyclic aromatic hydrocarbons
have greater than three carbon rings and are more
carcinogenic than the lower weight polycyclic aromatic
hydrocarbons.

Material that settles to the bottom of a water body or
collects on the bottom of pipes such as sewers and storm
drains.

Poisonous,  cancer-causing, or  otherwise directly
harmful to life.

Presence of toxic substances, often caused by release
of metals or synthetic organic  chemicals to the envi-
ronment.
       Washington Ranking Method   A process used by the Washington Department of
                                     Ecology to rank hazardous waste sites and prioritize
                                     these sites for cleanup activities.
       Watershed
The geographic region within which water drains into
a particular river, lake, or body of water.
                                         84

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References
                         Chapman, P.M,, R.N. Dexter, R.M. Kocan, and E.R. Long. 1985.
                         An overview of biological effects testing in Puget Sound, Washing-
                         ton: methods, results, and implications, pp. 344-362. In: Aquatic
                         Toxicology, Proceedings of the Seventh Annual Symposium. Spec.
                         Tech. Rpt. 854, American Society for Testing and Materials,
                         Philadelphia, PA.

                         City of Olympia & Port of Olympia. 1990. Urban waterfront plan.
                         Draft Report.  City of Olympia and the Port of Olympia USA,
                         Olympia, WA.

                         Entrance.  1990. Report to Washington Department of Ecology on
                         results of sediment analysis, Budd Inlet. Entrance Engineers, Lie.,
                         Kirkland, WA.

                         PTL  1990. The urban bay action program approach:  a focused
                         toxics control strategy.  Prepared for U.S. Environmental Protec-
                         tion Agency Region 10, Office of Puget Sound. PTI Environmental
                         Services, Bellevue, WA.

                         PIT.  1991. Reconnaissance survey of chemical contamination and
                         biological effects in southern Puget Sound.  Prepared for U.S.
                         Environmental Protection  Agency Region 10, Office of Puget
                         Sound. PTI Environmental Services, Bellevue, WA.

                         PTI and Tetra Tech. 1988a. Elliott Bay action program: analysis
                         of toxic problem areas.  Final Report.   Prepared  for the U.S.
                         Environmental Protection  Agency Region 10, Office of Puget
                         Sound. PTI Environmental Services, Bellevue, WA.

                         PTI and Tetra Tech.   1988b.  Everett Harbor action program:
                         analysis of toxic problem areas.  Final Report. Prepared for the
                         U.S. Environmental Protection Agency Region 10, Office of Puget
                         Sound. Tetra Tech, Inc., Bellevue, WA.

                         Tetra Tech. 1988. Budd Inlet action plan: initial data summaries
                         and problem identification.  Prepared for the U.S. Environmental
                         Protection Agency Region 10, Office of Puget Sound. Tetra Tech,
                         Inc., Bellevue, WA.
                                                     85

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References
                          Tetra Tech.  1990.  Puget Sound Ambient Monitoring Program
                          1989:   marine sediment monitoring.   Prepared for Washington
                          Department of Ecology, Ambient Monitoring Section. Tetra Tech,
                          Inc., Bellevue, WA.

                          Thurston County.  1991.  Moderate risk waste plan for Thurston
                          County.  Thurston County Planning Department and  Thurston
                          County Health Department, Olympia, WA.

                          Thurston Regional Planning Council.  1988.  Capitol Lake Resto-
                          ration  Committee  report  and proposed action plan.   Thurston
                          Regional Planning Council, Olympia, WA.
                                                     86

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         APPENDIX A

Administrative Record of Agency
    Letters of Commitment

-------
Appendix A
Table of Contents
      Letter to U.S. Army Corps of Engineers                                    A-l
      U.S. Army Corps of Engineers response                                    A-3
      Letter to U.S. Fish and Wildlife Service                                    A-5
      U.S. Fish and Wildlife Service response                                    A-7
      Letter to Squaxin Island Tribe                                            A-9
      Squaxin Island Tribe response                                           A-13
      Letter to Washington Department of Fisheries                               A-15
      Washington Department of Fisheries response                               A-17
      Letter to Washington Department of General Administration                   A-19
      Washington Department of General Administration response                   A-21
      Letter to Washington Department of Health                                 A-23
      Washington Department of Health response                                 A-25
      Letter to Washington State Parks and Recreation Commission                  A-27
      Washington State Parks and Recreation Commission response                  A-29
      Letter to Puget Sound Water Quality Authority                              A-33
      Puget Sound Water Quality Authority response                              A-37
      Letter to Washington Department of Natural Resources                       A-39
      Washington Department of Natural Resources response                       A-43
      Letter to City of Olympia Public Works Department                          A-47
      City of Olympia Public Works Department response                          A-51
      Letter to Thurston County Environmental Health Division                     A-55
      Thurston County Office of Water Quality and Resource
      Management response                                                   A-59
      Letter to Port of Olympia                                               A-71
      Port of Olympia response                                               A-75
      Letter to City of Tumwater                                              A-81
                                      A-ii

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City of Tumwater response                                              A-85

Letter to Lacey, Olympia, Tumwater, and Thurston County
Wastewater Management Program                                        A-89

Lacey, Olympia, Tumwater, and Thurston County Wastewater
Management Program response                                           A-93
                                 MI

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IHRI
ET1N!:0 CRECOIRE
  Direaor
                                      STATE OF WASHINGTON

                                DEPARTMENT OF ECOLOGY
                 "272 Cleanwater Lane. LU-11 •  Olympia. Washington 98504-6811  •  (206) 753-2353
                                        June 6,  1990
          Linda Cox
          Army Corps of Engineers
          P.O. Box C-3755
          Seattle, WA  98121

          Dear Linda,

          Thank you for meeting with Michael Rylko of EPA and me in March.    In
          the meeting we discussed actions that might be taken to complement
          existing programs and projects affecting Budd Inlet.  As a followup to
          the meeting, I have summarized below several of those potential
          activities which we hope become part of the draft Budd Inlet Action
          Plan.  Please respond to the following meeting summary and questions,
          including (where applicable) target dates,  potential funding sources,
          resource constraints and/or other comments  on feasibility.  Please also
          clarify any inaccuracies found below.

          East Bav Marina  Dissolved Oxygen Monitors and Aerators

          The installation, operation and maintenance of dissolved oxygen (DO)
          continuous monitors and aerators remain a condition of the East Bay
          Marina project.  The Corps is aware the system does not operate
          sufficiently to  ensure DO levels meet water quality standards.   Through
          the critical summer months, the Corps has allowed the Port to conduct
          manual titrations in lieu of continuous monitoring.  The manual sampling
          is not scheduled, but rather is conducted on a sporadic basis.   This
          summer the Corps will provide the Port of Olympia with a portable DO
          ;rcbc vith vhieh *:« rcr.r'v.c*: ». mor*» in-depth analysis of how well the
          current aeration system works.  Will the Corps provide a schedule
          detailing frequency, locations, depths, etc. for the monitoring?  If the
          study showa aerators are not sufficient to compensate for decreased
          flushing and low DO levels resulting from alteration of the estuary,
          what contingency actions has the Corps planned to mitigate this?

          Dredging and Filling Project3

          A related concern is that of Clean Water Act Section 404 fills  in East
          Bay.  Accordingly,  fill material on the southeast portion of the Port
          peninsula was only  to be developed for water dependent uses.  Several
          proposed developments indicate the fill may be used for non-water
          dependent uses.  Will the Corps allow such nonconforming uses?
                                            A-1

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Linda Cox
June 6,  1990
Page 2
The Corps is evaluating the need for improvements to the Olympia Harbor
turning basin and navigation channel.  The cost-benefit portion of this
evaluation was recently completed and recommended against funding to
widen the Olympia Harbor turning basin.  Though the turning basin
project is no longer under consideration, the Corps continues in their
negotiations with state and federal natural resource agencies to
determine biological studies and mitigation projects needed prior to
widening the navigation channel.  Pleaaa summarize which biological
studies are likely to take place and when.

Thank you again for taking time out of your busy schedules to meet with
us and to respond to this letter.  Similar letters are being sent to
other Budd Inlet Workgroup members.  These letters and their responses
will be assembled and mailed as a packet to all workgroup and citizen
advisory committee members.  The packet will also be included as an
appendix to the final Budd Inlet Action Plan.

Please submit your written response by June 22, 1990.  Also, please feel
free to call me with any questions and/or if you wish to discuss any
part of this letter (586-5554).


                                   Sincerely,
                                   Melany Vora
                                   Budd Inlet Action
                                    Plan Coordinator
cc:  Frank Urabeck, Array Corps of
                    Engineers
     Fred Weiman, U.S. Environmental
                    Protection Agency
     Gwill Ging, U.S. Fish £ Wildlife
                    Service
                                       A-2

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                        DEPARTMENT OF THE ARMY
                      SEATTLE DISTRICT.  CORPS OF ENGINEERS
                                 P.O. BOX C-3755
                          SEATTLE, WASHINGTON 981Z4-2255
       ATTENTION OF
  arming Branch
                                                              A!!p - 8
Ms. Melany Vorass
Department of Ecology
7272 Cleanwater Lane, LU-11
Olympia, Washington  98504-6811

Dear Melany:

    I am writing In response to your letter dated June 6, 1990 regarding East
Bay water quality (WQ) and nonwater dependent uses and a summary of the
biological studies that are likely to take place In the Olympia Harbor
Navigation Improvement project.

    East Bay Marina Dissolved Oxygen Monitors and Aerators.  Operation and
maintenance of the aeration system and WQ monitoring is a mitigation feature
of the East Bay Marina project.  The Port staff has diligently maintained the
aeration system to ensure that it is operable prior to and during the seasonal
period (generally August-September) of low dissolved oxygen (DO).

    Operation of the originally Installed continuous WQ monitoring equipment
for DO has proven to be infeasible.  The Port repeatedly calibrated and
modified the automatic monitoring equipment per the manufacturer's service
representative recommendations; however, the equipment has failed to provide
reliable readings.  Other continuous monitoring systems have been considered
but found to have similar problems of high maintenance and poor reliability.
Therefore, the Port staff performs manual titrations to obtain accurate
measurements.  Manual sampling at selective depths is in fact preferred for
determining when to operate the aeration system as more information is
provided than with the fixed depth samples obtained with the continuous
monitoring device.  To supplement manual sampling this summer, the U.S. Army
Corps of Engineers is loaning the Port a portable WQ instrument.  Early July
monitoring indicates DO levels well above the State minimum standard, which is
typical of past early July observations.  The weekly July frequency of
observations increases to daily observations as observed DO gets close to or
below the State standard during August and early September.  Monitoring is
conducted during early morning hours when aeration is required until
monitoring data indicates WQ has recovered to allow aerators to be turned
off.  Your office will be provided with a copy of our WQ monitoring data
gathered this summer.

    Causes of low DO in the south Puget Sound are very complex and we do not
believe that it is possible to attribute decreases solely to flushing
characteristics alone.  We have no plans to provide mitigation measures in
addition to the seasonal installation/operation of aeration equipment and
periodic WQ monitoring, but if requested we could meet this fall and discuss
the summer data.

                                      A-3

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                                      -2-
    Summary of Biological Studies in West Bay.  The Corps of Engineers
performed biological sampling on Olympia Harbor project benthos and fish from
May 2-5, 1990.  The Corps of Engineers sampled 10 stations within the project
area, 5 in the 30-foot channel and 5 in the 4- to 7-foot shallow bar that
would be dredged.  At each station four van Veen grabs were pulled for
infauna, one sampling sled was pulled for epifauna, and approximately one
ottertrawl and one beamtrawl was pulled across each station, once during the
day and once after dusk, to collect demersal fish, macroinvertebrates, and
epifauna.  This information will be used as part of the Olympia Harbor
Navigation Channel biological study that will be used to evaluate the
environmental impacts of the project and determine the mitigation needed for
the widening of the navigation channel.

    Section 404 Fills in East Bay.  In response to Section 404 fills in East
Bay, Regulatory Branch will respond in a separate letter.  If you have any
questions in regards to this topic, please contact Regulatory Branch at
telephone (206) 764-3495.

    If you have any questions regarding the first two topics, please contact
me at telephone (206) 764-3654.

                                       Sincerely,
                                       Linda Cox
                                       Environmental Coordinator
Copy Furnished:

Mr. Fred Weinmann
Environmental Protection Agency
Mr. Gwill Ging
Fish and Wildlife
Service
                                      A-4

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IRIST1NE O  CRECOIRE
   Director
                                     STATE OF WASHINGTON

                               DEPARTMENT  OF  ECOLOGY
               7272 Oeanwater Lane. LU-11  •  Olympa, Washington 98504-6811  •  (206; 753-2353
                                       June 6, 1990
          Gwill Ging
          U.S.  Fish fi Wildlife Service
          2625  Parkmont Lane S.W.
          Building B-3
          Olympia, WA  98502

          Dear  Gwill,

          Thank you for meeting with Michael Jacobson (PTI Environmental Services)
          and me in March.  In the meeting we discussed actions that might be
          taken to complement existing programs designed to enhance and protect
          water quality in Budd Inlet.  As a followup to the meeting, I have
          summarized below several of those potential activities which we hope
          become part of the draft Budd Inlet Action Plan.  Please respond to the
          following meeting summary and questions, including (where applicable)
          target dates, potential funding sources, resource constraints and/or
          other comments on feasibility.  Please also clarify any inaccuracies
          found below.

          Dredging and Filling Projects

          The U.S. Fish & Wildlife Service (USFWS) comments on proposed Clean
          Water Act Section 10 and 404 projects.  The agency also reviews
          mitigation projects.  This review can assert that mitigation projects
          are to be in place prior to the start of the project, and can recommend
          contingency plans in the event mitigations are later determined
          Insufficient.  Ths i^ct^ll^ticn cf csntin-c"2 dissolved oxvgsr. 'nn>
          monitors and aerators was a requirement for dredging in East Bay.  USFWS
          is aware the system has not been sufficient for ensuring DO levels meet
          water quality standards.  This summer, the Army Corps of Engineers will
          provide the Port of Olympia with a portable DO probe with which to
          conduct a more in-depth analysis of how well the system works.  The
          federal Water Resources Development Act (WRDA) of 1986 establishes a
          mitigation project fund for needed post-construction projects.  The
          funding is limited to high priority sites.  Fishkills resulting from low
          DO levels are well documented in Budd Inlet.  If new data submitted to
          the Corps shows that the aerators are insufficient to prevent violations
          of water quality standards, will DSFW recommend WRDA funding for
          contingency mitigation projects?
                                             A-5

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Gwill Ging
June 6, 1990
Page 2
A related concern is that of Clean Water Act Section 10 and 404 permit
conditions which specify that fill material on the southeast portion of
the Port peninsula is to be developed for water dependent uses only.
Several proposed developments for this fill area might be determined
non-water dependent uses.  In the event projects are deemed
nonconfarming uses, how does USFW anticipate they would address this?
Pleaae be specific.

Looraftino in West Bay

I understand that lografting in West Bay is a concern to USFW and other
natural resource agencies.  Studies on lografting conducted elsewhere in
Puget Sound show the practice La detrimental to benthic communities, as
well as to outmigrating salmonid fingerlings.   At low tide, it is
common to see lografts resting on West bay tideflats.  Does DSFW have
any plans to address this problem?  Does DSFW have informational
materials that would help educate the Port and citizen groups on the
subject?  Please suggest any means you know of for limiting the
destructiveness of this practice.

Thank you again for taking time out of your busy schedule to meet with
us and to respond to this letter.  Similar letters are being sent to
other Budd Inlet workgroup members.  These letters and their responses
will be assembled and mailed as a packet to all workgroup and citizen
advisory committee members.  The packet will also be included as an
appendix to the final Budd Inlet Action Plan.

Please submit your written response by June 22, 1990.  Also, please feel
free to call me with any questions and/or if you wish to discuss any
part of this letter (586-5554).
                                   Sincerely,
                                   Melany Vorabs
                                   Budd Inlet Action
                                    Plan Coordinator
cc:  Fred Weiman, Environmental Protection
                    Agency
                                    A-6

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               United States Department of the Interior

                           FISH AND WILDLIFE SERVICE

                          Fish and Wildlife Enhancement
                          2625 Parkmont Lane SW,  Bldg B
                           Olympia, Washington   98502
                           206/753-9440   FTS 434-9440

                               September 17, 1990
Ms. Melany Vorass
Budd Inlet Action Plan Coordinator
Washington Department of Ecology
7272 Cleanwater Lane, LU -11
Olympia, Washington  98504-6811

Re:  Budd Inlet Action Plan

Dear Ms Vorass:

This letter  responds to both  our discussion of September  6,  1990,  and your
letter of June 6, 1990.

The U.S. Fish  and Wildlife  Service  (Service)  reviews and provides  recommenda-
tions  on  projects  that  require  federal  permits,   (e.g.,   Section   10/404
permits),  federal   licenses   (e.g.,   Federal  Energy  Regulatory  Commission
licenses), or  involve  federal funding  (e.g.,  federal  projects).   Our  review
typically focuses on evaluating the potential of a project  proposal to  impact
fish and wildlife resources  of concern to the Service, and to then recommend
measures  to  mitigate  and  enhance  the  affected resources,  as  appropriate.
Depending on the level of impact and the prospects  for  implementing successful
mitigation, the Service may elect to recommend against  project  construction.

The  Service  has questions  and concerns  similar  to those  expressed  by your
agency regarding the operation of the continuous  dissolved oxygen monitors and
aerators.  It  is our understanding that  the  original  equipment  has not been
entirely effective,  and that  alternative equipment is  now being used.   Of
concern  to  the  Service  is whether  the  alternative  equipment provides  an
equivalent level of  protection of the  resource.  We will initiate  discussions
with the Corps, following the  Port  of  Olympia's summer monitoring  efforts, to
address this issue.

Regarding your question  on  the use  of Water Resources Development Act  (WRDA)
funding, the Service in 1990 recommended to the Corps that funding  be provided
to mitigate  for  fish and wildlife  impacts  caused  by  the construction  of the
East Bay  Marina Project  (Project).   One  of the options  that was discussed
involved measures  to  improve  inwater  habitat  within the  East Bay  of Budd
Inlet.     The  Service  would  support  measures such  as  the  replacement  of
monitoring and aerator equipment through funding  from WRDA  if  the existing
equipment is inadequate.  While  WRDA (Section 1135) authorized the Secretary
                                     A-7

-------
of the Army to spend up to 25 million dollars, Congress has yet to appropriate
the requested  funds.   The Service is unaware of  any projects nationwide that
have been funded through WRDA.

Your inquiry about  the appropriateness of using  former  intertidal areas that
were filled  during the  construction of  the  Project for  non-water dependent
purposes raises some interesting  questions.   Such proposals are inappropriate
from the  Service's  perspective and  they  would  be inconsistent both with the
Corps'  policy  (EP  1165-2-1)  and  with  the justification given  in  the Project
EIS for  selecting  the  alternative with the greatest intertidal/subtidal fill
(i.e.,  creation of cargo  handling areas).   Since  impacts to fish and wildlife
resources resulting from the project have already occurred, the Service is now
primarily concerned with preventing further losses of habitat.  The Service is
opposed to additional  filling  of  wetlands and intertidal and shallow subtidal
habitats.   Since  the  Port  may need  all  of  its  existing  cargo handling and
storage areas  at  some  time in the  future,  such areas should be  reserved for
bona  fide  Port  purposes,  instead  of  being  used   for non-water  dependent
facilities  (e.g.,   Olympic  Academy,   restaurants,   etc.).    Because  of  the
ramifications  regarding  future fills  in Budd Inlet,   the Service  will request
clarification  from the Corps  on  what type of developments  are  appropriate on
the areas created for cargo handling and storage.

The Service is also  concerned about the  Port's practice of storing log rafts
over intertidal habitats along West  Bay, Budd Inlet.   During certain tidal
periods, these log rafts "ground out" and likely crush or smother both benthic
and epibenthic invertebrates,  some  of which  are  prey species  for anadromous
fish and migratory birds.   The sluffing  and  subsequent  decomposition of bark
and the  production of leachate   from  stored  logs can  also  adversely  impact
water quality, (e.g.,  low dissolved oxygen levels,  toxicity) and  reduce both
species diversity and  abundance.   The  facts  that shallow  water habitats are
important rearing and  acclimation areas  for juvenile salmonids, and that the
log storage area is  located  along a migration  route, increases  the Service's
concern over Port's log storage practice.   While the  Service does  not have any
regulatory  authority  to  eliminate  this  practice,  it  is  our  intention  to
initiate discussions with the Port with the objective of having this practice
terminated.

If you  have any  further  questions  regarding  the  issues  contained in  this
letter,   please  contact  Mr.   Gwill  Ging  of  my  staff  at  the   letterhead
phone/address.
                                          Sincerely,
                                          David C.  Frederick
                                          Field Supervisor
                                      A-8

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ST1NE O. CRECOIRE
  Director
                                    STATE OF WASHINGTON

                              DEPARTMENT OF ECOLOGY
               7272 Ceanwater Lane. LU-11  • Olympia, Washington 98504-6811 •  (206) 753-2353
                                      June 6, 1990
         Jeff Dickison
         Fran Wilshesen
         Squaxin Island Tribe
         Natural Resources Oept.
         West 81 Highway 108
         Shelton, WA  98584

         Dear Jeff and Fran,

         Thank you for meeting with Michael Jacobson  (PTI Environmental Services)
         and me in February.   Several Squaxin Island Tribe activities we
         discussed exemplify a strong willingness to ensure progressive
         environmental protection programs are put  into place.   In keeping with
         this enthusiasm, we discussed actions that might be taken to complement
         existing programs.  As a followup to the meeting, I have  summarized
         below several of those potential activities which we hope become part of
         the draft Budd Inlet Action Plan.  Please  respond to the  following
         meeting summary and questions,  including  (where applicable)  target
         dates, potential funding sources, resource constraints  and/or other
         comments on feasibility.  Please also clarify any inaccuracies found
         below.

         Nutrient Loading / Abatement Studies

         The tribe is concerned that required upgrades at the LOTT facility may
         not sufficiently address plant-related  nutrient loading problems in Budd
         Inlet.  Both the tribe and LOTT are interested in conducting "before"
         ind "zftsr" 3tudiss ^ic cbssrvs  th-s 9^ti3r.^  ~f "3.t2r Tu&litv Ir^'srovsir.ent.
         The tribe and LOTT co-wrote and submitted  a CCWF grant  proposal to
         partially fund a nutrient loading/abatement  study that  was to be largely
         sponsored by Seagrant.  Because Seagrant monies were denied, the
         proposal was withdrawn.  However, there remains considerable interest
         and support for the study.  Can the Budd  Inlet Action Plan state in
         certain terns that the tribe will submit  a retailored grant proposal
                the next grant application period?
                                              A-9

-------
Jeff Dickison
Fran Wilshesen
June 6, 1990
Page 2
Boo Planting & Stream Enhancement Activities

The Department of Fisheries has cut back financial support for salmonid
egg planting and stream enhancement activities in the Budd Inlet basin.
Initially, the Squaxin Island Tribe planned to add several tributaries
to their program, including Mission Creek.  Though the tribe will
continue to maintain the current level of activity (1 million eggs in
Adams Creek and Gull Harbor), work in Mission Creek and other
tributaries will probably be delayed for up to 2 years.  Have other
potential resources been mramint*A for funding this activity (e.g., TrouL
Unlimited and other organizations)?  As an element of the Action Plan,
can it be stated in certain terms that Mission Creek will be added to
the program within the next two years?  What other tributaries are
scheduled to be included and when?

Geographical Information System (GIS)

With funding from the Northwest Indian Fisheries Commission and the
Budd/Deschutes watershed management grant, the tribe is developing a CIS
database which would be used for mapping and storing habitat
information.  The system is not yet ready for practical use.  Data
collected will be useful to other natural resource agencies.  When do
you anticipate the system's information to be accessible to other
agencies?   Currently, what are the limiting factors for its development
and use?  Please suggest any actions other agencies might take to help
you expedite development of the system.

Capitol Lake Wetland Feasibility Study

The tribe will continue their involvement with the Capital Lake wetland
feasibility study.  One of ths tribe's rr.ain ccr.csrr.s is sedirr.sr.t leading
in the Deschutes River and Capitol Lake.  According to at least one
study, increased surface water velocities due to watershed management
practices  (e.g., forestry) results in scouring in the Deschutes, which
is found to be the primary cause of sedimentation in Capitol Lake.  To
substantiate the results of this and other studies, the tribe is
interested in tracing the origin of sediments found in Capitol Lake.
This summer, the lake will be drawn down, making sediment sampling an
easier task.  Is the tribe interested in conducting the sampling at this
time?
                                   A-10

-------
Jeff Dickison
Fran Wilshesen
June 6, 1990
Page 3
WSDOT Highway Runoff

With the Department of Fisheries, the tribe shares management of the
Chinook salmon fishery in the Oeschutes River and Capitol  Lake.  Several
atormwater drainage systems carry large volumes of highway runoff to the
Oeschutes River and Capitol Lake.  The State Department  of
Transportation (WSDOT) is working with Ecology to develop  a stormwater
manual for future use.  Local jurisdictions in Thurston  County are  also
working on a separate stormwater management manual.  As  you are aware,
WSDOT stormwater represents a large portion of the total runoff to  the
Deschutes River, Capitol Lake,  Budd Inlet and local  stormwater systems.
Because 1-5 and SR-101 are both within watershed and urban bay
management areas, local jurisdictions have the opportunity to propose
that WSDOT implement a more stringent "Roadside Management Plan" within
these areas.  As a part of their involvement in watershed  and urban bay
           plans, will the tribe also consider entering  into such an
         :, or agree to formally encourage and provide  support to such an
effort?  Bow may this be stated specifically in the  draft  Budd Inlet
Action Plan?
    V.
Dredging and Filling Projects

Additional fill projects in Budd Inlet adversely impact  flushing rates
which results in further degradation of water quality  in Budd Inlet.
Through the Urban Waterfront Taskforce and other forums  of interagency
coordination, the tribe has encouraged the City, County, Army Corps of
Engineers and the Port of Olympia to minimize future fill  projects  in
the inlet.  At the  local level  this can be accomplished  through the
revision of applicable policies and ordinances; at the state and federal
level, this might be accomplished through a memorandum of  understanding
 ;:iO'JJ z: ether fsrsial  ^grssraer.t.  2oes the tribe have  specific
suggestions or plans on how and when such agreements would be entered
into?

A related issue  is  that of  use  of 404 fill for non water-dependent  uses.
With few exceptions, 404  fills  are to be used for water-dependent uses
only.  Several proposals  indicate fill material on the southeast portion
of the Port peninsula  is being  considered for siting non-water dependent
developments.  The  tribe has  a  comment role on 404 permits issued  for
dredging and filling projects.  This role implies a  certain authority to
ensure post-project permit  conditions are met.  The  tribe  plans  to
continue their active  role  in  coordinating with the  Port,  City,  USFWS
and others to request  from  the  Army Corps of Engineers an  interpretation
of how 404 fills should be  used in East Bay and other  areas. When do
you anticipate a formal  interpretation from the Corps?  Is the
interpretation  likely  to  also contain requirements  for how nonconforming
uses will be mitigated?


                                     A-11

-------
Jeff Dickison
Fran Wilshesen
June 6,  1990
Page 4
Thank you again for taking time out of your busy schedules to meet with
us and to respond to this letter.  Similar letters are being sent to
other Budd Inlet workgroup members.  These letters and their responses
will be assembled and mailed as a packet to all workgroup and citizen
advisory committee members.  The packet will also be included as an
appendix to the final Budd Inlet Action Plan.

Please submit your written response by June 22, 1990.  Also, please feel
free to call me with any questions and/or if you wish to discuss any
part of this letter (586-5554).

                                   Sincerely,        s-*
                                   Melany Vorass
                                   Budd Inlet Action
                                    Plan Coordinator
cc:  Northwest Indian Fisheries Commission
     Michael Rylko, EPA
                                   A-12

-------
                                   SQUAXIN ISLAND TRIBE
  June  22, 1990


  Melany Vorass
  Department of Ecology
  7272  Cleanwater Lane, LU-11
  Olympia, WA  98504


  Dear  Ms. Vorass:

  Thank you for your letter of June 6th.  We appreciate the work you
  are doing to coordinate activities for  the Budd Inlet Action Plan.
  Following are some comments in response to the questions you have
  asked of the Tribe.

  Nutrient Loading  / Abatement Studies

  The Tribe  is extremely concerned about nutrient  loading  in Budd
  Inlet as this problem is perhaps the most, significant cause of fish
  mortality in the  inlet.   The Tribe continues to support the need
  for a study to assess the effects of a nutrient abatement program
  at  LOTT.   The  CCWF  grant was submitted  by LOTT for  funding to
  accomplish this study.  Regardless  of  the  source of funding, the
  Tribe believes that  it  is essential to monitor the effectiveness
  of the LOTT program.   The  Tribe has no plans at this  time to submit
  their own grant proposal  for funding this endeavor.

  Egg Planting and  Stream Enhancement Activities

  Egg planting  is  an important element  of the Tribe's  enhancement
  program.  Budd Inlet  continues to be a likely area  for expanded egg
  planting activities.  However, due  to  the  failure of  our budgets
  to keep pace with  inflation and the added burden of absorbing Gramm
  Rudman cuts, our  program  is  faced with cuts in work elements and
  services.  Fish enhancement activities  are of high priority to the
  Tribe and this should serve as some indication of the severity of
  our budgetary  situation.   At this time we  cannot foresee adding
  any additional streams to  our egg planting program, and  in fact are
  faced with the possibility of reducing  or eliminating our existing
  program.  The  assistance  of volunteers generally serves  only to
  augment an existing  program.   In the present situation our basic
  funding is in jeopardy and must first be secured before  seeking the
  support of volunteer organizations.

NATURAL RESOURCES DEPARTMENT / West 81 Highway 108 / Shelton, WA 98584
                   FAX 426-3971  /  Phone (206) 426-9783
                                A-13

-------
Melany Vorass - Budd Inlet Action Plan
June 22, 1990
Page 2

Geographical Information System

As one might expect, there have been unexplained delays and extreme
frustration  in the  implementation of a new  computer system.  We
will assess  the situation this  summer and develop some ideas for
the assistance from other agencies.

Capitol Lake Wetland Feasibility Study

Sediment transport  and deposition  is a  serious concern  in the
Deschutes River and Capitol Lake.  The Tribe is interested in any
efforts to sample sediment composition.  Though we have heard some
general discussion of lake draw down,  we  will  have to  examine the
intentions  of  other  programs  to conduct  sampling  during  this
period.  Any information you can provide would be helpful.

WSDOT Highway Runoff

The Tribe is participating in the process  initiated by  Ecology and
DOT under the  Puget Sound Plan  to develop  a stormwater program.
One aspect  of  this  program  will be the development of "Roadside
Management Plans" on a localized basis.  When the process reaches
this  stage, the  Tribe  will be an  active  participant in  the
development  of these plans.   It is  our  full intention to improve
the quality  of stormwater entering the  Capitol Lake system in as
short a time frame as is practicable.

Dredging and Filling Projects

The Tribe is currently working  with  the City and the Port on the
Urban Waterfront Plan.  One element of that plan will  establish the
basis for a Comprehensive Habitat Management  Plan.  This plan will
address habitat needs in the  Harbor area and  should deal with many
of  the  dredging  and  filling issues.   On  the related  issue  of
restrictions of  use for  404 permitted  fills,  we  have  not yet
received a  response from either the  ACOE or EPA.   I don't know
their timeline  or  the depth with which they will address the issue.

I am sorry to acknowledge that all the news is not good news.  If
you have  any ideas of  how  we  could  address  our  funding needs,
either programmatically or on a  project specific basis, please let
me know.  Thanks for your help.
Sincer
               Biologist

                             A-14

-------
.HRIST1NE O  CRECOIRE
    Director
                                      STATE OF WASHINGTON

                               DEPARTMENT OF ECOLOGY
                    Cleanwater Lane. LU-n  •  Olympia, Washington 98504-6811  .  (206) 753-2353
                                      June  6,  1990
         Neil  Rickard
         Regional Habitat  Manager
         Washington Dept.  of  Fisheries
         Mail  Stop AX-11
         Olympia, WA 98504

         Dear  Neil,

         Thank you for  meeting with Michael Jacobson (PTI Environmental Services)
         and me in February.    In the meeting we discussed actions that might be
         taken to complement  existing programs designed to enhance and protect
         water quality  in  Budd Inlet.  As a followup to the meeting,  I have
         summarized below  several of those potential activities which we hope
         become part of the draft Budd Inlet Action Plan.  Please respond to the
         following meeting summary and questions, including (where applicable)
         target dates,  potential funding sources, resource constraints and/or
         other comments on feasibility.  Please also clarify any inaccuracies
         found below.

         Bulkhead Permits  /  Illegal Construction

         Fisheries is concerned with the probable high number of illegal bulkhead
         constructions  occurring in Budd Inlet.  Resources for enforcement
         activities are limited.  Thurston County requires a shoreline permit to
         be "on site" during  construction; however, there is no requirement for
         permits to be  posted in a place visible from the water.  To make boat
         r-zr-raillEnce a more  effective means of inspection and enforcement, will
         Fisheries provide the County with signs that can be noon zrom cne -citer,
        .and encourage  the County to incorporate a "post-permits-visibly"
         requirement in shoreline permits?

         Will  Fisheries agree to *»am* no other means of controlling the
         construction of  illegal bulkheads (e.g., certification program for
         contractors) and to  provide recommendations to agency upper management?

         Until recently,  surfsmelt spawning was thought to occur only in lower
         tidelands.  Fisheries has recently identified sandlance (candlefish)
         surfsmelt spawning  further up in tidelands.  Current bulkhead
         requirements are  not adequate to preserve this spawning habitat.
         Sandlance spawning occurs both in Boston Harbor and near Priest Point
         Park.  Fisheries  notes shoreline permits for bulkheads, particularly in
         these areas, need to be redefined to address this.  Please provide a
                                  oermit requirements.
                                           A-15

-------
Neil Rickard
June 6, 1990
Page 2
Hydraulic Permit Approval (HPA1 Guidelines

Fisheries is currently revising HPA guidelines for stormwater retention,
water quality and water quantity.  The revised guidelines will be
submitted to Fisheries management with a recommendation to either  adopt
them as policy or to use them as standard SEPA response.  When are the
guidelines likely to be implemented?  Will the new guidance be applied
to Fisheries' SKPA review for LOTT's new outfall?

Habitat Enhancement

Fisheries is involved in the management and enhancement of Chinook,
echo, and chum salmon in Adams, Ellis, Mission, Indian and Moxlie
Creeks.  Chum and pink salmon are also known to use Tyler and Butler
Cove.  When do you anticipate specific management and enhancement
activities to be developed in these areas?  Also, the Squaxin Island
Tribe may be willing to plant eggs in Mission Creek if eggs are
provided.  If so, will Fisheries provide eggs for planting in Mission
Creek?

Looraftina Impacts to Fish

Lografting in West Bay is a concern to several natural resource
agencies.  Studies on lografting conducted elsewhere in Puget Sound show
the practice is detrimental to benthic communities and to outmigrating
salmonid fingerlings.  At low tides, lografts over West Bay tidelands
directly affect habitat used by juvenile salmonids.  Does Fisheries have
specific plans to mitigate the potential affects of this practice? Are
Hatural Resource Damage Assessments  (NRDA) applicable to log rafting  and
assort a ted habitat loss; if so, does Fisheries plan to conduct a HRDA in
West Bay?

Thank you again for taking time out of your busy schedule to meet  with
-= ^nd to respond t= this letter.  Cirr.ilir Isttars ars bsir.g csr.t  to
other Budd Inlet workgroup members.  These letters and their responses
will be assembled and mailed as a packet to all workgroup and citizen
advisory committee members.  The packet will also be included as an
appendix to the final Budd Inlet Action Plan.

Please submit your written response by June 22., 1990.  Also, please feel
free to call me with any questions and/or if you wish to discuss any
part of this letter  (586-5554).
                                    Sincerely
                                    Melany Vorass
                                    Budd Inlet  Action
                                     Plan Ccordir.c.t;i"
 cc:   Michael Rylko,  EPA
                                   A-16

-------
JOSEPH R. BLUM
  Director
                                STATE OF WASHINGTON

                            DEPARTMENT OF  FISHERIES
        775 General Administration Building •  Olympia, Washington 98504  •  (206) 753-6600 • (SCAN) 234-6600

                                 August 1, 1990
       Department of Ecology
       ATTENTION: Melany Vorass
       Budd Inlet Action Plan  Coordinator
       7272 Cleanwater Lane, LU-11
       Olympia, Washington  98504

       SUBJECT:  Draft Budd Inlet Action Plan - Meeting Summary,
                 Questions and Clarification of Inaccuracies

       Dear Ms. Vorass:

       The Department of Fisheries  (WDF)  has reviewed the above-
       referenced letter of June 6,  1990 and we have the following
       comments.

       We disagree with your assessment of WDF's view on bulkhead
       activity in Budd Inlet.  First,  there is not a high number, if
       any, of illegal bulkheads being  constructed in Budd Inlet.
       Second, we believe that Thurston County has its own procedures
       for enforcement of bulkhead  activities and it would not be
       appropriate for us to encroach on their area of jurisdiction.  It
       would also be inappropriate  for  WDF to participate in a county
       certification program for contractors.

       At this point in time,  information on sandlance spawning habitat
       requirements is not well documented.   Until this information is
       available, it would be  inappropriate to revise the bulkhead
       criteria appearing in the Washington Administrative Code  (WAC
       220-110-280 (2)).  However,  WDF  will review each bulkhead
       proposal on a case by case basis and provide adequate protection
       for sandlance spawning  habitat.

       At the present time the Stormwater Management Guidelines are
       interim, but are being  implemented.   The final policy will be
       circulated for SEPA review upon  completion.  Since there is no
       relationship between LOTT and the Guidelines, their application
       would be inappropriate.

       Management and enhancement of the salmon stocks in the urban
       tributaries of Budd Inlet is the responsibility of WDF's Harvest
       Management Division.  We suggest you contact Tim Flint at
       753-0198 for information regarding the issues identified in the
       letter.
                                      A-17

-------
Melany Vorass
August 1, 1990
Page 2


We are concerned about log rafting and its detrimental affects on
fisheries resources and their habitat but our authority related
to existing log rafting areas is limited.  We are, however,
addressing new log rafting projects and are requiring full
mitigation.  It is our understanding that Natural Resource Damage
Assessments apply to chemical contamination that is typically
related to superfund sites, and would therefore not be
appropriate in these instances.

Thank you for the opportunity to meet with you and comment on the
development of the draft action plan. If you have any question,
please contact Neil Rickard, Regional Habitat Manager at
753-5732.

                         Sincerely
                         Earl L. Finn, Jr.
                         Supervisor, Marine Permits
                         Habitat Management Division
ELF:NR: jkd:23:6
cc:  Tim Flint - WDF, Harvest Management
     Thurston County Planning Department
     Michael Rylko - EPA
                              A-18

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CHRISTINE O. GREGOIRE
     Director
                                      STATE OF WASHINGTON

                                DEPARTMENT OF ECOLOGY
                 7272 Cleanwater Lane, LU-11  •  O/>mp/a. Washington 98504-6811 •  (206) 753-2353
                                        June 6,  1990

           Bob  Arndt
           Cliff Ikerd
           Washington Dept.  of
           General Administration
           Mail Stop AX-22
           Olympia, WA  98504

           Dear Bob and Cliff:

           Thank you for meeting with Michael Jacobson (PTI  Environmental  Services)
           and  me in February.    In the  meeting  we discussed actions  that  might be
           taken to complement existing  programs designed to enhance  and protect
           water quality in Capitol Lake.   As a  follow-up to the  meeting,  I have
           summarized below several of those potential activities which  we hope
           become part of the draft Budd Inlet Action Plan.   Please respond to  the
           following meeting summary and questions,  including (where  applicable)
           target dates, potential funding  sources,  resource constraints and/or
           other comments on feasibility.   Please also clarify  any inaccuracies
           found below.

           Wetland Feasibility Study

           The  department hired a consultant to  conduct a wetlands feasibility
           study for the middle and south basins of  Capitol  Lake.   The report will
           not  contain specific recommendations,  but will be used by  GA  to 1)
           evaluate the necessity of funding continued maintenance dredging in  the
           lake,  2) address  water quality,  and 3)  develop and erosion/nonpoint
           pollution control plan.   Does GA have any plans contingent on
           information in the report (e.g.,  recommendations  to  conduct further
           sediment sampling,  recommendations to fund an  aerial survey of
           sedimentation)?  Does GA plan to submit recommendations to the  90/91
           legislature based on the report  and any subsequent evaluations?

           Petroleum Storage Tanks

           Over 30 stormwater outfalls discharge to  Capitol  Lake,  1 of which
           collect water from GA property.   Two  of the outfalls discharge  water
           that collects in  a containment dike around a 300,000 gallon aboveground
           petroleum tank.   The storage  and its  containment  system do not  include
           oil/water separators.   State  law (RCW 90.48) requires  discharges from
           such systems to be  sufficiently  treated to assure no contamination
           enters state waters.   How does GA plan to upgrade their bulk  petroleum
           storage system and when will  this take  place?   Also, federal  law (40 CFR
           112)  requires Spill  Prevention and Containment and Contingency  (SPCC)
           plans  to be on site  at bulk oil  storage facilities.  Does  an  SPCC plan
           exist  for the facility?   If not,  please provide a target date for
           completing a plan.


                                              A-19

-------
Bob Arndt
Cliff Ikerd
June 6, 1990
Page 2
GA plans to remove their 1,000 gal. underground storage tank.  What is
the target date for removal?

Capitol Lake Restoration Plan

This year, the GA, in conjunction with other local and state agencies,
will begin phase two of the Capitol Lake Restoration Plan,
implementation.  Which elements of the restoration plan are budgeted for
1990, 1991, 1992?  Will GA meet target dates shown in the plan document?

Highway Construction Storage Area in Wetland

GA is responsible for managing Capitol Lake and surrounding lands.  A
wetland at the southwest end of the lake houses a storage area for the
Department of Transportation.  An Ecology drive -by inspection revealed
riprap and barrels being stored in the area.   GA reviewed records and
found reference to a verbal agreement permitting this.   GA noted two
barrels of wood preservative stored on the site and requested its
removal.  The barrels have been removed and riprap remains on the site.
Ecology plans a thorough inspection this spring.   If problems are found,
is GA willing to coordinate with Ecology to minimize the threat of any
potential contaminants on site?

Thank you again for taking time out of your busy schedules to meet with
us and to respond to this letter.   Similar letters are  being sent to
other Budd Inlet workgroup members.  These letters and  their responses
will be assembled and mailed as a packet to all workgroup and citizen
advisory committee members.  The packet will  also be included as an
appendix to the final Budd Inlet Action Plan.

Please submit your written response by June 22,  1990.   Also, please feel
free to call me with any questions and/or if  you wish to discuss any
part of this letter (586-5554).
                                   Sincerely,
                                   Melany Vorass
                                   Budd Inlet Action
                                    Plan Coordinator
cc: Allen Moore,  Ecology
                                  A-20

-------
K. WENDY HOLDEN
   Director
                                STATE OF WASHINGTON

                    DEPARTMENT OF GENERAL ADMINISTRATION
                 278 Genera/ Administration Building, AX-22  •  Olympia, Washington 98504-0622

                                      July 2,  1990
        Ms. Melany Vorass, Budd  Inlet Action Plan Coordinator
        Department of Ecology
        7272 Cleanwater Lane, LU-11
        Olympia, WA  98504-6811

        Dear Melany:

        This communication is in response to your letter of June 6, 1990
        regarding activities which may  affect water quality in Capitol
        Lake.  I apologize for the delay in responding to your questions.
        Each of your questions is addressed as follows:

        1.   Wetlands Feasibility Study

             GA's plans related  to wetlands are contingent on the content
             of the feasibility  study report.  The findings will be
             presented to the 1991 Legislature, and GA is expected to
             implement Legislative directions on wetland development,
             dredging, or other  actions.

        2.   Petroleum storage tanks

             GA intends to upgrade the  bulk diesel storage tank at the
             Powerhouse in the 1991-1993 biennium by installing an oil
             separator system in the enclosure perimeter.  This will
             allow rainwater to  exit the enclosure, but prohibit oil from
             entering Capitol Lake.  We will also develop a Spill
             Prevention and Containment Contingency plan in conjunction
             with this project.   Estimated completion of both projects is
             December 1992.                                        "

             The 1,000 gallon underground storage tank (UST) adjacent to
             the Powerhouse is currently in temporary closure.  Petroleum
             products have been  removed from the tank, and GA plans to
             remove the tank during the 1991-1993 biennium.  A projected
             date for removal is March  1993, as removal of regulated USTs
             (those used for motor fuel)  will be accomplished prior to
             removal of unregulated or  exempt tanks.
                                      A-21

-------
Melany Vorass
July 2, 1990
Page 2


3.   Capitol Lake Restoration Plan

     During 1990, GA will complete a study of erosion in the
     North Basin.  GA will also be a member of the Capitol Lake
     Action Committee, as per recommendation #1 of the plan, with
     the City of Olympia in the lead position.

     Capital items are not projected for the 1991-1993 biennial
     period, nor will be requested until the feasibility study
     results are available and have been analyzed.

4.   Highway construction storage area in wetland

     GA is willing to coordinate an effort with the Department of
     Ecology to minimize contamination on the site.  We cannot,
     however, commit to accomplish or to fund contamination
     mitigation efforts until the extent of any liability is
     determined.  Should the Department of Transportation or its
     contractors be determined at fault for contamination, GA
     would seek restitution for any damages or costs of cleaning
     the site.

I hope that this information provides you with a more complete
understanding of GA's planned activities related to Capitol Lake.
Should you have questions regarding the information in the
letter, please contact me at 753-0501 or Nick Cockrell at 586-
5256.  Nick will be replacing me as project manager of the
Wetlands Feasibility Study.

                              Sincerely,
                              Robert Arndt
                              Facilities Planning Manager
                              Division of Capital Management
RA:ncm
                             A-22

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IHRISTINE O CRECOIRE
    Director
                                      STATE OF WASHINGTON

                                DEPARTMENT OF  ECOLOGY
                ~272 Cleanwater Lane. LU-11,  •  Olympia. Washington 98504-6811  • (206) 753-2353
                                      June 6, 1990
         Bill Cleland
         Washington Dept.  of Health
         Mail Stop LD-11
         Olyrapia,  WA  98504

         Dear Bill,

         Thank you for meeting with Michael Jacobson (PTZ Environmental Services)
         and me in March.    In the meeting we discussed actions that might be
         taken to complement existing programs designed to enhance and protect
         water quality in Budd Inlet.  As a followup to the meeting, I have
         summarized below potential activities which we hope become part of the
         draft Budd Inlet Action Plan.  Please respond to the following meeting
         summary and questions, including (where applicable) target dates,
         potential funding sources, resource constraints and/or other comments on
         feasibility.  Please also verify any inaccuracies found below.

         Commercial Geoduck Beds

         Commercial geoduck beds located at the mouth of Budd Inlet are harvested
         on a rotational basis.  The Budd Inlet geoduck beds were harvested this
         year, and will probably not be re-opened for harvest for at least
         another 10 years.  At Boston Harbor, a wastewater treatment plant (WWTP)
         is under construction to serve that area; the outfall pipe will be
         placed within a 1/2 mile of the geoduck beds.  In recent years, simply
         by virtue of proximity, the beds would have been administratively closed
         to commercial harvest.  The Department of Health now determines a
                     one t              -                            fl *:h
          r         z
         department agree to conduct baseline water column sampling prior to the
         WWTP ^"••»«yj on line?  The Department also conducts occasional geoduck
         tissue sampling.  Will the DOB agree to conduct: baseline tissue sampling
         to determine future WWTP impacts to the geoduck beds?

         Recreational Shellfish Harvesting / Warning Signs

         Through the Puget Sound Ambient Monitoring Program, DOH conducts annual
         tissue chemistry sampling at Priest Point Park. The department also
         conducts quarterly sampling for fecal coliform bacteria at Priest Point
         Park and Burfoot Park.  Priest Point Park has been closed to
         recreational shellfish harvesting.  Will the DOH agree to continue
         sampling for fecals on quarterly basis at Burfoot?  Are there other
         areas in Budd Inlet in which DOH plans to conduct future tissue
         chemistry sampling?
                                              A-23

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Bill Cleland
June 6, 1990
Page 2
DOH has available contaminated shellfish warning signs.  The County is
responsible for actually posting and maintaining warning signs.  In at
least one other urban bay area, DOH has entered into a formal agreement
with the county health department to designate responsibilities for
various shellfish monitoring activities.  The agreement includes a
specific trigger for the point at which the county health department
would post a beach warning.  Could this MOA be applied in Thurston
County to encourage posting warning signs; if new data confiras
contaminated shellfish at other public beaches (e.g.. Rat Cove in west
Bay) will DOH formally recommend Thurston County post warning signs in
those locations?

Thank you again for taking time out of your busy schedule to meet with
us and to respond to this letter.  Similar letters are being sent to
other Budd Inlet workgroup members.  These letters and their responses
will be assembled and mailed as a packet to all workgroup and citizen
advisory committee members.  The packet will also be included as an
appendix to the final Budd Inlet Action Plan.

Please submit your written response by June 22, 1990.  Also, please feel
free to call me with any questions and/or if you wish to discuss any
part of this letter (586-5554).

                                   Sincerely,
                                   Melany Vbtass
                                   Budd Inlet Action
                                    Plan Coordinator
cc:  Clive Pepe, DOH
                                    A-24

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                         STATE OF WASHINGTON

                     DEPARTMENT OF HEALTH
                        Olympia, Washington 98504


                          June 21,  1990
Ms.Melany Vorass
Budd Inlet Action Plan Coordinator
Department of Ecology  MS PV-11
Olympia, Washington  98504

Dear Jlg^—Verassr ,

Please find below my responses to the questions you asked  in your
June 6th letter regarding the Budd Inlet action plan:

Will the department agree to conduct baseline water column
sampling prior to the WWTP coming on line?

     Yes.  We have stations located in the  immediate vicinity
     which are sampled as part of our ambient monitoring plan.

Will the DOH agree to conduct baseline tissue sampling to
determine future WWTP impacts to the geoduck beds?

     Yes.  Geoduck tissue sampling is a routine activity.
     However, tissue samples are not used to determine water
     quality impacts.

Will the DOH agree to continue sampling for fecals on quarterly
basis at Burfoot?

     Once we have collected a sufficient number of samples to
     classify Burfoot (15 samples per station) ambient monitoring
     will occur on a yearly basis.

Are there other areas in Budd Inlet in which DOH plans to  conduct
future tissue chemistry sampling?

     No additional chemistry sampling sites are planned at this
     time.

Could this recreational shellfish MOA be applied in Thurston
County to encourage posting warning signs;  if new data - confirms
contaminated shellfish at other public beaches  (e.g., Rat  Cove in
West Bay) will DOH formally recommend Thurston County post
warning signs in those locations?
                              A-25

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Ms. Melany Vorass
Page two
June 21, 1990
     Posting contaminated beaches is a part of the recreational
     shellfish program.  All public beaches in Inner Budd Inlet
     should be posted and we have recommended this.  We
     anticipate concluding a formal MOA with Thurston County by
     late summer.

I hope I have addressed all of your concerns.

If you have any questions or require further assistance, I can be
reached at 753-5993.

                              Sincerely,
                              BILL CLELAND
                              Public Health Advisor
                              Office of Shellfish Programs
BCrvb
                               A-26

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:HRISTINE o. GREGOKE
    Director
                                      STATE OF WASHINGTON

                                DEPARTMENT  OF ECOLOGY
                 7272 Cleanwater Lane, LU-11  •  Olympia, Washington 98504-6811 •  (206; 753-2353
                                     September  11, 1990
          Ms.  Peggy Britt
          Boater Education Program
          Parks & Recreation Commission
          7150 Cleanwater Lane
          Mail Stop KY-11
          Olympia,  WA  98504-8711

          Dear Ms.  Britt:

          Thank you for meeting with Michael Jacobson (PTI Environmental Services)
          and  me earlier this summer.  At that time,  and in subsequent
          conversations, we discussed several Parks and Recreation Commission
          activities related to environmental protection in the Budd/Deschutes
          watershed.  Below is a summary of topics we discussed,  as well as a few
          remaining questions.  In addition to responding to the questions, please
          clarify any inaccuracies found in the text below.   Please provide your
          written response by September 21,  1990.

          Marine Sewage Disposal Pumpouts

          Design criteria for marina pumpouts has  now been finalized,  and a grant
          program for funding the installation and retrofitting of pumpouts is now
          being administered by your agency.   At least two local jurisdictions in
          Thurston County have applied for grants  to improve the operation of
          existing pumpouts.    When is it likely monies for this grant period will
          be allocated, and when will the next grant period begin?  Also,  you
          indicated the agency estimates approximately six pumpout stations will
          be "intalled" statewide per year.   How do grants toward retrofitting
          figure into this estimate; is there a cap on funds that go toward
          retrofitting?

          Marine Sewage Disposal (MSP) Requirements

          The  agency has been working on an enforcement strategy for requiring
          MSDs on recreational boats under 65'  feet in length.   The report,
          required by the 1988 PSWQ Plan,  was due  spring,  1990.   If the report has
          been completed, please forward a copy.   If not,  what  is the status for
          completing the report and what factors may have caused delays?

          The  Parks and Recreation Commission conducted a survey detailing types
          of MSDs,  frequency  of use,  waste issues,  boating impact on local
          communities,  etc.   Please forward a copy of the final report.  Also,  you
          indicated the agency is likely to perform another survey in 1991 to
          determine the program's success.   When do you anticipate the decision
          will be made on whether or not to conduct the 1991 survey?
                                              A-27

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Ms. Peggy Britt
September 11, 1990
Page 2
Interpretive & Educational Signs

I am aware of two signs your agency makes available to local
jurisdictions.  Please briefly describe these and other signs available;
are these also available to private marinas?

Thank you for your continued participation in the Budd Inlet Action
Plan.  Please contact me at 586-5554 with any questions on the above or
other elements of the Action Plan.
                                   Sincerely,
                                   Melany Vorass
                                   Budd Inlet Action
                                   Plan Coordinator
                                 A-28

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JAN TVETEN
 Director
                                      STATE OF WASHINGTON

              WASHINGTON STATE PARKS AND RECREATION  COMMISSION

                 7750 Cleanwater Lane, KY-11  •  Olympia, Washington 98504-57 n  • (206)753-5755


                                            September  27,  1990
        Ms. Mel any Vorass
        Budd  Inlet Action  Plan  Coordinator
        Department of  Ecology
        7272  Cleanwater  Lane, W-ll
        Olympia, Washington  98504-6811

        Dear  Ms. Vorass,

        I  am responding  to   your   letter   dated   September   11,   1990   requesting
        clarification  and  confirmation  of  Washington  State   Parks  and  Recreation
        Commission's (State  Parks) activities related  to  environmental  protection  in
        the  Budd/Deschutes  watershed.   I  will respond to  each   section  of your
        letter.

        Boat  Sewage Pumpout  Grants

        The first  round of  grants were  awarded on  September 21, 1990.   State  Parks
        will  fund  10 and possibly 12 pumpout  stations in this  round.   Olympia  Parks
        and Recreation Department will  be awarded a  grant.   The Port of Olympia will
        not receive a  grant  in  this  round.

        Renovation of  existing facilities  is an eligible grant cost.   There  is  no
        cap on  funds  that go toward renovations;  however State  Park engineers will
        make  a  recommendation  on  suitability  of  a station for renovation and may
        require a new  system to be installed  for cost  and maintenance reasons.

        Marine Sewage  Disposal  (MSP)  Requirements

        State Parks has  not  developed an  MSD  enforcement  strategy as directed by the
        1988  PSWQ Plan.    State  Parks  did  not receive  the   staffing required  to
        undertake the  task.   We will  begin  working on an enforcement  strategy July
        1991  and finish  July 1992.   The enforcement strategy will  be developed with
        the aid  of  an  advisory  committee  consisting  of boating  and  state agency
        representatives.     A   second  boater  survey  may  be   a part   of  the MSD
        enforcement strategy project.

        Interpretive and Educational  Signs

        State Parks Boating  Programs has two signs  and an instructional  decal.  One
        sign  is an interpretive sign  and  one  is  a pumpout logo  sign  used  to  indicate
        the location   of  a  boat  sewage pumpout  station or  portable  toilet  dump
        station.   Copies of these two  signs  are enclosed.   The  instructional  decal
        verbally and  visually  describes how to operate  a  pumpout  station.   This


                                             A-29

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instruction decal  has  been  adopted  for  use by  Keko,  Inc.   All  new Keko
pumpout stations now include the instruction decal.

Please contact me if you require  any  further information.   I may be reached
at 586-2283.
                                   Peggy^BMtl
                                   Boating Environmental
                                   Education Coordinator
PB/kf

Enclosures
                                    A-30

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PUMP OUT
 STATION
  A-31

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                PLEASE  HELP
       PRESERVE HOOD CANAL'S  BOUNTIFUL
           AND FRAGILE ENVIRONMENT
      Over 40,000 boaters visit the waters of Hood Canal each year.  Litter, sewage,
and boat maintenance wastes can pollute water and contaminate marine life. Water in
shallow bays and inlets is often restricted and natural flushing may take several years or
more. Wastes that are dumped overboard tend to stay around for a long time.
           BOATERS CAN MAKE A DIFFERENCE.
                THIS IS WHAT WE CAN DO:

      Stow all litter on board.  Dispose of it in proper
      dockside containers or take it home.

      Dispose of sewage properly by treating it or using a
      holding tank.  Watch for pumpout stations and use
      them as they become available in the future.  Use
      sboreside restrooms when possible.

      Practice smart boat maintenance: keep your engines
      well-tuned; recycle waste oil and solvents; use a bilge
      sponge; and choose non-toxic paints and
      biodegradable cleansers.

    CAPTAINS: INSIST THAT YOUR CREW, GUESTS AND
      FELLOW BOATERS FOLLOW THESE PRACTICES.
                  SET A GOOD EXAMPLE.
      This panel was developed by citizen volunteers. Special thanks to Adopt a Beach and to
       the Hood Canal Coordinating Council, the Puget Sound Water Quality Authority, Naval
      Submarine Base, Bangor and the Washington State Parks and Recreation Commission for
                         funding and support.
                           A-32

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CHRISTINE O. GREGOIRE
     Director
                                      STATE Of WASHINGTON

                                DEPARTMENT OF ECOLOGY
                 7272 Cleanwater Lane, LU-11  • Olympic, Washington 98504-6811 •  (206) 753-2353
                                        June 6,  1990
           Andrea Copping
           Puget Sound Water
            Quality Authority
           217  Pine St.,  Suite 1100
           Seattle, WA  98101

           Dear Andrea:

           Thank you for meeting with Michael Rylko of EPA and me in March.  In the
           meeting we discussed actions that might be taken to complement existing
           environmental protection programs.  As a follow-up, I have summarized
           potential activities we hope become part of the draft Budd Inlet Action
           Plan.   Please respond to the following summary and questions,  including
           (where applicable) target dates,  potential funding sources, resource
           constraints and/or other comments on feasibility.  Please also clarify
           any  inaccuracies found below.

           Stormwater Management Programs

           As part of the Puget Sound Water  Quality Plan,  Ecology is drafting a
           stormwater management manual.   The manual will provide minimum
           requirements for stormwater management in the Puget Sound basin.
           Watershed planning areas and other areas considered environmentally
           sensitive are subject to more stringent requirements under area-specific
           "roadside management plans."   The area-specific plans would be
           primarily negotiated between local jurisdictions and the State
           Department of Transportation.   Large volumes of highway runoff and
           sediment impact wetlands and waters within both the fiudd/Deschutes
           watershed planning area and the Budd Inlet Action Plan study area.  As
           environmentally sensitive areas are identified through these efforts,
           and  if local jurisdictions propose WSDOT implement a roadside  management
           plan,  will the Authority provide  support to such an effort (e.g.,
           letters of support; recommendations for local rule, authority, funding)?

           Ecology is also in the process of drafting stormwater rules.  The
           authority under which the rules are being promulgated (RCW 90.48)  does
           not  permit Ecology to extend to local authorities provisions for private
           stormwater facilities.  Under RCW 90.70, the PSWQA is given authority to
           address private systems.   The Authority plans to exercise this authority
           by adopting the Puget Sound Management Plan by rule or by developing a
           companion rule.  When will this decision be made?  If the Authority
           proposes a companion rule, will the rule adoption process occur
           simultaneously with Ecology's RCW 90.48 rule adoption?
                                             A-33

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Andrea Copping
June 6, 1990
Page 2
The Department of Transportation has agreed to write an EIS this year
for pesticide use in Washington.  The EIS could be applied to other
statewide applicators, such as Burlington Northern and Union Pacific
railroads.  Would the Authority agree to review the draft EIS and, if
applicable, formally recommend the conditions become requirements for
other applicators?

NPDES Permits

The Authority tracks and reviews certain NPDES permits written by
Ecology for consistency with the Puget Sound Water Qulity Management
Plan.  Generally, only precedent-setting permits are chosen for review,
due to the number and complexity of NPDES permits.  Ecology is
responsible for reviewing and prioritizing the vast majority of permits
to be written and/or renewed.  How do you anticipate PSWQA and Ecology
will coordinate permit review and prioritization in the future?

PSAMP Monitoring

The Authority coordinates the Puget Sound Ambient Monitoring Program
(PSAMP), which involves sediment and fish sampling for toxic chemicals,
among other parameters.  Under PSAMP, there are two fixed (annual) and
two rotating (triannual) sediment sampling stations and two fixed fish
tissue sampling stations in Budd Inlet.   The stations are selected with
the objectives of obtaining baseline data and looking for long-term
trends to identify any changes in ambient estuarine quality.   Which
agencies secured funding to continue PSAMP?  Is the PSWQA now
considering placing future PSAMP monitoring (Puget Sound-wide) closer to
shore in order to improve the resolution of degradation or improvement
trends in the marine estuary?

Public Involvement and Education (PIE) Fund

Local agencies and citizen groups implementing the Budd Inlet Action
Plan are eligible to apply for PIE awards.   Will higher priority for
funding be assigned to projects that involve implementation of urban bay
action plans?

What changes, if any, do you anticipate over the next two years in the
PIE award program?

Thank you again for taking time out of your busy schedule to meet with
us and to respond to this letter.  Similar letters are being sent to
other Budd Inlet workgroup members.  These letters and their responses
will be assembled and mailed as a packet to all workgroup and citizen
advisory committee members.  The packet will also be included as an
appendix to the final Budd Inlet Action Plan.
                                  A-34

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Andrea Copping
June 6, 1990
Page 3
Please submit your written response by June 22, 1990.  Also, please feel
free to call me with any questions and/or if you wish to discuss any
part of this letter (586-5554).
                                   Sincerely,
                                   Melany Vorass
                                   Budd Inlet Action
                                    Plan Coordinator
cc:  Vallana Piccolo, PSWQA
     Sheila Kelly, PIE Fund Administrator, PSWQA
                                  A-35

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A-36

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KATHERINE FLETCHER
    Chair
                                STATE OF WASHINGTON

                   PUGET SOUND WATER QUALITY AUTHORITY

                 277 Pine Street, Suite 1100 • Seattle, Washington 98101 • (206) 464-7320
       August 30, 1990

       To:        Melany Vorass
       From:     Andrea Copping
       Re:        Response to Questions concerning Budd Inlet Action Plan


       In  response  to your letter  of  June  6,  I  am providing  the
       information which you highlighted as being important  for inclusion
       in the Budd Inlet Action Plan.

       Stormwater Management Programs

       Under  the  stormwater program  of  the Puget  Sound  plan,  local
       jurisdictions  have  several  options  for  gaining  support  for
       implementing a roadside management plan including: a rule and model
       ordinances  for carrying out  the rule  (element  SW-4); technical
       assistance  from the Department  of Ecology  for  developing local
       ordinances  (SW-3.2);  and  eligibility   for  funding  under  the
       Centennial  Clean  Water Fund  and the  Puget  Sound Grants Program
       (element EM-6).

       The decision  to adopt  the  Puget  Sound plan by rule or to adopt a
       companion rule will  be made after  the 1991 plan is adopted.  The
       Authority will probably examine adopting a companion stormwater
       rule simultaneously  with the  adoption of 90.48 by Ecology  as one
       of several options.

       The Authority will probably review the WSDOT EIS  on pesticide use.
       The Authority's role in pesticide use  by  statewide applicators is
       generally restricted to encouraging education and research into the
       safe application of pesticides.

       NPDES Permits

       Under element P-13  of the 1991 Puget Sound Water Quality Management
       Plan, the Authority gives priority  to  the review  of  NPDES permits
       in urban  bays.   In general,  the  Authority  reviews permits for
       consistency with the permit writer's manual (element P-5)  and other
       portions of the Puget Sound plan.   Through the urban bay  action
       teams and the  ongoing working relationship between the point source
       sections of the Authority and Ecology, coordination for the review
       of urban bay permits between the two  agencies should be enhanced.
                                      A-37

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PSAMP Monitoring

Under  the  1989  Puget  Sound plan,  funds  became  available for
monitoring the following PSAMP tasks:
     o    sediment quality (Ecology) - about 80% funded
     o    fish  toxics  and  fish  health  (Fisheries)  -  about 35%
          funded
     o    shellfish contamination (Health) - about 40% funded
     o    marine water column (Ecology) - about 35% funded
     o    fresh water (Ecology)  - about 25% funded

We  anticipate  that  the  PSAMP  agencies  will  have these   funds
available  to them during the next biennium.   In  addition,  we
anticipate that additional funds will be available for PSAMP-

In order to meet the goals of PSAMP, sampling stations are placed
away  from  the  shoreline  and away from  individual  sources  of
contamination.   At this time, there are no plans  to  move  PSAMP
stations closer to shore.

Public Involvement and Education (PIE) Fund

Selection criteria during the first four rounds  of the PIE fund
focussed on model projects directed  towards implementing the  Puget
Sound plan.   Projects associated with the UBATs were given  equal
consideration with all others which have direct relationship to the
plan.

We  anticipate that new  criteria  for  the  selection of  PIE  fund
projects will be developed for awards during the next biennium.

I apologize for the delay in getting this information to you.  If
I can be  of any further help, please  call me  at  464-7934   (scan
576-7934) .
Sincerely,
Andrea E. Copping, PhD.
PSAMP Coordinator
                               A-38

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PRISTINE O. GREGOIRE
    Director
                                      STATE OF WASHINGTON

                                DEPARTMENT OF ECOLOGY
                 7272 Cleanwater Lane, LU-11  •  Olympia, Washington 98504-6011 •  (206) 753-2353
                                        June 6,  1990
           Dave Jamison
           Washington Department
           of Natural Resources
           Mail Stop  EX-12
           Olympia, WA  98504

           Dear Dave:

           Thank you  for meeting with Michael Jacobson (PTI Environmental Services)
           and me  in  February.   In the meeting we discussed actions that might be
           taken to complement  existing programs designed to enhance and protect
           water quality in Budd Inlet.   As a follow-up to the meeting,  I have
           summarized below several of those potential activities which we hope
           become  part of the draft Budd Inlet Action Plan.  Please respond to the
           following  meeting summary and questions,  including (where applicable)
           target  dates,  potential funding sources,  resource constraints and/or
           other comments on feasibility.   Please also verify any inaccuracies
           found below.

           Commercial Geoduck Beds

           DNR may elect to re^seed a recently harvested geoduck bed located at the
           mouth of Budd Inlet.   What criteria must  be met in selecting an area for
           re-seeding.   Is  Budd Inlet likely to approved for reseeding,  and if so,
           when would it likely take place?  Specifically, what conditions would
           prevent the area from being re-seeded?

           DNR Administration of Model Toxics Control Act Rules

           Though  the Port  owns  most tidelands adjacent to the Port peninsula,  DNR
           manages aquatic  lands adjacent to those and is concerned that industrial
           discharge  pollutants  migrate  to DNR-managed aquatic lands.   The results
           of several recent sediment sampling projects may confirm these concerns.
           Ecology and DNR  are  developing a memorandum of understanding  (MOU)  by
           which DNR  will carry  out provisions of the state Model Toxics Control
           Act for DNR-managed  aquatic lands.   What  is the target date  for
           finalizing the agreement?  Until the MOU  is signed, how will  DNR address
           contaminated sediments that may be identified in recent studies?
                                             A-39

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Dave Jamison
June 6, 1990
Page 2
DNR is currently developing a method to assess probability of
contaminated sediments from near-shore industrial use (type of industry,
length of time there, etc.)  Due to resource constraints, sediment
sampling may not occur except in areas that have high potential to be
impacted.  Have criteria been selected to determine where sampling
projects will be located; are any areas of Budd Inlet likely to meet
those criteria?  At the earliest, when might sampling projects begin in
Puget Sound?

Pesticide Impacts to Marine Plants

Recently, the Washington Department of Transportation (WSDOT) agreed to
write an EIS for their statewide pesticide use.  When completed,
conditions of the EIS may be applied to other entities (e.g., Burlington
Northern and Union Pacific railroads).  Will DNR consider formally
encouraging this?

Lografting Impacts to Benthic Communities

Lografting in West Bay is of concern to several natural resource
agencies.  Studies on lografting conducted elsewhere in Puget Sound show
the practice is detrimental to benthic communities, as well as to
outmigrating salmonid fingerlings.   At low tides, lografting in West
Bay directly affects habitat used by juvenile salmonids.   Does DNR have
authority to restrict this practice over Port-owned tidelands?  What
guidelines does DNR impose for lografting over aquatic lands that might
be adopted by the Port?  Does DNR have informational materials that
would help educate the Port and citizen groups on the subject?  Please
suggest any means you know of for mitigating the effects of this
practice.

Aquatic Lands Enhancement Account

A workshop was held in March to inform interested parties of available
monies to provide public access to shorelines.  I would appreciate
receiving information on any proposed activities within the
Budd/Deschutes basin.

Thank you again for taking time out of your busy schedule to meet with
us and to respond to this letter.  Similar letters are being sent to
other Budd Inlet workgroup members.  These letters and their responses
will be assembled and mailed as a packet to all workgroup and citizen
advisory committee members.  The packet will also be included as an
appendix to the final Budd Inlet Action Plan.
                                   A-40

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Dave Jamison
June 6, 1990
Page 3
Please submit your written response by June 22, 1990.  Also, please feel
free to call me with any questions and/or if you wish to discuss any
part of this letter (586-5554).
                                   Sincerely,
                                   Melany Voi
                                   Budd Inlet Action
                                    Plan Coordinator
cc:  ALEA Coordinator
                                  A-41

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A-42

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   WASHINGTON STATE DEPARTMENT OF
   Natural Resources
                                                              BRIAN BOYLE
                                                   Commissioner of Public Lands
                                                         OLYMPIA, WA 98504
Melany Vorass
Budd Inlet Action Plan Coordinator
Department of Ecology
LU-11
Olympia.WA 98504-6811

July 30, 1990

Dear Melany:

I'm sorry for the delay in responding to your earlier letter on the
action plan.  Here are my responses to your questions:

Commercial Geoduck beds
     As of this date the only planting has been of an experimental
nature. The  main criteria is whether or not natural recruitment
appears to be occuring at the site. If it is then no planting will be
done. We do not know the statis of the Budd Inlet site in terms of
future planting.

DNR and MTCA
     The  MOU with DOE is in the discussion stage. I anticipate we
will be signing the document the fall of 1990.  Using funds from the
Model Toxics Account allocated to DNR by the legislature this past
session, DNR is forming an action team to begin an inventory of
potential contaminated sites on state owned aquatic lands, including
Budd Inlet. We hope to have the inventory done by the end of this
fiscal year. In addition we have funds from the same source to begin
characterizing sites where a potential PRP is not  present.  We have
just begun development of criteria to identify and rank those sites.
It is unknown if a site in Budd Inlet will be identified.

Pesticides
     We have not contemplated formally dealing with the
Department of Transportation on this issue, but we would like to
review the EIS draft when it is issued.
                             A-43

             Equal Opportunity/Affirmative Action Employer

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Vorass                                                   Page 2
DOE - Budd Inlet
Comments
7/30/90
Log rafting Impacts
     Attached for your information is WAG 332-30-145 which deals
with log rafting.  The current lease for the West Bay harbor area for
log storage expires in 1992.  While current lease language appears
not to have anti-grounding language, those raft areas appear to be
beyond the intertidal zone so grounding would not be a problem.

ALEA
     I will inform the program manager of your interest in the
program.
          ours,
David W Jamison, Ph.D.
Senior Marine Scientist
Division of Aquatic Lands
                             A-44

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                                           Aquatic Land Management
                                          332-30-145
in the vicinity, and the degree of navigational use by the
public and adjacent property owners;
   (c) The dock interferes with preferred water-depen-
dent uses established by law; or
   (d) The dock is a public health or safety hazard.
   (6) Appeal of revocation. Upon receiving written no-
tice of revocation or cancellation, the abutting residen-
tial owner shall have thirty days from the date of notice
to file for an administrative hearing under the contested
case proceedings of chapter 34.04 RCW.  If the action  to
revoke the permission is upheld, the owner shall correct
the cited conditions and shall  be liable  to the state for
any compensation due to the state from the use of the
aquatic lands from the date of notice until  permission
requirements are  met  or  until  such permission is no
longer needed. If the  abutting residential  owner  dis-
claims ownership of the dock,  the department may  take
actions to have it removed.
   (7) Current leases. Current lessees of docks meeting
the criteria in this section will be notified of their option
to cancel the lease. They will  be provided a reasonable
time to respond. Lack of response will result in cancella-
tion of the lease by the department.
   (8) Property rights. No property rights in, or bounda-
ries  of,  public aquatic lands  are  established  by  this
section.
   (9) Lines of navigability. The department  will  not ini-
tiate establishment of lines of navigability on any shore-
lands unless requested to do so by the shoreland owners
or their representatives.
   (10) Nothing  in this section is intended  to  address
statutes  relating   to sales of  second class  shorelands.
[Statutory Authority:  RCW  79.90.105,  79.90.300, 79-
.90.455,  79.90.460, 79.90.470,  79.90.475, 79.90.520, 79-
.68.010,  79.68.68  [79.68.080],  and chapter 79.93 RCW.
85-22-066 (Resolution No.  500),  § 332-30-144,  filed
11/5/85.]

   WAC  332-30-145  Booming, rafting  and storage  of
logs. All requirements in this section shall apply to the
department and to port districts managing aquatic lands
under a management agreement (WAC 332-30-114).
   (1) Unless specifically exempted  in  writing,  all log
dumps located  on  aquatic lands, or operated in direct
association with booming grounds on aquatic land, must
provide facilities for lowering logs into the water  without
tumbling, which loosens the bark. Free rolling of logs is
not permitted.
   (2) Provision must be made to securely retain all  logs,
chunks, and trimmings and other wood or bark particles
of significant size within the leased  area. Lessee will be
responsible for regular cleanup and upland disposal suf-
ficient to prevent  excessive accumulation of any debris
on the leased area.
   (3) Unless permitted in writing,  aquatic  land leased
for booming  and rafting shall not be used  for  holding
flat rafts except:
   (a) Loads of logs averaging over 24" diameter.
   (b) Raft assembly, disassembly and log sort areas.
   (4) Unless permitted in  writing, grounding of logs or
rafts is not allowed on tidelands leased for booming and
rafting. However, tidelands which were leased for boom-
ing and  rafting prior  to  January 1, 1980, are exempt
from this provision.
   (5) No log raft shall remain on aquatic land for more
than one year, unless specifically authorized in writing.
   (6) For leases granted to serve the general needs of an
area such as an island, the  leased area shall be made
available to others  for booming and  rafting and  at a
reasonable charge.
   (7) Areas within a lease boundary meeting  the defini-
tion of log booming are water-dependent uses. The rent
for these areas will be calculated according to WAC
332-30-123.
   (8) Areas leased  for log storage  shall have the rent
calculated by  applying a  state-wide base  unit rent per
acre. Temporary holding  of  logs alongside a vessel for
the purpose  of loading  onto the vessel is neither booming
nor storage.
   (9) The base unit rent, application to existing leases,
and subsequent annual rents will be determined as pro-
vided for water-dependent  uses under WAC 332-30-
123 except for the following modifications:
   (a) A formula rental calculation will be made for each
such area leased as  of July 1, 1984, as though  the for-
mula applied on July 1, 1984.
   (b) The assessment  for an upland parcel shall not  be
used when the following situations exist:
   (i) The parcel is not assessed.
   (ii) The size of the parcel in acres or square feet is not
known.
   (c) When necessary to select an alternative  upland
parcel, the nearest assessed  waterfront parcel shall  be
used if not  excluded by the criteria under (b)  of this
subsection.
   (d) Because of the large size and shape of many log
storage areas, there may be more than one upland parcel
that could be used in the formula. The department shall
treat such multiple parcel  situations by using:
   (i) The per unit value of each upland parcel applied to
its portion of the lease  area. If it is not possible or feasi-
ble to delineate all portions of the lease area by extend-
ing the boundaries of the upland parcel, then;
   (ii) The total of the assessed value  of all the upland
parcels divided by the  total acres of all the upland par-
cels shall be the per unit value applied  in the formula.
   (e) The total  formula rents divided by the total acres
under lease  for log storage equals the annual base unit
rent for  fiscal years 1985-1989. That  figure  is  $171.00
per acre.
   (0 For purposes of calculating stairstepping of rentals
allowed  under  WAC  332-30-123,  the base unit rent
multiplied by the number of acres shall be the  formula
rent. In cases of mixed uses, the log storage formula rent
shall be added to the formula rent determinations for the
other uses under leases before applying the criteria  for
stairstepping.
   (g) Inflation adjustments to the base rent shall begin
on July 1, 1990.
   (10) On July 1, 1989, and each four years  thereafter,
the department shall establish a new base unit rent.
(11/5/85)
                                                   A-45
                                  [Ch. 332-30 WAC—p 21]

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332-30-145
Aquatic Land Management
  (a) The new base rent will be the previous base rent
multiplied by  the result of dividing the average water-
dependent lease rate per acre for the prior fiscal year by
the average water-dependent lease rate per acre for the
fiscal year in  which the  base unit rent was  last estab-
lished. For example, the  formula  for the base unit rent
for  fiscal year  1990 would be:
                               (FY89 AWLR)
  FY90 BUR  = FY85 BUR x   	
                               (FY85 AWLR)

  (b) When necessary to calculate the average water-
dependent lease rate per acre for a  fiscal year, it shall be
done on or near July 1. The total  formula rent plus in-
flation adjustments divided by the  total acres of water-
dependent uses affected by the formula during the prior
fiscal year shall be the prior fiscal year's average.
  (11) If portions of a log  storage lease area are open
and accessible  to  the  general public,  no rent  shall be
charged for such areas provided that:
  (a) The area meets the public use requirements under
WAC 332-30-130(9);
  (b) Such areas are in a public use status for a contin-
uous period of three months or longer during  each year;
  (c) The lease includes  language  addressing public use
availability or  is amended to include such language;
  (d) The department approves the lessee's  operations
plan for public use, including safety precautions;
  (e) Changes in the amount of area  and/or length of
time for public use availability shall only be made at the
time of rental adjustment to the lease; and
  (0 Annual  rental for such areas will  be prorated by
month and charged for each month or part of a month
not available to the general public.  [Statutory  Authority:
1984 c 221 and RCW 79.90.540. 84-23-014 (Resolution
No. 470), § 332-30-145, filed  11/9/84. Statutory Au-
thority: RCW 43.30.150.  80-09-005  (Order 343),   §
332-30-145, filed 7/3/80.]

  WAC  332-30-148  Swim rafts and mooring buoys.
(1) Swim rafts or  mooring buoys will not be  authorized
where such structures will interfere with heavily traveled
routes for watercraft, commercial fishing  areas or on
designated public use - wilderness beaches.
  (2) Swim rafts or mooring buoys  may be  authorized
on aquatic lands shoreward of the -3 fathom  contour or
within 200 feet of extreme low water or line of naviga-
bility whichever is appropriate. The placement of rafts
and buoys beyond the -3. fathom contour or 200 feet will
be evaluated on a case by case basis.
  (3) No more than one structure may be installed for
each  ownership beyond  extreme  low  water  or line of
navigability. However, ownerships exceeding 200 feet as
measured along the shoreline may be permitted  more
installations on a case by case basis.
  (4) Swim rafts or  buoys must float at least 12" above
the water and  be a light or bright color.
                 (5)  Mooring  buoys may  be authorized beyond the
               limits described above on land designated by the depart-
               ment for  anchorages. [Statutory Authority: RCW 43-
               .30.150. 80-09-005  (Order  343), §  332-30-148,  filed
               7/3/80.]

                 WAC 332-30-151  Reserves (RCW  79.68.060). (1)
               Types of reserves: Educational, environmental,  scientific
               - see definitions (WAC 332-30-106).
                 (2) Aquatic lands  of special educational or  scientific
               interest or aquatic lands of special environmental impor-
               tance threatened  by  degradation shall  be considered for
               reserve status. Leases for activities in conflict with re-
               serve status shall  not  be issued.
                 (3) The department or other governmental  entity or
               institution may nominate specific areas for consideration
               for reserve status.
                 (4) Such  nominations will be reviewed  and  accepted
               or rejected by the commissioner of public lands based
               upon the following criteria:
                 (a) The site will accomplish the purpose as stated for
               each reserve type.
                 (b) The site will  not  conflict  with  other current or
               projected uses of the  area. If it does, then a determina-
               tion  must  be made by the commissioner of public lands
               as to which use best serves the public benefit.
                 (c) Management of the reserve can  be effectively ac-
               complished by either the department's management  pro-
               gram or by assignment to another governmental agency
               or institution.
                 (5) The department's  reserves management  program
               consists of prevention of conflicting land use activities in
               or near the reserve through lease actions. In those cases
               where physical  protection of  the area may be necessary
               the management of the area may be assigned to another
               agency.
                 (6) When  DNR retains the management of reserve
               areas the  extent  of  the  management  will consist  of a
               critical review of lease applications in the reserve area to
               insure  proposed activities or  structures will not conflict
               with the  basis for reserve designation.  This review will
               consist of at least the following:
                 (a) An environmental assessment.
                 (b)  Request of agencies  or institutions previously
               identified  as having  a special  interest in the  area for
               their concerns with regard to the project.
                 (7) Proposed leases for structures or activities imme-
               diately adjacent to any reserve area will be subjected to
               the  same critical  review as for leases within the area if
               the structures and/or activities have the potential of:
                 (a) Degrading water quality,
                 (b) Altering local currents,
                 (c) Damaging marine life,  or
                 (d) Increasing vessel traffic.                         ,
                 (8) All  management costs  are to be borne by the ad-
               ministering agency. Generally, no lease fee is  required.
               [Statutory Authority: RCW  43.30.150. 80-09-005  (Or-
               der 343), § 332-30-151, filed 7/3/80.]

                 WAC 332-30-154  Marine  aquatic plant removal
               (RCW  79.68.080). (1) Any species of aquatic plant may
[Ch. 332-30 WAC—p 22]
           A-46
(11/5/85)

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 O GREGOHE
Dnctor
                                  STATE OF WASHINGTON

                           DEPARTMENT  OF  ECOLOGY
            7272 Cl&anwater Lane, LU-11  •  Olympia, Washington 98504-6811  •  (206) 753-2353
                                    June 6, 1990
       Joanne Richter
       City of Olympia Public Works
       P.O. Box 1967
       Olympia, WA  98507

       Dear Joanne,

       Thank you for meeting with Michael Jacobson (PTI Environmental Services)
       and me in January.  Olympia'a current and planned activities exemplify a
       strong willingness to ensure progressive environmental protection
       programs are put into place at the local level.  In keeping with this
       enthusiasm, we discussed in our meeting actions that might be taken to
       complement existing programs.  As a followup to the meeting, I have
       summarized below several of those potential activities which-we hope
       become part of the draft Budd Inlet Action Plan.  Please respond to the
       following meeting summary and questions, including (where applicable)
       target dates, potential funding sources, resource constraints and/or
       other comments on feasibility.  Please also clarify any inaccuracies
       found below.

       Regional Drainage Manual

       In conjunction with other local jurisdictions, the City of Olympia is in
       the process of assembling a manual containing design criteria and other
       requirements for stormwater management.  Beginning in August, 1990, the
       manual will be used by City and County planning, public works and
       utilities staff for routine review of development.  To better ensure
       consistent use of the manual, will City staff agree to mtH•iiBHnrt the
       annual be adopted by ordinance?

       The current draft manual does not define operation and maintenance
       requirements'and to what extent education and enforcement are to be
       funded.  As part of the Action Plan, will staff agree to recommend to
       the City Council to adopt and enforce an ordinance (or other means) to
       ensure operation and maintenance programs are adequately funded for both
       private and public systems?

       Percival and Moxlie/Indian Storm Drain Studies

       The City is conducting storm drain studies in Indian, Moxlie and
       Percival Creeks.  Studies will be completed by the end of 1990, and data
       will be used to prioritize capital improvement needs.  To determine
       long-term effects of future capital improvement projects, will the City
       consider continuing to monitor at regular intervals in locations sampled
       during the study?

                                          A-47

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Joanne Richter
June 6, 1990
Page 2
The City is participating with other local and state agencies in
preparing a Capitol Lake wetland feasibility study for legislative
review. . As part of the study, and to make improvements in Percival
Cove, the lake will be drawn down in July, 1990.  The County plans to
take advantage of a drawdown to conduct storm drain surveys.  Is the
City interested in coordinating with the County in this effort so data
on Percival Cove can be applied to the City's Percival Creek Stormwater
Study  (e.g., source identification).

WSDOT Highway Runoff

The Washington State Department of Transportation (WSDOT) is currently
working with Ecology to develop and adopt a highway runoff manual.  The
manual will contain design and OSM requirements for new construction.
Current WSD&T design criteria may not meet local drainage manual
requirements.  Through watershed and urban bay planning activities,
local  jurisdictions are dedicating many hours and much money to
protecting waterways from contaminants delivered by local stormwater
systems.  As you are aware, WSDOT stormwater represents a large portion
of runoff discharging directly to the Deschutes River, Capitol Lake and
Budd Inlet, as well as to local stormwater systems.  Because 1-5 and SR
101 are both within watershed and urban bay management areas, local
jurisdictions have the opportunity to propose that WSDOT implement a
more stringent "Roadside Management Plan" within-these areas.  In
conjunction with other local jurisdictions, will the City of Olympia
agree  to co-write and submit such a proposal to WSDOT?  (A proposal
might  be as easy and brief as suggesting WSDOT meet the requirements of
the new local drainage manual.)

City Owned and Operated Marine Sewage Pumpout

The City owns, operates and maintains a marine sewage pumpout at
Percival Landing.  Several citizen complaints to Ecology indicate a need
to improve O&M practices and/or upgrade the facility.  The City may
qualify for a State Parks and Recreation grant to fund .major renovation
to the existing pumpout or a new pumpout; will the City apply for one of
these  grants?  What other steps has the City planned to ensure the
pumpout operates sufficiently on a consistent basis?

Water  Quality Policies and Ordinances

The City recognizes increased resources are needed in order to
adequately fund and staff inspection and enforcement activities to
ensure requirements are adhered to under the Shoreline Master Program,
SEPA conditions and building codes.  In addition, the City specifically
recognizes the need to increase resources to improve enforcement of
erosion and sedimentation requirements.  Will City staff examine
potential  funding sources for these activities and submit
recommendations to the City Council?
                                     A-48

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Environmental Education

In addition to the regional drainage manual and the County's
environmental education library, a handbook containing water quality
policies (and possibly educational information, best management
practices,  building code information, etc.) would be beneficial to
developers, to zoning officials and to staff responsible for design
review.  As an Action Plan element, will the City consider working with
the County to organize and distribute such a manual?

The City is conducting storm drain surveys to identify and prioritize
problem drains for capital improvement projects.  However, high priority
capital improvements will not take place until at least 1992, and lower
priority drains may not be addressed for some time after that.  Until
the systems are upgraded, public awareness of street-to-waterway drains
should be increased,  will the City agree to help increase awareness by
actively participating with neighborhoods to initiate storm drain
stencilling projects?  In addition to this, will the City agree to
assist other agencies in the distribution of storm drain posters
(provided by Ecology) to businesses?

The City and other local jurisdictions recently allocated funding for
time on a local cable t.v. channel.  Coverage for this year will include
County Commission and possibly City Council meetings to which viewers
will be able to phone in their questions.  Future meeting agendas are
now being reviewed, and specific meetings will be identified as those
most likely to be aired.  Thurston regional growth has brought to the
forefront many environmental issues in need of citizen input.  Hill the
City of Olympia agree to formally recommend (or encourage 'to whatever
extent possible) that one or more of the televised meetings include
discussion on key environmental issues being addressed by the City in
the Budd/Deschutes basin?

Thank you again for taking time out of your busy schedules to meet with
us and to respond to this letter.  Similar letters are being sent to
other Budd Inlet workgroup members.  These letters and their responses
will be assembled and mailed as a packet to all workgroup and citizen
advisory committee members.  The packet will also be included as an
appendix to the final Budd Inlet Action Plan.

Please submit your written response by June 22, 1990.  Also, please feel
free to call me with any questions and/or if you wish to discuss any
part of this letter (586-5554).
                                   Sincerely,
                                   Melany \Wrass
                                   Budd Inlet Action
                                    Plan Coordinator
cc:  Marziah Kiehn, Olympia Planning
     Dan Doles, Olympia Fire Dept.
                                    A-49

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A-50

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   City of
   OLYMPIA
   Public Works Department
August 17, 1990
Melany Vorass
Budd Inlet Action Plan Coordinator
Department of Ecology
7272 Cleanwater Lane, LU-11
Olympia, WA   98504-6811
Dear Melany:

The  following  responds  to the  meeting  summary  and  questions
presented  in your letter  of June 6, 1990.   I have attempted  to
clarify  several inaccurate statements  as  well as address  target
dates, potential funding sources,  and resource constraints that may
affect the City of Olympia's implementation of specific aspects  of
the Budd Inlet Action  Plan.   I have also addressed many  of the
issues  that you  raised in your  June  6,  1990  letter to Marziah
Kiehn.   I  apologize that  it has  taken  me  so long to get back  to
you.  I'm  finding that  the life of a local government  employee  is
never boring.


Regional Drainage Manual

The  regional  drainage  manual is   scheduled  to  be  adopted  by
ordinance  by  the  end  of  the  year.     City  staff   have  been
implementing various aspects of the draft manual since  early June,
including enhanced storage and treatment requirements and improved
erosion  and  sediment control practices.

The current  draft manual does address operations  and  maintenance
(O & M)  requirements  for both private and public  facilities.   In
addition, the City's new Storm  and Surface Water Management Program
describes  an enhanced 0 &  M program that is funded by  increased
utility  rates approved in June of  this year.   In addition to a
yearly O & M budget of about $550,000,  the utility is also funding
a stormwater enforcement  staff person who  will  be responsible for
enforcement  of stormwater ordinances,  development standards,  and
policies.   This  person will  also   conduct  a regular  inspection
program  to ensure that public and  private facilities  are being
properly maintained.
p-WICACITY
Hill!


    1987
                               A-51
   Av«.~..» •; F P n R™, IQA7 <~il»~-ia, WA 98507-1967, (206) 753-8314

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Percival and Moxlie/Indian Storm Drain Studies

The  first  phase of the Indian/Moxlie Drainage Basin Plan will  be
completed  by the end of 1990;  the second phase of this  study and
the Percival Creek Drainage Basin Plan will be completed by the end
of 1991.   The  City,  in conjunction with the other jurisdictions,
intends  to maintain permanent  flow  and  water quality monitoring
stations  at key  locations  within the drainage basins.   We are
currently  working on a draft interlocal agreement to  formalize the
cost-sharing arrangement for this monitoring program.  The City's
share of the program will be funded by utility revenue.

During the July 1990 draw-down  of Capitol Lake, City crews walked
the  lake shoreline to  inventory  storm  drain outfalls.   We also
obtained a copy of the water quality data that the County  collected
from storm drain outfalls  during  that event.   Those data will  be
included in our Percival Creek  Drainage Basin Plan.


WSDOT Highway Runoff

Preliminary discussions   among  the  local  jurisdictions  have
indicated   consensus  agreement  that  WSDOT   should   meet  all
requirements of the new regional drainage manual.  As  this drainage
manual nears completion towards the end of the year, the City,  in
conjunction with the other local jurisdictions,  will  make a formal
request  to WSDOT to  seek  their cooperation  in meeting regional
drainage manual requirements.


City Owned and  Operated Marine  Sewage Pumpout

The  City  has  applied  for a  $5,500 grant  from State  Parks and
Recreation to  replace  the  marine  sewage  pumpout facility located
at Percival Landing.  Although the existing  facility  is maintained
year-around on  a regular basis by the City Parks and Recreation
Department,   chronic   mechanical   failures   necessitate   its
replacement.


Water Quality Policies and Ordinances

The  City of Olympia  has approved  funding  to hire  a  stormwater
enforcement person  whose  duties  would  include enforcement   of
-erosion-and-sedimentation-requirements.  We intend to  advertise for
this position this fall and hire no later than the end of year.

I  support  the  adoption  of  stricter  standards  for aboveground
storage tanks  (ASTs) in order to achieve better protection of our
surface  and  groundwater  resources.    With  Ecology   providing
background information to justify  the need,  I  can commit  resources
from within my  program  to pursue  adoption by the  Olympia City
                               A-52

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Council of stricter standards for ASTs.

With respect to the City adopting stricter environmental standards
for new  marinas,  these  stricter  standards will be  applied when
existing marinas undergo expansion or other alterations.  However,
existing marinas  not undergoing  expansion are considered  to be
"grandfathered" under the old standards;  they will not be required
to comply with the stricter standards.


Sediment Quality Studies

The City has not yet received results of the sediment sampling that
is being done  for  the draft  EIS  on the Olympic Academy.   We will
review those data as they become available.


Environmental Education

The City will  be  developing  informational  flyers covering  our
stormwater policies, best management practices,  stormwater facility
design standards,  water quality educational programs,  and  other
topics.  These flyers will be distributed  to staff, the development
community, and others.  At this time we do not envision preparing
a separate manual  that  would include these items.   However, such
a manual, developed jointly with the county and other cities,  may
be warranted in the future.

The City is actively developing a storm drain stenciling program.
We have  organized  12  stenciling  kits and training materials that
are available for use by groups throughout the  City.  In addition,
we are  working with  neighborhood  groups interested  in  specific
stream restoration/cleanup  activities.  As  part of  our  overall
public involvement and  education program,  we would  be pleased to
work with  other state and local agencies  in the  distribution of
storm drain posters and other educational materials as they become
available.

I  believe  a  discussion by  the  Olympia City Council  of  key
environmental issues in the Budd/Deschutes basin is an appropriate
topic for  a  televised council meeting.  I will raise this  issue
with the Council's Energy and Utilities  Committee  to  see  if they
will support pursuit of such a discussion.


In summary, the City of Olympia actively  supports the ongoing work
of the Budd Inlet Urban Bay Action Committee, and we look forward
to playing an integral role in the implementation of the Budd Inlet
Action Plan.  I believe the activities we are pursuing as part of
our comprehensive Storm and Surface Water  Program nicely complement
your efforts  to protect and preserve water  quality  and marine
habitats in Budd Inlet.
                               A-53

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I hope this letter has helped clarify the relationship between some
of our on-going programs  and elements of  the draft  Budd Inlet
Action Plan.   Please let me  know  if I can provide you with any
additional information.
Sincerely,
Joanne E. Richter, Supervisor
Water Resources Program
cc.  Emmett Dobey, Olympia Public Works Department
     Marziah Kiehn, Olympia Planning Department
     Paula Ehlers, Olympia Planning Department
     Kevin Pierce, Olympia Parks and Recreation Department
                               A-54

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PRISTINE O. GRECOIRE
   Director
                                     STATE OF WASHINGTON

                               DEPARTMENT  OF ECOLOGY
                7272 Oeanwater Lane. LU-11  • Olympia. Washington 98504-6811  •  (206^ 753-2353
                                       June 6,  1990
          Linda Hoffman
          Thurston County
           Environmental Health Div.
          2000 Lakeridge Drive SW
          Olympia, WA  98502

          Dear Linda,

          Thank you for meeting with Michael  Rylko  (EPA),  Michael  Jacobson (PTI
          Environmental Services)  and me  in February.   Thurston  County's  current
          and planned activities exemplify a  strong willingness  to ensure
          progressive environmental protection  programs are  put  into  place at  the
          local level.  In keeping with this  enthusiasm, we  discussed in  our
          meeting actions that might be taken to  complement  existing  programs.  As
          a followup to the meeting, I  have summarized below several  of those
          potential activities which we hope  become part of  the  draft Budd Inlet
          Action Plan.  Please respond  to the following meeting  summary and
          questions, including  (where applicable) target dates,  potential funding
          sources, as well as resource  constraints  and/or  other  limiting  factors.
          Please also clarify any  inaccuracies  found below.

          Regional Drainage Manual

          In conjunction with other local jurisdictions, Thurston  County  is in the
          process of assembling a  manual  containing design criteria and other
          requirements for stormwater management.   The manual will be in  use by
          August, 1990, and will be used  for  routine review  of development.  The
          current draft does not define operation and  maintenance  requirements and
          to what extent program education and  enforcement are to  be  funded.   Aa
          part of the Action Plan, will staff agree to recommend to County
          rnmainninnrrn adopting an ordinance (or other means) to  ensure  these
          elements of the program  will  be adequately funded  for  both  private and
          public systens?  Also, will the County  consider  encouraging other local
          jurisdictions to enter into agreements  to ensure regional consistency
          for these elements?

          Thurston County has taken a lead role in  recognizing the need to impose
          requirements for the design,  operation  and maintenance of oil/water
          separators, as well as minimum  requirements  for  disposal of sediments
          from these systems.  Will requirements  for sediment disposal be included
          in the drainage manual for both public  and private systems  (or  imposed
          by another means)?
                                             A-55

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Linda Hoffman
June 6, 1990
Page 2
Basin Planning

The County hopes to receive Centennial Clean Water monies to help  fund
the first phase of Budd/Deschutes watershed planning.  EPA and Ecology
conducted marine sediment sampling in April, 1990; several sampling
stations were located near larger stormwater outfalls.  Will the County
consider reviewing this data (singularly and/or in conjunction with data
collected through watershed planning, stormwater surveys and ground
water studies) and, where necessary, take early actions to identify
priority upland sources and drainages of contamination?

Wetland Feasibility Study

The County is participating with other local and state agencies in
preparing a Capitol Lake wetland feasibility study for legislative
review.  As part of the study, and to make improvements in Percival
Cove, the lake will be drawn down in summer, 1990.  When this occurs,
the County may conduct a stormdrain survey.  Though the survey may not
include sediment sampling, an inventory of outfall locations will be
performed, and data will presumably become part of a larger stormwater
mapping project.  As the outfalls are mapped, will the County consider
identifying, prioritizing and mapping potential "upstream" contaminant
sources to the systems?  Does the County have an interest; in
coordinating this effort with the Squazin Island Tribe for the
development of a regional geographical information system (CIS)?

If sediment sampling does take place, what contaminants will be analyzed
and how will the data be used?  Hill Puget Sound Protocols be used?
Will source identification sampling follow?

Water Quality Policies and Ordinances

County staff recognize that increased resources are needed in order to
adequately fund and staff inspection and enforcement activities to
ensure requirements are met under the Shoreline Master Program, SEPA and
building codes.  Will County staff agree to «»»•«•<"«» potential funding
sources and submit recommendations to the County Commission?

As with most other local jurisdictions, the County regulates the
construction of aboveground storage tanks (ASTs) through the Uniform
Fire Code (adopted by reference in the state building code).  The Fire
Code contains few requirements pertaining to environmental protection
(e.g., the Code holds no requirement for impervious surfaces to be
placed beneath ASTs, nor for oil/water separators within diked
containment and adequate burm construction).  The fire code gives fire
marshals discretion to impose stricter standards; this has been done by
the City of Olympia, using Ecology guidelines, on a case-by-case basis.
If adequate justification were presented (by Ecology), the County would
consider using the guidelines on a consistent basis by referencing them
in building codes or in an ordinance (either countywide or in
                                   A-56

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Linda Hoffman
June 6, 1990
Page 3
environmentally sensitive areas).  However, imposing new rules may
require increased staffing.  If Ecology provides background information
illustrating the need for stricter requirements (e.g., by siting local
incidents), will County staff consider 1) identifying resource needs to
implement new guidelines, and 2) recommending their implementation as
well as potential funding sources to the County Commission?

The scope of work for the County Stormwater Utility identifies the need
to develop an erosion control ordinance.  What is the target date for
adopting the ordinance?  Are there any foreseeable delays to meeting
this date?  Also, the County recognizes the need to increase enforcement
resources in order to ensure current, general erosion control
requirements are met.  As an element of the Action Plan, will the County
agree to include in the draft ordinance a means to increase funding for
enforcement activities?

WSDOT Highway Runoff

The Washington State Department of Transportation (WSDOT) is currently
working with Ecology to develop and adopt a highway runoff manual.  The
manual will contain design, operation and maintenance requirements for
new construction.  Current WSDOT design criteria may not meet local
drainage manual requirements.  Through watershed and urban bay planning
activities, the County and other local jurisdictions have dedicated many
hours and much money for protecting waterways from contaminants
delivered by local stormwater systems.  However, as you are aware,
stormwater from WSDOT right-of-ways represents a large portion of the
total runoff to the Deschutes River, Capitol Lake and Budd Inlet.
Because 1-5 and SR 101 are both within watershed and urban bay
management areas, the County has the opportunity to propose that WSDOT
incorporate more stringent standards through "Roadside Management Plans"
within these areas.  In conjunction with other local jurisdictions, will
the County agree to take the lead on writing and submitting such a
proposal to WSDOT?  (A proposal might be as easy and brief as suggesting
WSDOT meet best management practices prescribed in the new local
drainage manual.)

Environmental Education

In addition to the regional drainage manual and the County's
environmental education library, a handbook containing water quality
policies (and possibly educational information, best management
practices, building code information, etc.) would be beneficial to
developers, to zoning officials and to staff responsible for design
review.  Will the County consider organizing and distributing such a
manual?
This year, the County and other local jurisdictions bought airtime on
the local cable t.v. channel.  Television coverage for this year
includes County Commission meetings during which viewers are able to
phone in questions.  Future meeting agendas will be reviewed, and
                                    A-57

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Linda Hoffman
June 6, 1990
Page 4
specific meetings identified as those most likely to be aired.  Thurston
County's growth rate has brought to the forefront many environmental
issues in need of citizen input.  As an element of the Action Plan, will
the County Department of Health formally recommend (or encourage to to
the extent possible) that one or more of the televised meetings include
discussion on key environmental issues being addressed in the
Budd/Deschutes basin?

Two County parks on Budd Inlet, Priest Point and Burfoot Parks, both
have maintained trails providing beach access.  The beach at Priest
Point Park posts a warning that shellfish are contaminated.  Will the
County Parks Department also post environmental education signs and/or
interpretive displays (e.g., detailing how Priest Point Park shellfish
became contaminated)?

Fecal Contamination

The County administers a "limited volunteer shellfish sampling program.
Will the County agree to directly contact residents living in areas of
concern to solicit their involvement? (Areas of concern include beaches
near package wastewater treatment plants, between Butler and Tykle
Coves, Athens Beach.)  When a private beach is found to be contaminated,
what followup action does the County typically take?

The County is planning to upgrade the Tamoshan package wastewater
treatment plant.  Improvements will include aeration and decreasing
discharges of nutrients and fecals.  When do you estimate the
improvements will be made?

Thank you again for taking time from your busy schedule to meet with us
and to respond to this letter.  Similar letters are being sent to other
Budd Inlet workgroup members.  These letters and their responses will be
assembled and mailed as a packet to all workgroup and citizen advisory
committee members.  The packet will also be included as an appendix to
the final Budd Inlet Action Plan.

Please submit your written response by June 22, 1990.  Also, please feel
free to call me with any qestions and/or if you wish to discuss any part
of this letter (586-5554).

                                   Sincerely,     /^
                                   Mel any Vorass
                                   Budd Inlet Action
                                    Plan Coordinator
mv/
cc:  Terry Rogers, County Parks
     Greg Grunenfelder, County Health
     Clint Dice, County Public Works
     Jay Armstrong, County Public Works
     Michael Rylko, EPA
                                   A-58

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                                                       COUNTY COMMISSIONERS
                                                       George L. Earner, Jr.
                                                         District One
                                                       Diane Oberquell
                                                         District Two
                                                       Les Eldridge
                                                         District Three
                                   OEFICE OF WATER QUALITY
                                   AND RESOURCE MANAGEMENT
                                                      . Linda Hoffman, Director

September 6, 1990

Ms. Melany Vorass
Budd Inlet Action Plan Coordinator
Washington State Department of Ecology
7272 Cleanwater Lane   Mail Stop:  LU-11
Olympia, WA  98504

Dear Melany:

Thank  you  for  your  assistance  in  framing and  responding  to
questions about  Thurston  County  activities relating to  the Budd
Inlet Action Plan.  The following are responses to your questions
with the exception  of  those pertaining to the Tamosham wastewater
treatment plant and above ground storage tanks.   I understand you
will  talk to  Clint  Dice,  Public  Works,  and  the Public  Works
Building Division on those issues.

Thurston Regional Drainage Manual

The manual will be adopted in late-1990 and will  be  in use by 1991.
Each  local  jurisdiction  will  be responsible  for  determining the
mechanism by which the manual will be implemented; those mechanisms
have  yet  to  be   decided.    To  ensure  adequate  funding  for
implementation of all aspects of the manual, each jurisdiction will
be responsible for identifying their own funding  sources; this will
be part of the utility budget  process.

Funding  of program education and  enforcement  activities  is  a
priority,  but  monies  for these  elements   have  not  yet  been
"earmarked;"  county staff are dedicated  to,  at the very least,
ensuring improved training for new staff,  providing workshops for
design  engineers and  other staff  education  efforts.   As above,
resources dedicated to these  elements of the program  would be a
separate utility budget process for each jurisdiction.

Operation and maintenance requirements are included in the  manual
for  facilities that  are  part of  an overall project  undergoing
permit review.   The manual covers public  and private facilities.
Additional policies are being  developed to address maintenance of
stormwater  systems that are  not part  of  a   project reviewed in
accordance with the new manual.

The completion  of  an  inventory of private and  public  systems is
expected August, 1990.


           Mailing Address: 2000 Lakeridge Drive SW, Olympia, Washington 98502-6045
      Location: 921 Lakeridge Drive SW, Room  113, Olympia, Washington 98502-6045 (206) 754-4111
                                                                    Recycled Paper
                                A-59

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The drainage manual requires sediments to be disposed but does not
specify at this time the method of disposal.

Basin Planning

The Ecology grant contract under which Thurston County will begin
the first phase of Budd/Deschutes  watershed planning was signed in
early-August,  1990.   Under this contract, water  quality  data is
being collected and analyzed, and will be used to develop the plan.
Throughout  this  and  other data collection  activities,  where
problems are identified, the County plans to take immediate actions
to identify upland sources and drainages of contamination.

The County is also a subcontractor to the City of Olympia for water
quality  monitoring  in support  of  stormwater basin  plans  for
Indian/Moxlie and Percival Creeks.

Wetland Feasibility Study

Earlier  this  summer,  the  County  completed  an  inventory  of
stormdrains discharging to Capitol Lake.  Sediment  sampling was not
a  part of  the  survey,  though  this  is  likely  to occur  under
watershed  planning activities.   As data  is  collected  through
watershed planning activities,  the County will begin to identify,
prioritize and map potential "upstream" contaminant sources.  The
data collected will be compiled as a  "Data Collection and Analysis
Plan."   This  plan will be  used to  determine future water  and
sediment sampling needs.   Thurston  County has subcontracted the
Squaxin Island Tribe to develop a regional geographic information
system (CIS).  Data collected will become part of the CIS.

As the Data Collection  and Analysis Plan is developed, any sediment
sampling outlined will  reference the Puget Sound Protocols.  Source
identification will be done within the time permitted by funding.

WQ Policies and Ordinances

County directors  are proposing  a  variety  of  budget additions for
1991, including increased funding for improved enforcement of the
regional  Shoreline Master  Plan,  SEPA,  building  codes,  erosion
policies, etc.   The budget will  be reviewed  and adopted during
October - December, 1990.

The County Stormwater Utility has given high priority to developing
an erosion  control ordinance.   County board  members  support the
effort, and  adoption  of the ordinance is expected by late-1990.
There are no foreseeable delays to meeting this target date.  The
ordinance will provide enforcement  authority.   Various  funding
sources to support enforcement  activities are being examined and
will be addressed as part of the adoption process.
                               A-60

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WSDOT Highway Runoff

The County cannot at this time commit to taking the lead on writing
and  submitting  a "Roadside  Management Plan"  proposal to WSDOT.
Such an activity may receive higher priority as watershed planning
efforts continue.   However,  upon completion of the Indian/Moxlie
stormwater study, Thurston County's recommendations to the City of
Olympia could potentially include a suggestion that such a plan be
proposed.

Environmental Education

Informational  materials containing local  ordinances, policies,
educational information, BMPs,  building code information, etc. are
indeed valuable to developers,  design reviewers, zoning officials,
etc.  The County will continue the  longterm project of organizing
and  providing  informational handbooks  to staff  and  the  public.
Though many  of  the materials would (in varying degrees)  address
environmental protection,  there  are no plans to compile a manual
with water quality  issues  as its primary  focus.

As  part  of  the  watershed  planning efforts,  the County  would
consider televising a Commission meeting during which environmental
issues in the Budd/Deschutes basin  would  be the focus. This could
be  carried out  as  an element of  the  "Public Information  Plan"
portion of the program.

Priest Point Park is a City of Olympia park.

Fecal Contamination

To the extent funding will  allow, the County is willing to formally
encourage  citizens to  conduct  volunteer  shellfish  sampling,
specifically targeting residents living near "package" wastewater
treatment plants.

When high  levels of fecal  contamination are detected, the County
typically  performs  follow-up activities,  including sampling,  in
order to identify the source.

I hope this letter  adequately responds to your questions.   We are
extremely supportive of the work on the Budd Inlet Action

                                        Sincerely,
                                        Linda Hoffman,
                                        Director
                               A-61

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                     MAINTENANCE POLICY DEVELOPMENT
                                SCOPE OF WORK
PROJECT OVERVIEW:

Most private drainage facilities within the County receive little or no maintenance.
When a problem with these facilities develops, most people turn to the County for
assistance.  At the present time, the County is unable to provide maintenance assistance,
and generally provides only minimal technical assistance. New policies will be developed
relating to the maintenance responsibilities of private drainage facilities, and the funding
for maintenance expense.  These policies will be developed in coordination with the
Surface Water Commission, Road Division and Drainage Districts.

Private drainage facilities that fall under this scope  of work include retention/detention
ponds in subdivisions, catch basins, vaults in commercial/industrial facilities, old drainage
district ditches, private drainage ponds, swales, wetlands, culverts and others.  Most
private facilities are usually working in conjunction  with some public facility.

In addition to a lack of policies relating to private facility maintenance, there is a great
need to improve the public response process for service requests.  At this time there is
frequently confusion on how drainage requests should be responded to.  This project is
detailed in the Drainage Complaint Response Scope of Work.

TASK 1. PRIVATE FACILITY DATA BASE

      To develop policies pertaining to private drainage facilities, we need to  identify
      how many, what type, what condition, and who maintains the existing facilities.
      The data base will be limited to the existing  surface water area boundary, and
      may be further restricted to identified problem areas.

   o 'There will be a significant amount of data that is unavailable, and the policy
      development will be based somewhat on "best guesses".

   o Review existing inventory put together by students.

   o Gather all drainage  district X-sections, boundary, and topo info from assessor's.

   o Contact local consultants regarding drainage plans for facilities for mini markets,
      offices, shops, etc.

   o Contact DOE to determine if any discharge  permits are issued within the
      boundary.

   o Contact private pumpers to obtain a list of customers.

   o Contact attorneys to obtain list of private drainage litigations.
                                     A-62

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MAINTENANCE POLICY DEVELOPMENT
SCOPE OF WORK
PAGE 2
TASK 1, CONTD.

   o  Review any new inventory information and enter into the data base (includes field
      review).

   o  Gather copies of past drainage maintenance requests.

   o  Gather all existing regulations and policies pertaining to drainage facilities in
      Thurston County (RCWs, UBC, Comp. plan, Platting Subdivision Ordinance,
      etc.).

   o  Gather maintenance information from other jurisdictions.

   o  Gather any past correspondence from prosecutor's office relating to drainage
      problems, obtain any case law.

   o  Interview County Staff for a list of past drainage complaints/problems in the
      North County area.

                              TOTAL HOURS:  250
                              ESTIMATED COMPLETION DATE: July 1990
TASK 2.  MAINTENANCE POLICY DEVELOPMENT

   o  Develop maintenance action criteria, ie: County facility damage, private property
      damage, ground/surface water contamination, etc.

   o  Compare level of maintenance problem to action criteria, to develop an action
      prioritization list.

   o  Identify general categories of maintenance needs, then prepare a maintenance
      frequency and cost estimate.

   o  Review legal responsibilities & prohibitions with prosecutor's office.

   o  Draft private facility maintenance schedule, cost, responsibility alternatives.

                             TOTAL HOURS: 115
                             ESTIMATED COMPLETION DATE:  August 1990
                                   A-63

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MAINTENANCE POLICY DEVELOPMENT
SCOPE OF WORK
PAGE 3
TASK 3.  MAINTENANCE POLICY REVIEW/APPROVAL

   o  Review the facility maintenance alternatives in-house: PW staff, OWQ, Policy
      Group, and Board.

   o  Make revisions.

   o  Meet with affected drainage districts to review alternatives and obtain input.

   o  Meet with Surface Water Commission to review alternatives and obtain input.

   o  Meet with Tom Clingman to review alternatives and see how that fits in with the
      rate proposals.

   o  Meet directly with some homeowners associations to obtain their input.

   o  Conduct a survey of homeowners?

   o  Prepare a summary of special interest groups comments and recommendations,
      prepare a staff recommendation to take to Policy Group, then Board.

   o  Policy Group and Board briefings.

   o  Draft final maintenance policy.

   o  Follow-up with Tom Clingman regarding rate implications.

                             TOTAL HOURS:  160
                             ESTIMATED COMPLETION DATE:  October 1990
                                    A-64

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PROJECT/TASKS

VACTOR WASTE

1. Preliminary Report Complete

2. Engineering Report Complete

3. Review/Design Selection
PRELIMINARY    NEW
SCHEDULE     SCHEDULE
 May 7

Mid-June

 July
4. Final Facility Design Complete    Mid-October
5. Bid Package Prepared;
     Contract Awarded
COMPLAINT RESPONSE/MAINTENANCE
   POLICY DEVELOPMENT
1. Collect Data for Policy
     Development

2. Complete Policy Development *

3. Complete Maintenance Policy
     Review and Approval

4. Complete Complaint Response
     Policies and Procedures
  May
      October

      January


      May, 1991
 May?

August

September

January
Mid-December    May, 1991
June/July
* The data collection may take longer than July, due to
  staffing. We run some risk of developing policy without
  the full information gathered.
     August

     Mid-October


     Mid-June
                                 A-65

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GRANT NO.  TAX 91004
PROJECT TITLE: BUDD/DES CHUTES WATERSHED MONITORING
GRANTEE NAME:  THURSTON COUNTY HEALTH DEPARTMENT

                              PROJECT DESCRIPTION

In compliance with the Puget Sound Water Quality Management Plan, the GRANTEE
undertook a ranking of its Puget  Sound watersheds in 1988.  Because three of
the Thurston County watersheds (Henderson, Eld, and Totten/Little Skookum)
were already designated as Early  Action Watersheds, only the Budd/Deschutes
and Nisqually watersheds  remained to be ranked.  The Thurston County Watershed
Ranking Committee prioritized the Budd/Deschutes watershed as the number 1
priority for the development of a watershed action plan to deal with and
control non-point sources of pollution and protect beneficial uses.

Prior to establishing a watershed committee to develop an action plan, the
GRANTEE recognized the fundamental need to gather as much information as
possible regarding the current water quality status in the watershed.  The
purpose of this project is to characterize the water quality in the basin and
identify the major influences detrimentally impacting water quality.  The
resulting project will provide a  basis for the watershed committee to develop
an action plan to address the non-point sources of pollution identified within
the basin.

This grant will provide water quality data to be used in satisfying the
requirements of Chapter 400-12 WAC,  "Local Planning and Management of Nonpoint
Source Pollution."  A technical advisory committee will be formed to review
and comment on the various aspects of this project.  Following the completion
of this water quality data collection project, the next phase will be to form
the Watershed Management  Committee who will use this and other data to form
the Budd-Deschutes Watershed Management Plan.

                                 SCOPE OF WORK
TASK 1  - DATA nOT.T.gnTlQN AND ANALYSIS PLAN

The GRANTEE will  develop a Data  Collection and Analysis Plan  (DCAP) and a
Quality Assurance/Qxiality Control  (QA/QC) Plan which will outline the sampling
stations, parameters,  frequency,  timing, protocols, and- other  information as
needed.  The DEPARTMENT will review, comment and approve the plans according
to the  draft report  "Guidelines  and Specifications for Preparing Quality
Assurance Project Plans" dated January  5, 1990.  The DCAP will be developed
from a  review of  existing information on the basin water quality.  This
information will  be  drawn from a number of sources including  those applicable
sources listed  in the  List of  References for the Thurston Countv Watershed
Ranking Committee Final Report.  November. 1988.  Sampling stations and
sampling and analysis  methods  will be consistent with the applicable
requirements of the  DEPARTMENT publication "Guidance for Conducting Water
Quality Assessments".   This document further refers to following the guidance


                                      A-66

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GRANT NO.  TAX 91004
PROJECT TITLE: BUDD/DESCHUTES WATERSHED MONITORING
GRANTEE NAME:  THURSTON  COUNTY HEALTH DEPARTMENT

in the Puget Sound  Estuary Program's Protocols, where applicable.  The purpose
of following the applicable requirements of these documents ensures
consistency in the  type  of water quality data collected in the Puget Sound
region.

Completion Date:  October 31, 1990

Estimated Cost:   $9,960

Required Performance:

      A.    Data Collection and Analysis Plan

      B.    Quality Assurance/Quality Control Plan


TASK 2 - WATER QUALITY DATA COLT.FCTION

Task 2 cannot be started until the products of Task 1 have been approved by
the DEPARTMENT.  The GRANTEE will conduct water quality monitoring efforts in
accordance with the approved DCAP and QA/QC developed in Task 1.  While the
DCAP will fully describe the activities to be accomplished under this task, it
is currently envisioned  this effort would include routine ambient monitoring
throughout the watershed as well as more intensive monitoring in areas of
concern in attempts to identify pollution sources.  The area encompassed by
this monitoring effort would include Budd Inlet, .Capitol Lake, and the
Deschutes River basin south to the Lewis County boundary.   Parameters most
likely to be included in the effort include:

      fecal coliform
      temperature
      dissolved oxygen
      c onduc t ivi ty
      Ph
      turbidity (at selected stations)
      nutrients (at selected stations)
      chemical analysis  of sediments (one-time grab samples at selected
      locations)

Completion Date:  November 30, 1991

Estimated Cost:   $251,509

Required Performance:  Quarterly reports to the DEPARTMENT, which include all
the data collected  and analyzed to that time.   These quarterly reports are due
15 days after the end of the calendar quarter.  After the end of the first
year of data collection, that data will be presented in a report for
presentation to the project technical advisory committee (TAG).  The purpose
                                     A-67

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GRANT NO. TAX 91004
PROJECT TITLE: BUDD/DESCHUTES WATERSHED MONITORING
GRANTEE NAME:  THURSTON COUNTY PUBLIC HEALTH

of the TAG meeting will be to determine if the monitoring program is providing
the information that is needed to develop the watershed action plan that will
follow this project.  Further information on the annual report format is given
in SPECIAL CONDITION 11.
TASK 3 - UPPER DESCHUTES CHANNEL CHARACTERIZATION

The draft River Basin Team report on the Deschutes basin identified
sedimentation problems  in the upper Deschutes watershed as one of the most
significant impacts to  the river's water quality.  In order to better quantify
this issue, special emphasis will be placed on gathering data relative to
stream channel characterization in the upper watershed.  This task will
include:

      o     Collection  of hydrological data including rainfall, stream flows
            and discharge.
      o     Collection  of physical data including substrate,  bank stability,
            fine sediment embeddedness,  large organic debris, fish habitat
            units, stream width and depth, gradient,  and total suspended
            solids.
      o     Development of a stream mapping system which indicates adjacent
            land uses,  erosion source, riparian vegetation, and instream
            resources.

Completion Date:  August 31, 1991

Estimated Cost:   $51,650

Required Performance:   Task 3 data report including an evaluation plan to
outline an effective means of using the collected data for future watershed
planning activities and identifying watershed rehabilitation projects.


TASK 4:  DEVELOPMENT OF BACKGROUND INFORMATION

The GRANTEE will prepare the following information to be used by the Watershed
Management Committee to develop a watershed action plan in the next phase
following this grant  :

      o     summary of  land use trends,  activities and projections
      o     discussion  of beneficial uses
      o     program development plan which will provide a scope of work for
            the development of the watershed action plan by the future
            watershed management committee

The GRANTEE will ensure that this task does not duplicate efforts of the River
Basin Team Study.
                                     A-68

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GRANT NO. TAX 91004
PROJECT TITLE: BUDD/DESCHUTES WATERSHED MONITORING
GRANTEE NAME:  THURSTON  COUNTY HEALTH DEPARTMENT

Completion Date:  September 31, 1991

Estimated cost:    $11,543

Required Performance;

      A.    Development  of background information which will be incorporated
            into the  final water quality report (Task 5).

      B.    Development  of a program plan outlining a scope of work for
            development  of the watershed action plan and funding strategy for
            the next  phase of watershed management.


TASK 5:  WATER QUALITY REPORT DEVELOPMENT

The GRANTEE will develop a comprehensive water quality report for the
Budd/Deschutes watershed describing the data and information resulting from
the efforts of Tasks  1,  2, 3, and 4 above.   The report will be intended for
use by the Watershed  Management Committee in developing an Action Plan for the
watershed.  The report will provide background information on the watershed
area, summarize the sources of nonpoint pollution identified through the
project's efforts, and describe the overall status of the  water quality in the
basin.  This data will be used in the next phase to develop a water quality
assessment according  to  the requirements of Chapter 400-12 WAC.

Completion Date:  January 31, 1992

Estimated Cost:   $25,578

Required Performance:  Final water quality report for the  Budd/Deschutes
watershed.


TASK 6:  GRANT MANAGEMENT. COORDINATION AND PROGRAM SUPPORT

The GRANTEE shall provide overall grant administration and operational support
for the undertaking of this grant project.   Elements of this task include:

      o     provide overall grant and subcontract management
      o     provide grant accounting and liaison with Ecology
      o     coordinate and monitor the progress of various tasks and elements
      o     provide secretarial, office, and goods and services support for
            all related  grant activities of the Health Department and Office
            of Water  Quality
      o     coordinate with the PSWQA and other agencies or jurisdictions on
            programs  and activities related to the watershed program (eg.
            stormwater plans,  Capitol Lake  wetlands feasibility study, Budd
                                    A-69

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GRANT NO. TAX 91004
PROJECT TITLE: BUDD/DESCHUTES WATERSHED MONITORING
GRANTEE NAME:  THURSTON COUNTY HEALTH DEPARTMENT

            Inlet Urban Bay Action Plan, etc.).
      o     A technical advisory committee (TAG) will  be  formed to review and
            comment: on various aspects of the project  including the data
            collection program, whether it needs to  be modified during the
            project and how the data will meet the needs  of the project.   The
            membership of the TAG will be selected by  the GRANTEE upon
            approval by the DEPARTMENT.

Estimated Cost:   $69,760

Required Performance:

      A.    quarterly and final reports to the DEPARTMENT
      B.    periodic billings
      C.    maintenance of records sufficient for audit
      D.    meetings of the TAG as needed
                                    A-70

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MISTIME o. GRECOIRE
   Director
                                     STATE OF WASHINGTON

                               DEPARTMENT  OF  ECOLOGY
               7272 Cleanwater Lane. LU-n  •  Olympia. Washington 98504-6811  •  (206^ 753-2353
                                      June 6, 1990

         Dick Malin,  Dir.
         Engineering & Planning
         Port of  Olympia
         P.O. Box 827
         Olympia, .WA  98507

         Dear Dick,

         Thank you for meeting with Michael Jacobson (PTZ) and me in March.
         Several  planned Port activities exemplify a strong willingness to ensure
         required environmental protection programs are put into place. In
         keeping  with these efforts, we discussed in our meeting actions that
         might be taken to complement and expedite existing programs.  As a
         followup to the meeting, I have summarized below several of those
         potential activities which we hope become part of the draft Budd Inlet
         Action Plan.  Please respond to the following meeting summary and
         questions,  including  (where applicable) target dates, potential funding
         sources, as well as resource constraints and/or other limiting factors.
         Please also clarify any inaccuracies found below.

         East Bay Marine Sewage Pumpout Facility

         The Port recognizes that the marine sewage pumpout facility at East Bay
         Marina is frequently inoperative.   To remedy this, funding for a booster
         pump is  to be included in the Port's 1990 budget.   The booster pump
         will be  in operation in late-spring or early-summer, 1990.  Baa the Port
         applied  for a State Parks and Recreation grant to fund the project?
         Please provide a specific target date for Installation.

         East Bav Dissolved Oxygen Monitors and Aerators

         As a condition of dredging for East Bay Marina, the Port is responsible
         for the  operation and maintenance of continuous dissolved oxygen (DO)
         monitors and aerators located there.  Because the monitors are not
         reliable,  the Corps allowed the Port to conduct manual titrations using
         the "Winkler" method.  This method cannot be considered continuous
         monitoring,  as required, and is performed on an irregular schedule
         through  critical late-summer months.  This year, the Corps provided the
         Port with a portable DO probe with which to conduct a more in-depth
         water quality analysis,  and to thus determine how effective the aerators
         are.  Does the Port plan to continue to perform manual titrations In
         addition to using the portable probe?  For either or both methods, will
         the Port agree to follow a detailed monitoring schedule, particularly
         during critical summer uiuncnsr  J..L avaxj-ouj-e, please provxue <-n<=
         schedule you anticipate using.
                                             A-71

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Dick Malin
June 6, 1990
Page 2
A related issue is that of marina live-aboards turning off aerators
during evening hours.  Boat owners frequently shut the aerators off,
stating the equipment is noisy and stirs waters to a foam that adheres
to boathulls.  Port staff assert the switchbox cannot be locked for
safety reasons.  Will the Port agree to install mufflers on the system
or to address this problem in another way?   Will the Port also place
nearby educational signs stating the purpose and necessity of the
aerators?  How soon can this be done?

Stormwater Management / NPDES Permit Application

The Port has hired a consultant to design a sampling plan for gathering
information needed to determine NPDES permit limitations and necessary
treatment for stormwater.  When will sampling be conducted and when will
the data be available?  Please give a target date for submitting the
NPDES permit application.  When finalized, please also provide the
sampling plan, as recommended by your consultant.

The Port is to be commended for completing several logyard paving
projects aimed to reduce Port property pollutants from entering Budd
Inlet.  A sizeable log storage area is still in need of paving.  Please
provide a target date for budgeting and completing this project.

Underground Storage Tank (UST^ Removal

In this year's budget, the Port allocated funding to remove remaining
USTs.  Please provide a target date for completing this project.

Land Lease Requirements

The Port is very interested in ensuring tenants meet requirements of all
environmental laws and policies to prevent further contamination to
Port-owned property.  In keeping with this, will the Port include
in lease language references to local, state  and federal natural
resource agency requirements  (e.g., AST and storm water BMPs, water
quality technical guidance for log sort yards, and/or a blanket
statement)?
Navigation Channel Dredging

The Port will fund 50% of studies needed prior to Corps-sponsored
navigation channel widening project.  Does this 50% also apply to
mitigation projects?
                                     A-72

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Dick Malin
June 6, 1990
Page 3
West Bav Loaraftino

Lografting over Port-owned tidelands in West Bay directly affects
habitat used by juvenile salmonids.  The Port considers lografting in
West Bay to be "market driven" and does not know of any authority it may
have to minimize this practice.  Are there ways in which the Fort could
reduce the need for this practice?  If so, what are they and when might
they be implemented?

Cascade Pole

The Port will conduct sediment sampling off the north end of the Cascade
Pole site.  The data will not only be used to determine a final cleanup
plan, but will also be a valuable addition to the Budd Inlet database.
What is the schedule for this sampling?

The Port is also organizing a committee to garner citizen input for Port
decisions made on Cascade Pole cleanup activities.  Has a decision boon
•after on how this group will function and on what their specific purpose
will be?  Do you anticipate the group will apply for a Public
Information and Education (PIE) award from the Puget Sound Water Quality
Authority?  Will the Port formally encourage the group to coordinate
closely with the Budd Inlet Citizen Advisory Committee on issues
relating to the Cascade Pole site?

              Education
The Port owns, operates and maintains a marine sewage pumpout at East
Bay Marina.  The pumpout is well posted with user instructions provided
by the State Department of Parks and Recreation.  In addition to these
signs, State Parks and Recreation now also provides environmental
interpretation signs for use at pumpout sites and other marina areas.
Will the City post one of these signs at Bast Bay Marina?

East Bav Sediment Fill '

According to Section 404 of the Clean Water Act, fill material on the
southeast portion of the Port peninsula is to be developed for water
dependent uses.  Several development proposals indicate the fill is
being considered for siting non-water dependent developments.  How do
these plans conform to the Section 404 dredging permit?

Thank you again for taking time out of your busy schedule to meet with
us and to respond to this letter.  Similar letters are being sent to
other Budd Inlet workgroup members.  These letters and their responses
will be assembled and mailed as a packet to all workgroup and citizen
advisory committee members.  The packet will also be included as an
appendix to the final Budd Inlet Action Plan.
                                   A-73

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Dick Malin
June 6, 1990
Page 4
Please submit your written response by June 22, 1990.  Also, please feel
free to call me with any questions and/or if you wish to discuss any
part of this letter (586-5554).

                                   Sincerely,
                                   Melany Vorass
                                   Budd Inlet Action
                                    Plan Coordinator
cc:  Eric Egge, Port of Olympia
     Bill Backous, Ecology
                                    A-74

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Commissioners
J.D. "Jim" Wright
O.R. "Ray." Dinsmore
Sam Bradley, Ph.D.

Executive Director
Douglas P. Edison
915 Washington St. N.E.
Post Office Box 827
Olympia, Washington 98507-0827
206 586-6150
FAX 586-4653
                                                                   PORT OF OLYMPIA USA
                                                                                August 10, 1990
      Department of Ecology
      7272 Cleanwater Lane, LU-11
      Olympia, WA  98504-6811

      Attention:     Melany Vorass

      Dear Melany:

      I am responding to your letter of June 6, regarding activities at the Port and the Budd Inlet Action
      Plan.

      East Bay Marina Sewage Pumpout Facility:

             Application was made to State  Parks  & Recreation for a grant to  replace the existing
             pumpout facility. As soon as a grant is confirmed, we will implement  a contract to replace
             the existing system.

      East Bay Dissolved Oxygen Monitors and Aerators:

             We plan to continue to perform  manual titrations  throughout the critical period.  We are
             currently sampling twice weekly in the early mornings because DO levels still remain high.
             As  DO levels fall, we will switch to daily sampling.  Results are reported to the Corps as
             soon as the titrations are completed.

             There is no practical way to muffle the  noise from these aerators, though we have looked
             into many possibilities.  We would have no problem with installing some sort of educational
             signage nearby. We could try signage at each switch box and see if this is effective.

      Stormwater Management/NPDES Permit Application:

             Sampling will be conducted during this winter's rainy season.  A sampling plan will be
             submitted to Ecology prior to the rainy  season.  A copy will be forwarded to you.

             Continued capital improvements on yard paving and drainage will  depend upon the fiscal
             impact to the Port of the Cascade Pole cleanup.  Much of the Port's funding is going to be
             directed at this cleanup effort.  Given the limited capital funding outside of this effort, we
             will continue to pursue our paving and  storm drainage program.
      a:rm081001.90
                                                  A-75

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Ms. Melany Vorass                                                        August 10, 1990
Department of Ecology                                                              Page 2
Underground Storage Tank (LIST) Removal:

       The last two remaining underground fuel tanks are slated for removal in late August or early
       September of this year.

Land Lease Requirements:

       Below is the standard language included in Port of Olympia leases:

       "PETROLEUM, DANGEROUS, TOXIC AND HAZARDOUS MATERIALS.   Tenant agrees to
       abide by all federal, state and local  laws  pertaining to the handling,  storage, use and
       transportation of petroleum, dangerous, hazardous and toxic materials.  (For purposes of
       this Agreement, wood waste shall be considered a dangerous material to be handled in
       accordance with the Department of Ecology's requirements or guidelines for wood waste
       disposal.)   Tenant further agrees in the event of any occurrence in violation of such laws
       (including   but not  limited to,  any action  resulting  in a  spill, emission, accumulation,
       contamination or fire, whether discovered during the term of this Lease or after termination
       or renewal thereof), Tenant shall take all steps required by law  and the appropriate
       authorities to  clean  up and restore the premises, and any  other contaminated or affected
       area, to the satisfaction of said authorities and to provide a letter from said authorities to the
       Port certifying that the premises and affected areas have in fact been cleaned or restored
       and are presently in  compliance with all federal, state and local laws. Finally, Tenant agrees
       to indemnify the Port for any claims, damages, costs or professional fees  incurred by the
       Port by reason  of  any  event or occurrence  involving petroleum,  dangerous, toxic or
       hazardous  wastes directly or indirectly  attributable to Tenant's use of Port  property."

       In addition, please see attached Exhibit "A," also incorporated as part of the Port's standard
       lease document  language.

Navigation Channel Dredging:

       50% applies to studies done for the Feasibility Study. Actual mitigation under a federal
       project, if implemented, would be considered a project cost and would be funded at a 25%
       match by the Port.

West Bay Log Rafting:

       Log  rafting is done independently of Port operations and is beyond  the Port's administrative
       jurisdiction.

Cascade Pole:

       Sediment sampling  is scheduled to begin this  November.  A Sampling & Analysis Plan is
       to be submitted to Ecology for comment on August 27.
 a:rm081001.90
                                           A-76

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Ms. Me/any Vorass                                                        August 10, 1990
Department of Ecology                                                             Page 3

       The Port Commission has selected 6 members from a number of applicants to serve in an
       advisory nature to the Commission.  They will be making reports to the Commission as the
       study progresses.

       P.I.E. funding is not available to a Port Advisory group.

       The Port encourages the Advisory  Committee to  coordinate and receive  input from any
       group or individual. The Committee shares this viewpoint.

Environmental Education:

       The City will probably  not be involved in any signage,  but the Port of  Olympia would
       certainly cooperate in any educational signage associated with the pumpout facility.

East Bay Sediment FIJI:

       This issue is not resolved at this time.  We will respond at a later date.

If you have any further questions, please do not hesitate to contact me.

Sincer
 R. O. Malin, P.E.
 Director of Engineering & Planning

 Attach. -1

 ROM/cbr
 a:rm081001.90


                                           A-77

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Ms. Melany Vorass                                                         August 10, 1990
Department of Ecology                                                              Page 4

                                       EXHIBIT "A"
         TOXIC,  DANGEROUS AND HAZARDOUS SUBSTANCES STORAGE LICENSE
                        (License required for any material covered by
                       Dangerous Waste Regulations in WAC 173-303
                    as amended and 40 CFR Part 116-117 as amended,
                      copies are on file in the Port of Olympia offices)
Licensee:
Lease:
Term:	(Not to exceed 5 years.)
Fee:	
Insurance:	The Port must be named insured and
                                         entitled notice prior to cancellation.

Renewable:   For life of underlying lease so long as conditions below are met:

1.     Facilities approved for installation and use:
2.     Reconstruction approvals required:
3.     Preoccupancy approvals required:
4.     Inspections required:
       a.     	

       b.     At any time the Port has good reason to believe a problem may exist.
       c.     At a minimum, all tanks shall be pressure tested at least once every five (5) years
to assure no loss of  product into the environment (air, soil, surface or ground water).
5.     Materials authorized for storage:
       a.     	

       b.     Any additional materials require the consent of the Port.
6.     Additional terms:
       a.     The Port Engineer shall have the right to terminate this license at any time and in
his own  discretion, if the facilities fail to meet all federal, state or local requirements or otherwise
pose a hazard of unlawful contamination or pollution and such failures are not cured within thirty
(30) days of written notice or such  lesser time as appropriate under emergency circumstances.
       b.     The licensee agrees to bear all costs of  construction,  operation,  maintenance,
inspection or repair of the approved facilities and to keep the same in good operating repair during
the term  of this license, and the cost of any cleanup or other activities required in the  event of a
spill, leak or other pollution causing event.

a:rm081001.90
                                           A-78

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Ms. Me/any Vorass                                                         August 10, 1990
Department of Ecology                                                              Page 5

       c.      The licensee agrees at any time that the approved facilities cease to be subject to
a valid license agreement, for any reason, that the licensee shall, at its own cost, remove the
facilities and restore the site to its original condition (including removal of all contaminated soils or
water).
       d.      The Port shall have the right to terminate this license upon breach of any term herein
or termination  of the specified lease.  Breach of any term of this license shall constitute a breach
of the specified lease.
       e.      The  licensee shall compensate the Port for all costs  incurred by  reason of any
breach of this license.

UCENSEE:                                      PORT OF OLYMPIA;
By:	                 By: _
Title:	                Title:
License Date:
a:rm081001.90
                                          A-79

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A-80

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BCHRBTINE O. CRECCMRE
      Director
                                        STATE OF WASHINGTON

                                 DEPARTMENT OF ECOLOGY
                  7272 Cleanwater Lane, LU-11  •  Olympia, Washington 98504-6811  •  (206) 753-2353

                                          June 6, 1990
            Jerry Hendrichs
            Doug Baker
            City of Tumwater
            555 Israel Road SE
            Tumwater, WA  98502

            Dear Jerry and Doug:

            Thank you for meeting with Michael Jacobson (PTI Environmental Services)
            and me in February.  Several of Tumwater's current and planned
            activities exemplify a strong willingness to ensure progressive
            environmental protection programs are put into place at the local level.
            We discussed in our meeting actions that might be taken to complement
            these efforts.  As a followup to the meeting, I have summarized below
            several of those potential activities which we hope become part of the
            draft Budd Inlet Action Plan.  Please respond to the following meeting
            summary and questions, including (where applicable) target dates,
            potential funding sources, resource constraints and/or other comments on
            feasibility.  Please also clarify any inaccuracies found below.

            Regional Drainage Manual

            In conjunction with other local jurisdictions, the City of Tumwater is
            in the process of assembling a manual containing design criteria and
            other requirements for stormwater management.  The manual will be in use
            by August, 1990, and will be used for routine review of development.  To
            better ensure consistent use of the manual, will the City agree to adopt
            it by ordinance?

            The current draft manual does not define operation and maintenance
            requirements and to what extent education and enforcement are to be
            funded.  As part of the Action Flan, will staff agree to recommend to
            the City Council adopting and enforcing an ordinance (as part of the
            manual adoption or separately) or other means to ensure these elements
            of the program will be adequately funded for both private and public
            systems?  Also, will the City strongly encourage other jurisdictions to
            formally adopt a similar means of funding these elements?
                                                 A-81

-------
Jerry Hendricks
Doug Baker
June 6, 1990
Page 2
Percival Creek Storm Drain Studies

The City of Tumwater is working with the City of Olympia to conduct
storm drain studies in Percival Creek.   The study is to be completed by
the end of 1990,  and data will be used to prioritize capital improvement
needs.   To determine the longterm effectiveness of future capital
improvement projects, is the City of Tumwater willing to work with
Olympia to conduct sampling at regular intervals at locations sampled
during the study?

Capitol Lake Wetland Feasibility Study

The City is participating with other local and state agencies in
preparing a Capitol Lake wetland feasibility study for legislative
review.  As part of the study, and to make improvements in Percival
Cove, the lake will be drawn down in summer, 1990.  The County plans to
take advantage of the drawdown to conduct a storm drain survey.   Will
the City coordinate with Olympia and the County in developing the scope
of work so that data might also be used for source identification work
in Percival Creek?

Washington State Department of Transportation
Highway Runoff

The Washington State Department of Transportation (WSDOT) is currently
working with Ecology to develop and adopt a highway runoff manual.  The
manual will contain design and O&M requirements for new construction.
Current WSDOT design criteria may not meet local drainage manual
requirements.  Through watershed and urban bay planning activities,
Tumwater and other local jurisdictions  are dedicating many hours and
much money to protecting waterways from contaminants delivered by local
stormwater systems.  As you are aware,  WSDOT stormwater represents a
large portion of runoff to the Deschutes River, Capitol Lake,  Budd
Inlet,  and to local stormwater systems.   Because 1-5 and SR 101 are both
within watershed and urban bay management areas, local jurisdictions
have the opoprtunity to propose that WSDOT implement a more stringent
"Roadside Management Plan" within these areas.  In conjunction with
other local jurisdictions, will Tumwater agree to co-write and submit
such a proposal to WSDOT?  (A proposal  might be as easy and brief as
suggesting WSDOT meet the requirements  of the new local drainage
manual.)
                                 A-82

-------
Jerry Hendricks
Doug Baker
June 6, 1990
Page 3
Water Quality Policies and Ordinances

The City recognizes increased resources are needed in order to
adequately fund and staff inspection and enforcement activities to
ensure requirements are adhered to under the Shoreline Master Program,
SEPA conditions and building codes.  The City specifically recognizes
the need to increase resources to improve enforcement of new erosion and
sedimentation requirements.  Will City staff examine potential funding
sources for these activities and to submit recommendations to the City
Council?

Environmental Education

In addition to the regional drainage manual and the County's
environmental education library, a handbook containing water quality
policies (and possibly educational information, best management
practices, building code information, etc.) would be beneficial to
developers, to zoning officials and to staff responsible for design
review.  As an Action Plan element, will the City work with other local
jurisdictions to organize and distribute such a manual?

With the City of Olympia, Tumwater is conducting storm drain surveys to
identify problem drains and to prioritize capital improvement projects.
However, high priority capital improvements would probably not take
place until at least 1992, and lower priority drains may not be
addressed for some time after that.  Until the systems are upgraded,
public awareness of street-to-waterway drains should be increased.  Will
the City agree to help increase awareness by actively participating with
neighborhoods to initiate storm drain stencilling and waste
oil/antifreeze collection projects?  In addition to this, will the City
agree to assist other agencies in the distribution of storm drain
posters (provided by Ecology) to businesses?

The City of Olympia and Thurston County recently allocated funding for
time on a local cable TV channel.  Coverage for this year will include
County Commission and possibly City Council meetings to which viewers
will be able to phone in their questions.  Future meeting agendas are
being reviewed, and specific meetings will be identified as those most
likely to be aired.  Thurston regional growth has brought to the
forefront many environmental issues in need of citizen input.  Will the
City of Tumwater formally recommend that one or more of the televised
meetings include discussion on key environmental issues being addressed
by the City of Tumwater in the Budd/Deschutes basin?  Does the City of
Tumwater plan to fund televising council meetings?
                                  A-83

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Jerry Hendrlcks
Doug Baker
June 6, 1990
Page 4
Thank you again for taking time out of your busy schedules to meet with
us and to respond to this letter.  Similar letters are being sent to
other Budd Inlet workgroup members.  These letters and their responses
will be assembled and mailed as a packet to all workgroup and citizen
advisory committe members.  The packet will also be included as an
appenedix to the final Budd Inlet Action Plan.

Please submit your written response by June 22, 1990.   Also,  please feel
free to call me with any questions and/or if you wish to discuss any
part of this letter (586-5554).
                                   Sincerely,
                                   Melany Vorass
                                   Budd Inlet Action
                                   Plan Coordinator
cc:  Harold Robertson
     Thurston Regional Planning
                                  A-84

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555 ISRAEL ROAD S.W.
TUMWATHR, WA 98501

206/754-5855
INFORMATION
206/754-4 UO
MAYOR
COUNCIL
CITY ADMINISTRATOR
206/754-4130
FINANCE DIRECTOR
206/754-4133
UTILITIES
206/754-4140
ENGINEERING
PUBLIC WORKS
2o6,754.4i80                             Washington's First Community.
COMMUNITY DEVELOPMENT                           Ti-ina  OK  1QOH
PLANNING                                    «J U«e  Z 3 ,  17 7 U
BUILDING
PARKS &, RECREATION
206/754-4170
FIRE DEPARTMENT
206/754-4200
POLICE DEPARTMENT

206/754.4190  MS  . Melaney Vorass
MUNIC1PAL COURT  ..    -   J
       Budd Inlet Action Plan Coordinator

       Department of Ecology

       7272 Clearwater Lane,  LU-11

       Olympia,  WA  98504-6811


       SUBJECT:   Budd Inlet  Action Plan


       Dear Ms.  Vorass:


       Jerry  Hendricks  and I  have reviewed your letter of  June 6,  1990

       asking for specific Tumwater commitments in implementing the  Budd

       Inlet  Action Plan.


       Before outlining  our  responses  to , your  specific   questions  on

       commitments, I should make clear that most of these items will  take

       review and approval from the  City's Mayor and City  Council given

       the substantial policy decisions  involved.
       Question;    To better ensure  the consistent  use of  the Tumwater
       Stormwater Management Manual,  will the  City agree  to adopt  it by
       ordinance?

       Response;  Yes.   Jerry Hendricks has intended that the implementing
       act be by ordinance.
       Question;   Will staff recommend to Council an ordinance be adopted
       to ensure that the Action Plan  elements  are implemented  for the
       Stormwater Manual  dealing  with operation, maintenance, education
       and enforcement for private and  public systems?

       Response;   Staff will probably do this, 2but we reserve the right
       to change direction  given  further study on these issues later this
       year.
                                        A-85

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Pnrnmitment »3

Question;  Will the City strongly encourage other jurisdictions to
formally adopt ordinances  and  fund similar stormwater management
programs ?

Response;    This  is  an  area  that  would  take  City  Council
authorization and I can't make a commitment on this topic.

Commitment *4
Question;   Regarding  the  Tumwater and  Olympia  storm  drainage
studies in Percival Creek, would the City be willing to work with
Olympia to conduct samplings at regular intervals to determine the
long-term effectiveness of future capital improvement projects?

Response ;   This could  be a budget  proposal put  forward  by the
Public Works  Department,  but  the  question  is what would  be the
cost?   Without such  a  cost   estimate,  a  commitment would  be
premature and in any event the  Mayor and City Council must approve
any commitment of funds.  Also, I would think that  DOE should also
be a partner in such monitoring venture.

Commitment $5
Question;   The County plans to conduct a  storm drain survey for
Capitol  Lake when  it is  drawn  down this  summer.    Is Tumwater
willing to work with  Olympia and the County to develop a scope of
work so that the data might also be used for source identification
work in Percival Creek?

Response ;   I am not  clear how this would  be accomplished since
Percival Creek is not part of the  Capitol Lake Project.

Commitment  4E6
Question;   In conjunction with  other local jurisdictions, would
Tumwater  agree  to co-write and submit a proposal to the WSDOT to
implement  a more  stringent  "Roadside  Management Plan" for  1-5 and
SR  101?

Response ;  This would be a proposal which I  and Director Hendricks
would  favor  and so this may be  possible.   City Council approval
would  be  needed to  authorize such  an  action.

Co™»titment ^7

Question;  Will the City staff examine potential funding  sources
for increased resources for inspection and enforcement activity
relating to the Shoreline Master Program, SEPA conditions, building
codes, and erosion/sedimentation requirements?

Response;  Yes.
                               A-86

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Comm-il-TiMvn-t ^8

Question;  Will  Tumwater work with  other local jurisdictions to
organize  and  distribute  a  Water  Quality  Policy  Handbook  to
developers,  zoning officials  and staff  responsible  for design
review?

Response;  Possibly.  This type of project could be a future item
for consideration in our Development Standards Program.
Questiont  Will Tumwater help increase citizen awareness of street-
to-waterway drains through such programs as drain stencilling and
oil/antifreeze  collection projects?

Response ;  Tes.  Public Works is prepared to recommend beginning
this in  1991.
Question;  Will Tumwater  formally recommend that the local access
TV channel air a show on environmental issues addressed by Tumwater
in the Budd/DesChutes River Basin?

Response ;  Such a recommendation would have to be approved by the
City Council.   I  am uncertain of the effectiveness of this media
approach .

Commitment ill

Question;  Does Tumwater plan to fund televising Council meetings?

Response ;  Not to my knowledge.

I hope that this letter is helpful in your completion of the Budd
Inlet Action Plan.   If you have any  questions, please contact me.
                               incej
                                   Baker, AICP, Director
                              Community and Economic Development
cc:  Leonard Smith
     Jerry Hendricks


Itr\db90105
                               A-87

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A-88

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^CHRISTINE O. GREGOIRE
      Direct ex
                                        STATE OF WASHINGTON

                                 DEPARTMENT OF ECOLOGY
                  7272 Cleanwater Lane, LU-n  •  Olympia, Washington 98504-6811  • (206) 753-2353
                                         June 6, 1990
            Hike Sharar
            Tom Kolby
            LOTT Regional Wastewater
             Treatment Plant
            P.O. Box 1967
            Olympia, WA  98507-1967

            Dear Mike and Tom:

            Thank you for meeting with me in February.  Several  of  LOTT's ongoing
            projects exemplify a strong willingness to ensure progressive
            environmental protection programs are put into place at the local level.
            In keeping with this enthusiasm, we discussed in our meeting actions
            that might be taken to complement existing programs.  As a followup to
            the meeting, I have summarized below several of those potential
            activities which we hope become part of the draft Budd  Inlet Action
            Plan.  Please respond to the following meeting summary  and questions,
            including (where applicable) target dates, potential funding sources, as
            well as resource constraints and/or other limiting factors.  Please also
            clarify any inaccuracies found below.

            Water and Sediment Quality Sampling & Analysis

            LOTT currently conducts sediment and water column sampling at 5 stations
            in Budd Inlet.  In order for the data to be used conclusively in other
            studies, sampling and lab protocols may need to be reviewed.  If LOTT's
            current sampling procedures differ from EPA's "Puget Sound Protocols"
            (which are currently widely used and accepted), will LOTT consider
            incorporating the EPA procedures?

            LOTT is in the process of having their lab accredited,  and have offered
            to add parameters to Sampling efforts, as needed.  Ecology is moving
            toward incorporating toxics requirements in new permits.  To obtain
            baseline data for LOTT's new permit in 1992, are there  plans to add new
            parameters to monthly water and sediment sampling and analysis; if so,
            what parameters?

            Nutrient Loading/Abatement Studies

            LOTT recognizes that documenting "before" and "after" conditions in Budd
            Inlet,  relative to LOTT's nitrogen removal effort, is critical to
            understanding the long-term environmental benefits achieved.  Earlier
            this year,  LOTT and the Squaxin Island Tribe co-wrote and submitted a
            Centennial Clean Water Fund (CCWF) grant proposal to partially fund a
                                              A-89

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Mike Sharar
Tom Kolby
June 6, 1990
Page 2
nutrient loading/abatement study that was to be largely sponsored by
Seagrant.  Because Seagrant monies were denied, LOTT withdrew the
proposal.  However, there remains considerable interest and support for
the study.  Can the Budd Inlet Action Plan state in certain terms that
LOTT plans to submit a retailored grant proposal during the next grant
application period?

Infiltration and Inflow (I&I) and Combined Sewer Overflow (CSO)
Reduction Plans

Per NPDES requirement, LOTT submitted to Ecology an I&I reduction plan
in December, 1989 which describes how storm water infiltration to the
sewer system will be minimized.   Ecology has also required LOTT to
submit a CSO reduction plan.   Definitions of CSOs differ between the
agencies, and LOTT believes the I&I plan could also be used to fulfill
the CSO Reduction Plan requirement.  LOTT plans to schedule a meeting
with Ecology to clarify requirements.  Please provide a specific target
date for the meeting or for otherwise addressing this issue.

WSDOT Highway Runoff

The Washington State Department of Transportation (WSDOT)  is currently
working with Ecology to develop and adopt a highway runoff manual.   The
manual will contain design and O&M requirements for new construction,
and will address water quantity and quality.  As you are aware,  WSDOT
stormwater infiltration represents a large portion of total runoff to
downtown Olympia sewer drains.  Because 1-5 and SR 101 are both within
watershed and urban bay management areas, local jurisdictions have the
opportunity to propose that WSDOT implement a more stringent "Roadside
Management Plan" within these areas.  Through the Budd Inlet Action
Plan, interagency work group (IAWG) members representing local
jurisdictions have been asked to consider drafting such a proposal.
Presumably. LOTT's I&I and CSO Reduction plans address highway runoff.
Within these plans or separately, will staff consider recommending to
LOTT administrators the adoption of roadside management plans as a
partial means to reducing I&I and CSO events?

Ultraviolet (UV) Disinfection Pilot Project

Under a CCWF grant, LOTT has undertaken a pilot project using
ultraviolet disinfection.   Currently, the plant's primary disinfection
system is through chlorination;  in the past, the plant has experimented
with the ozonation.   The pilot project was recently completed,  and LOTT
partners agreed to submit to Ecology a revised engineering plan which
will include UV disinfection.  To allow time for the necessary
revisions, Ecology has extended the deadline for submitting the
engineering plan by two months.   This extension will not alter the final
date by which LOTT must have its improved system on line.
                                  A-90

-------
Mike Sharar
Tom Kolby
June 6, 1990
Page 3
Pretreatment Program

LOTT submitted a pretreatment program plan to Ecology for approval.  The
plan met with general agreement between LOTT partners and, once approved
by Ecology, could be implemented almost immediately.  Under the plan,
LOTT will issue and administer pretreatment permits to facilities
discharging industrial wastes to the WWTP.  Please provide a schedule
for implementation and a current listing of dischargers.

Environmental Education

The County and other local jurisdictions recently allocated funding for
time on a local cable t.v. channel.  Coverage for this year will include
County Commission and City Council meetings, and viewers will be able to
phone in their questions.  Future meeting agendas are now being
reviewed, and specific meetings will be identified as those most likely
to be aired.  As rates increase to fund LOTT facility improvements,
citizens are becoming more interested in the plant's efficiency.
Advertising tours of the LOTT facility has not generated the desired
level of public interest.  Vill LOTT consider televising administrative
meetings and/or developing presentations on how citizens can reduce
waste to the plant and thus reduce their cost (or other educational
information) ?

Thank you again for taking time out of your busy schedules to meet with
us and to respond to this letter.  Similar letters are being sent to
other Budd Inlet workgroup members.  These letters and their responses
will be assembled and mailed as a packet to all workgroup and citizen
advisory committee members .  The packet will also be included as an
appendix to the final Budd Inlet Action Plan.

Please submit your written response by June 22, 1990.  Also, please feel
free to call me with any questions and/or if you wish to discuss any
part of this letter (586-5554).
                                    Sincerely,
                                   Melany Vorass
                                   Budd  Inlet Action
                                     Plan Coordinator
cc:  Rob Lowe, Industrial Waste Supv, LOTT
     Ross Allan, Plant Supervisor, LOTT
     Bill Backous, Ecology
     Pat Lee, Ecology
                                  A-91

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A-92

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LOTT                    P0- Box 1967                       a Partnership of
•" ^^ '  '                    Olympia, WA 98507                   Lacey
Wastewater                     (206) 753-8291                       Olympia
Management                    ,                                 Tumwater, and
Program                                                         Thurston County
August 21, 1990
Melany Vorass
Budd Inlet Action Plan Coordinator
Washington State Department of Ecology
7272 Cleanwater Lane, LU-11
Olympia, WA 98504-6811
Dear Melany:

The following is in response to your questions concerning various issues in the
Budd Inlet Action Plan.  In general, funding for all LOTT activities comes
from LOTT rate payers. Certain specific, primarily capital, programs receive
grant assistance from the Washington State Department of Ecology
Cleanwater Fund.  At present, the schedule for nearly all of our activities is
driven by the schedule included in our NPDES Permit.  Attachment "A" to
this letter is a summary copy of the current dates and activities in that permit.

The following information is arranged according to your letter.

Water and Sediment quality Sampling and Analysis

LOTT uses EPA's "Puget Sound Protocols" for testing.  Some testing is done
for which protocols are not yet available. LOTT will adopt these as they
become available.

LOTT initiated a Sediment and Water Sampling Program of the receiving
water.  In the current NPDES Permit, DOE makes the LOTT program a
requirement. LOTT has consistently asked DOE about other testing
parameters,  but we currently do not have any additional testing planned as we
have not heard of any new specific requirement.  We are aware of DOE's
interest  in more sediment testing.
                                 A-93

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Melany Vorass
Budd Inlet Action Plan Coordinator
Washington State Department of Ecology
Page 2
Nutrient Loading/Abatement Studies

LOTT did seek grant funding for an extension of the nutrient studies
preformed by Dr. Charles Boatman, which led to the nitrogen removal
requirement at LOTT. The grant request effort, in the spring of 1990, relied
substantially on Sea Grant funding which was denied.  This denial forced us to
withdraw our request for Centennial Cleanwater Funds since without the Sea
Grant monies the research program was incomplete.

Work is underway by Dr. Charles  Boatman to redesign the program so it can
be accomplished  without Sea Grant funding.  At this time, the LOTT Partners
have not pledged rate payer money to support additional nutrient research
since capital program requirements have already resulted in a doubling of the
LOTT rate between January of 1989, and January of 1990.

At this point, it would be inappropriate to say categorically that LOTT will
submit a revised  grant proposal during the next grant application period.
LOTT's application will be dependent on the total  funding package which can
be assembled.

Infiltration and Inflow (I&I) and Combined Sewer  Overflow (CSO) Reduction
Plans

As you will recall from our discussion, characteristics of the LOTT system
confound the normal understandings of I&I and CSO.  It is our intention to
meet with Ecology to see if we can reach an understanding concerning our
NPDES, CSO and I&I requirements which places the emphases on efforts to
mitigate inflow.

We have not pursued scheduling this meeting during spring or summer. We
are hopeful that by year end a meeting can be scheduled and resolution
reached.  Meanwhile, the City of Olympia is moving forward with inflow
reduction efforts  which have been documented in our regular NPDES
reporting.
                                A-94

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Melany Vorass
Budd Inlet Action Plan Coordinator
Washington State Department of Ecology
PageS
WSDOT Highway Runoff

LOTT's I&I reduction plans do not specifically address highway runoff. This
issue would be handled by appropriate partner jurisdictions, primarily the City
of Olympia.  You may wish to contact the City of Olympia Assistant Director
of Public Works, Mr. John Cunningham (753-8362), for more information.

Ultraviolet (UV) Disinfection Pilot Project

An initial test of ultraviolet disinfection was conducted by LOTT in
cooperation with Trojan Industries between the summer of 1988 and fall of
1989. As a result of that effort, the Department of Ecology urged the LOTT
partners to consider including ultraviolet disinfection in the upgrade of the
LOTT Treatment Plant with 50% funding from the Centennial Cleanwater
Fund. The LOTT partners conducted a 90 day preliminary design study in
spring of 1990 to determine the feasibility of ultraviolet disinfection at LOTT.
That effort resulted in the decision by the LOTT partners to include
ultraviolet disinfection in the upgrade.

Currently, the LOTT partners are  engaged in designing an ultraviolet
disinfection facility.  Part of that design is a pilot test which will determine the
size of the disinfection system to be installed at LOTT. That pilot study will
begin in September and run six months.

Consideration of ultraviolet disinfection effected numerous NPDES dates.
Attachment "A" is a summary of the schedule which resulted from those
considerations.

Pretreatment Program

There is no definite timetable for implementation of elements of the
pretreatment program.  Issuing of  Industrial Discharge Permits can begin
following approval of the program by the Department of Ecology and
adoption of legal authority for pretreatment regulation by the local agencies.
To date, we have not received DOE approval although we believe our
proposal meets all DOE requirements.
                                 A-95

-------
Melany Vorass
Budd Inlet Action Plan Coordinator
Washington State Department of Ecology
Page 4
The industrial waste survey identified the following significant industrial
dischargers:

Hardel Mutual Plywood - Georgia Pacific Corp. - Continental Can Co. - Pabst
Brewing Co. - Columbia Bottlers - Louis Kemp Seafoods - Ellehammer
Packaging - Dart Container Corp.

The Pabst Brewery, Continental Can and Georgia Pacific currently operate
under state permits and specific agreements with the local agencies.  These
existing agreements could be the basis for local Industrial Discharge Permits
when the program is implemented.

The survey also identified 25 minor dischargers including printers, photo
processors, and dry cleaners. Permits will be issued to significant and minor
dischargers.  Pretreatment may not be required of all permitted dischargers.
The Industrial Waste Survey will be continually updated to identify new
significant dischargers.

                             DEFINITIONS

(V)   SIGNIFICANT INDUSTRIAL USER OR DISCHARGER - An
      industrial user of the municipal sewer system who:

      1.     Is subject to national pretreatment standards promulgated  under
             Section 307(b) or (c) of the Clean Water Act;  or

      2.     Has in its wastes any priority toxic pollutants listed in 40 CFR
             part 403 or appendix A; or

      3.     Has in its wastes toxic pollutants  as defined pursuant to Section
             307  of the Act; or

      4.     Has a discharge flow of 25,000 gallons or more per average
             work day; or

      5.     Has a discharge flow greater than 5 percent of the flow in the
             City's wastewater treatment system; or
                                  A-96

-------
Melany Vorass
Budd Inlet Action Plan Coordinator
Washington State Department of Ecology
Page 5
      6.     Is determined by the Director to have a significant impact,
             either singly or in combination with other contributing
             industries, on the wastewater treatment system, the quality of
             sludge, the system's effluent quality, or air emissions generated
             by the system.

(j)    MINOR INDUSTRIAL DISCHARGER OR USER; a non-categorical
      industrial or commercial user of the POTW, identified by the Director
      as having the potential to spill or discharge chemicals or slugs of
      wastewater to the municipal wastewater system, or the potential to
      discharge a waste stream that, when taken into account with the waste
      streams of other industrial users, may have a significant impact  on the
      POTW.

Environmental Education

Advertising of Treatment Plant tours has not received a high response.
LOTT's work with the local schools, colleges, and interested citizens, however,
has been very successful. Tours are offered on a regular basis to schools and
an extremely high participation has been received.

The LOTT Advisory Committee is very interested in pursuing worthwhile
public information efforts.  Any proposals you may have will be welcome.
Our only limitation is the same you encounter everywhere:  staff and budget.
Please call us if you have other information needs.

Sincerely,
D. Michael Sharar
LOTT Project Administrator
Tom Kolby
LOTT Plant Manager

DMS/sd

Attachment
                                  A-97

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                         ATTACHMENT A
UV GO  REVISED
Resubmit Hydraulic
Engineering Report	  (Late Summer)

Submit Final PS&E for Review
and Approval
Hydraulic Improvements	  Oct 30, 1990

Submit Plan of Operation
Hydraulic Improvements	  Oct 30, 1990

Bid Award
Offsite Preload  	  Jan 30, 1991

Submit Draft PS&E for Review
Nitrogen Removal Facility  	 (Early Spring)

Submit Final PS&E for Review
Nitrogen Removal Facility  	Jun 1, 1991

Submit Plan of Operation
Nitrogen Removal Facility  	Jun 1, 1991

Bid Award                                          !
Offsite Land Pipeline	Aug 30, 1991

Bid Award
Nitrogen Removal Facility  	Oct 1, 1991

Bid Award
Offshore Pipeline	  Oct 30, 1991

Submit Final O&M Manual
Nitrogen Removal Facility  	Dec 1, 1992

Substantial Completion
Nitrogen Removal Facility  	Feb 28, 1993

Discontinue Routine Use
of Fiddlehead Discharge	Feb 28, 1993

Nitrogen Facility on-line
Meeting Discharge Limits	  June 1, 1993

Complete Construction
Nitrogen Removal Facility  	Aug 30, 1993

                                 A-98

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               APPENDIX B

Available Funding Sources: Urban Bay Action
           Plan Implementation

-------
      AVAILABLE FUNDING SOURCES:
 URBAN BAY ACTION PLAN IMPLEMENTATION
              April, 1990
Prepared £or the Department of Ecology
          by Jo Anr«,; Harrison
                  B-1

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                          INTRODUCTION
        The Washington State Department of Ecology  (Ecology)
recognizes that some  local governments with.limited  financial
resources face serious water pollution control  needs.  While the
trend in solving environmental problems is toward equal
responsibility between federal, state, and  local governments,
creative options in meeting local match requirements are
available to help communities take advantage of funding sources
without straining local revenues.  Ecology stands ready to assist
local governments in  exploring these options in order to solve
environmental problems in a manner that does not cause undue
financial hardship.

        "In-kind" expenses  (services or materials contributed to
the project by organizations or individuals) can count toward up
to half of the local  match for many grants.  The local share may
be funded by taxes, sales of bonds, formation and assessment of
Local Improvement Districts, user fees, fines and penalties,
construction permits  and grants or loans from other  state or
federal agencies.  The Washington State Revolving Fund (SRF) for
Water Pollution Control can provide low interest financing of
local match for state grants.  Grants from the Centennial Clean
Water Fund  (CCWF) and loans from SRF may be combined, so
applicants need only  deal with Ecology staff for complete
financing of water pollution control projects.

        The Washington State Legislature and the U.S. Congress
have passed major legislation to protect water  resources.  State
legislation includes  the Centennial Clean Water Fund and Aquatic
Lands Enhancement Account.  Federal legislation includes the
Clean Water Act and the Coastal Zone Management Act  of 1972.
Amendments are added  to the Clean Water Act as  the need arises.

        Brief descriptions of possible funding  sources for
implementation of urban bay action plans are presented here for
your information.  A  chart  listing grant and loan programs,
requirements, time  lines, and contact persons is attached.


        THE WASHINGTON STATE CENTENNIAL CLEAN WATER  FUND

        The Centennial Clean Water Fund  (CCWF)  is a  major source
of  financial assistance providing grants and loans for water
quality projects. The CCWF  is a partnership between  the state and
local governments.  Created by the state legislature in 1986, the
continuation of the  fund has been authorized through the year
2021.  The CCWF helps local communities meet water quality,
health and  safety requirements.  It is dedicated to  protecting
the waters  of Washington State for current  and  future
generations.
                                 B-2

-------
        Through the year 1995, 50 percent of the annual fund of
$45 million is earmarked for marine water facilities, which
include secondary sewage treatment plants, reduction of combined
sewer overflows (CSOs), stormwater discharges or other facilities
which empty directly  into marine waters.  Facilities receive a
base 50 percent of the total eligible cost;.an additional grant
and/or loan is possible if the local match would cause the
community financial hardship.  Most activities receive a grant
covering 75 percent of the total eligible project costs.  Other
funding categories include, nonpoint pollution control,
groundwater and freshwater projects.  Activities include
planning, research, monitoring and education.  In special cases,
the discretionary category can provide up to 100 percent of the
eligible project cost.  Strong local support and the seriousness
of the problem are rating criteria for grant and loan awards.


            THE WASHINGTON STATE REVOLVING FUND (SRF)
                   FOR WATER POLLUTION CONTROL

        The Washington State Revolving Fund (SRF)  for Water
Pollution Control provides low interest  loans for high priority
water quality needs.  Congress established the SRF as part of the
Clean Water Act Amendments of 1987 as a way to phase out federal
grants and phase in state loans.  The U.S. Environmental
Protection Agency  (EPA) will "seed" the SRF with yearly
capitalization grants, subject to Congressional appropriation,
until 1994.  The state must contribute 20 percent matching funds
during this period.   After 1994, federal and state capitalization
will end.  Loan repayments, with interest, will sustain the SRF
from then on in perpetuity.

        Eighty percent of the money is earmarked for the
planning, design or contruction of water pollution control
facilities.  Ten percent can go for nonpoint sources control
projects, and 10 percent of the SRF can go to conservation and
management projects for federally designated estuaries like Puget
Sound.  Projects in this category may include purchases of
wetlands, the construction of boat pumpout facilities and other
projects.  The SRF can provide financing for the local match for
state grants under certain conditions such as financial hardship.

        The sooner the borrower repays the SRF loan, the lower
the interest rate.  For now, for a 0-5 year term, no interest
will be charged; for  a 6-14 year term, the interest rate will be
4  percent; and, for a 15-20 year term, the interest rate will be
5  percent.  After  1992, SRF interest rates will be 60 percent-75
percent of the current market rate.  If  all federal requirements
are satisfied, SRF can provide refinancing of local funds already
spent on planning and design not covered by grants as well as
'financing to make up  some ineligible portions of state or federal
grants.
                              B-3

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               COASTAL ZONE MANAGEMENT 306 GRANTS

        Ecology's Shorelands and Coastal Zone Management Program
administers $400/000 in 306 grant funds annually (provided to
Ecology through the federal Coastal Zone Management Act) for
local shoreline master program (SMP)  improvements and special
shoreline projects.

        Preparation of SMP amendments, including public
involvement, legislative review and process necessary for local
adoption, can address such issues as: public access policies and
regulations; environment mapping and redesignations; waterfront
revitalization policies and standards; beach and dunes management
provisions; use activity provisions such as aquaculture, marinas,
etc.; site planning and design for public access improvements,
waterfront restoration and interpretive centers; and, public
information and education programs.  The grant project must
enhance the local shoreline master program, improve management of
shoreline resources and go beyond routine shoreline management
activities.


                           205J GRANTS

        Each year approximately $334,000 in grant funds is
provided to the state from the Federal Clean Water Act, subject
to Congressional appropriations.  Fifty percent of the funds go
to state agencies and 50 percent is available for pass-through to
local governments.  The grants cover water quality planning
activities only.  One of the current priorities is the
restoration and maintenance of a healthy and productive Puget
Sound.  Ecology can provide information on what is currently
available.
               GROUNDWATER MANAGEMENT AREA PROGRAM

        Centennial grants in the Groundwater Category are
 providing $5.5 million in funds for fiscal year (FY) 91.  Funding
 is  available for the designation of local Groundwater Management
 Areas  (GWMAs) and for protection of groundwater quality and
 quantity.
                 WASTE MANAGEMENT GRANT PROGRAMS

        Many grant programs are available to address waste
 management problems.  Hazardous waste planning grants provide
 financial assistance for updating local comprehensive hazardous
 waste  management plans.  Local health departments can apply for
 solid  waste enforcement grants.  Financial assistance is
                                B-4

-------
available for planning and carrying out household hazardous waste
collection events.  Local governments may apply  for financial
assistance for  installation of groundwater monitoring wells at
municipal landfills, for the purpose of identifying potential
contamination of groundwater.  Waste reduction and recycling
grants provide  funds for the design of programs  that promote
Washington's solid waste management priorities.

        In 1989 the Legislature authorized several new waste
reduction and recycling grants.  Projects include: tire
recycling, removal, and enforcement programs; developing public
informational materials; establishing the feasibility of
composting food and yard waste; Phases 2 and 3 - waste reduction
and recycling grants; and, hazardous waste planning
implementation  grants.

        Public  participation grants are available to citizen
groups of three or more persons and not-for-profit public
interest groups organized for the purpose of working on
environmental issues or providing public involvement services.
Citizen/Proponent negotiations grants can be awarded to local
governments affected by the development of a dangerous waste
management facility, to establish a citizen negotiating committee
that will discuss mitigation of potential impacts on the
community with  the facility proponent.


                AQUATIC LANDS ENHANCEMENT ACCODNT

        In 1984 the Legislature created the Aquatic Lands
Enhancement Account  (ALEA) .  The ALEA was established to provide
funding for state and local projects designed to enhance state-
owned aquatic lands by providing public access, recreation and
environmental protection.  The account is funded by lease revenue
received from various uses of state aquatic lands under the
Department of Natural Resources  (DNR).

        Projects may involve acquisition of marine tidelands
and/or adjacent uplands.  Examples of eligible public
access/recreation projects are: planting shellfish for
recreational use; creating water-oriented interpretive displays;
establishing open-water swimming areas; providing nonmotorized
boat launches and temporary moorage facilities; and building
fishing piers and reefs.

        ALEA projects in Whatcom County include  the acquisition
of approximately 300 linear feet of tidelands abutting Birch Bay
State Park and  expanding and improving an existing trail system
along Whatcom Creek in downtown Bellingham.  The Whatcom Creek
project includes a viewpoint and deck at the historic location of
an old mill.
                               B-5

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             AGRICULTURAL WATER SUPPLY LOANS/GRANTS

        Referendum 38, (approved by the voters in 1980) ,
authorizes the State Finance Committee to issue state General
Obligation Bonds, in the amount of $125 million for water supply
facilities.  Fifty million dollars of the authorization is to be
used for agricultural water supply facilities alone or in
combination with fishery, recreational, or other beneficial uses
of water.  The $50 million is to be administered by the
Department of Ecology.

        Ecology may use or permit the use of the bond proceeds,
subject to legislative appropriation, by direct expenditure, and
by grants or loans to public bodies.  This includes grants to
public bodies as matching funds in any case where federal, local,
or other funds are made available on a matching basis.


                         REMEDIAL ACTION

        Remedial action funds are available for investigation of
suspected hazardous waste sites and for the cleanup of confirmed
sites.  For fiscal year  (FY) 89-91, $15,902,000 was made
available to applicants.  Fifty thousand dollars is the ceiling
amount for routine cleanup and also for site hazard assessment.
Fifty percent funding is available for investigation and cleanup;
100 percent for routine cleanups and site hazard assessments;
and, for economically disadvantaged communities an additional 25
percent supplement may be awarded.
                                 B-6

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                                                         f UNO INC
Centennial
Clean Hater
Fund ICCWT)
Financial 4
technical a**l*tance
for water pollution
control activitiea
and facllitiea
                                                                  HEQUmEHEMTS
Only water
quality projectn
1/2 of local ahare
•uat coaw Iron local
aoutcea or loane
                                                            MCKT APPLICATION PERIOD


                                                            Jan. - rrb. Ittl
                                                                                                                          COHTACT*
                                                                                          Helen Breiler
                                                                                          (20«)«S*-»096
State
Revolving fund
lor Mater Polluttc
control ISRPI
tow intareat
loane (or
water pollution
control project*
Meet atate
Honpoint Plan
or Puget Sound
Plan if relevant
                                                            June - July t. !••!
Oan PIIIp
Coaatal tone
Management
)0t Granta
Planning franta
and apectal project*
to tn»lea»nt enorellne
•••tor pragma*
                                                                  Nrlte or call
                          Jan. - Peb. Ittl

                          Jan. - Peb. I*«I
                                                                                          Steve
                                                                                                                         Jio Scott
                                                                                                                                *-«7tt
JOVI Cranta
Planning  (or water
quality projecta
Planninf
activltiee only
                                                                                           Jen. - Peb.  Itti
                                                                                          Helen arealer
                                                                                          (20«)4S9-CO»«
Cround Mater
Hanaqeaent
Area Proerao
Por deal«nation of
CMMAa and protecti«
of froundwator
quality l quantity
Mutt be on
Ccoloqy'e
General Schedule
                                                                                           Onqoinq
                                                                                          Pouq  Ruehton
Household
Natardoua Maate
Col lection Eventa
Planninq and
carryinq out
collection day*
for boueeholde
                                                                  Call for info.
                                                           Tall lor deadline info.
                                                                                                                         Mike OruMiqht
Public
ParticipatU
 Inveatiqatlnq and
 ttmudying  haiardoua
 aubetance  releaae
 Cbptr.  in-J
 MAC or  grant
                                                                                            reb.  -  March  1»»1
                                                                                                                         Laurie Davies
Cittren/
Proponent
Negotiation*
Megotiationg
cooaittee to oeet
with proponent* of
danqerou* waate
            (acllltie*
 MAC I7J-JOJ-»02
 and grant
 guideline*
                                                                                            Ongoing
                                                                                          Laurie Oavie*
                                                                                          |IOt|4)*-7S«2
Aquatic Land*
Enhancrvrnt
Account
Land) acquisition,
public  accra*/
recreation project*
                                                                  Call for info.
                          June )0.  t«*i
                          Dead I me
                                                                                                                         Robert trandow
Aqrirultural
M«ter Supply
Loan/Grant
Agricultural
water  aupply
lacilitie*
                                                                  Call  for  info.
                                                                                           Call  tor deadline  info.
                                                        Ray Newklrk
                                                        |20tl«S*-41CS
•media!
Action
• Note: To calI ecology ataff <
 ui* •SIS' inatead of '4Jf or
 Inveatigatlon  and
 cleanup of hasardou*
 wa*t* aitee

* the SCAM ayfteo.
•4JI."
                                  MAC Chptr.
                                  J71-J72 and
                                  grant guideline*
                                                                                            Carly auener  Itti
                                                        Julia Mood*
                                                        |20«|4J*-72(S

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     APPENDIX C

Summary of South Sound
 Reconnaissance Study

-------
PTI
ENVIRONMENTAL SERVICES
15375 SE 30th Place
Suite 250
Bellevue, Washington 98007
RECONNAISSANCE SURVEY OF
CHEMICAL CONTAMINATION AND BIOLOGICAL EFFECTS
IN SOUTHERN PUGET SOUND
Prepared 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 C744-27
April 1991

-------
                      EXECUTIVE SUMMARY
    The U.S. Environmental Protection Agency (EPA) Region 10, through the
Office of Coastal Waters, has been responsible for the development and imple-
mentation of an estuary program for Puget Sound.   The present study is a
reconnaissance survey of chemical contamination (i.e., of sediments and biota)
and associated adverse biological effects  in southern Puget Sound.  Although
several recent studies  have provided comprehensive evaluations  of chemical
contamination and biological effects in central and northern Puget Sound, a
similar evaluation has been lacking for southern Puget Sound.  The present study
serves to fill this gap in the soundwide database.

    In the present study, a reconnaissance survey was conducted throughout the
embayments of southern Puget Sound using several of the indicators of chemical
contamination and biological effects  employed in recent surveys conducted in
central and northern Puget Sound.  Environmental conditions were  evaluated in
two urban embayments (i.e., Budd  Inlet and Oakland  Bay),  eight nonurban
embayments (i.e.,  Hammersley  Inlet, Totten Inlet, Eld Inlet, Henderson Inlet,
Case Inlet, Filucy Bay, Carr Inlet, and  Wollochet Bay), and three areas off the
main channel of the southern sound (i.e., two areas near Steilacoom and one area
in Cormorant Passage).  In each study area, stations were located in depositional
areas  where chemical contaminants  would be expected to accumulate  in sedi-
ments. To provide integrative assessments of contamination over relatively large
areas, all stations were located away from known contaminant sources.

    The indicators used to assess chemical contamination and biological effects
were  a subset of those used in the recent surveys conducted in central  and
northern Puget Sound.  Chemical contamination was evaluated in the sediments

-------
of Budd Inlet and in five areas outside Budd Inlet (i.e., Eld Inlet, Henderson
Inlet, Cormorant Passage, Carr Inlet, and Wollochet Bay). Additional sediment
samples were collected for chemical analysis in the other five areas of southern
Puget Sound, but were not analyzed because the results of the sediment toxicity
tests indicated that the sediments were not toxic.  Bioaccumulation of chemical
contaminants was evaluated by measuring the concentrations of chemicals in the
edible muscle tissue of  fish [i.e.,  English sole  (Parophrys vetulus) or  starry
flounder (Platichthys stellatus)} throughout the southern sound and in the whole
bodies of littleneck clams (Protothaca staminea) from Budd Inlet.  The primary
indicators of biological effects throughout the southern sound were the amphipod
mortality toxicity test  (using  Rhepoxynius  abronius)   and  histopathological
abnormalities in the livers of English sole.  Benthic macroinvertebrate  assem-
blages were sampled in Budd Inlet, but those samples were not analyzed because
the results of the sediment toxicity tests indicated that the  sediments were not
toxic.  Although not used explicitly as indicators of chemical contamination, the
characteristics of demersal fish and megainvertebrate assemblages captured at all
transects  were  described  and  compared.   Megainvertebrates  include large
organisms such as crabs, starfish, and sea cucumbers that are collected using an
otter trawl.

     Field sampling was conducted from 3 to 12 April  1990.  Sediment samples
for chemical and bioassay analyses were collected at 12 stations in Budd Inlet.
Sediment samples were also collected for chemical analysis in  12 areas outside
Budd Inlet.  Chemical analyses were subsequently conducted for five of these 12
areas (i.e.,  Eld Inlet, Henderson Inlet,  Cormorant  Passage,  Carr  Inlet, and
Wollochet Bay). The five areas were selected because they were located in areas
that have the potential of being contaminated (i.e., near the heads of embayments
or, for Cormorant Passage, near a shoreline discharge). Sediment samples were
also collected for bioassay analysis at 12 additional stations outside Budd Inlet.
Demersal fish assemblages were sampled for histopathological and bioaccumula-
                                     XI

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tion  analyses along seven transects throughout southern Puget Sound.  Clams
were collected for bioaccumulation analysis at two intertidal stations in Budd
Met.

     Because the present study was a reconnaissance survey, the data evaluation
focused on comparisons with the results of previous studies in Puget Sound.  A
limited  number  of site-specific comparisons were possible  by  evaluating the
historical data collected at stations close to  those sampled in the present study.
Many of the site-specific comparisons were made with data collected in southern
Puget Sound as  part of the  Puget Sound Ambient Monitoring Program (Tetra
Tech 1990). In addition, all results of the present study were placed in the larger
context  of Puget Sound as  a  whole  by making  comparisons with the  results
obtained for other parts of the sound or with benchmark values based on previous
studies throughout the sound.  The benchmark values are values derived from
information collected throughout the sound for various purposes (e.g., develop-
ment of sediment quality values, identification of potential health risks). Because
they are based on soundwide databases, they can be used to place the results of
area-specific studies (such as the present study) in a soundwide perspective.

     For sediment contamination, the benchmark values included various sediment
quality values such as apparent effects threshold (AET) values (Barrick et al.
1988), the maximum level (ML) and screening level (SL) values developed by the
Puget Sound Dredged Disposal Analysis  (PSDDA), and  numerical sediment
quality  standards for  Puget Sound issued  by the Washington Department of
Ecology.  All of these values are described in the text of this report. Specific
AET values used for comparison were the lowest AET (LAET) and highest AET
(HAET) values for the four biological indicators  having AET values for Puget
Sound (i.e., the amphipod mortality, bivalve larvae abnormality, and Microtox®
toxicity tests and alterations of benthic  macroinvertebrate assemblages).  The
benchmark values for sediment contamination also included the interim  perfor-
mance standards proposed for reference areas in Puget Sound (Pastorok et al.
                                   XII

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1989). For bioaccumulation, the benchmark values included the tissue chemical
concentrations of concern in Puget Sound identified by Tetra Tech (1988). For
the amphipod mortality toxicity test, the benchmark values included the interim
performance standards for Puget Sound reference areas  (Pastorok et al.  1989).
Although no benchmark values were available for histopathological abnormalities
in fishes, the results of the present study were placed in a soundwide context by
comparing them with the results obtained in previous studies from a variety of
environments throughout the sound.

    The remainder of this section summarizes the major results for  each of the
indicators of chemical contamination and biological effects evaluated in this study.
SEDIMENT CHEMISTRY
Metals

    Concentrations of metals in sediments sampled at the 17 stations in southern
Puget Sound were relatively low, and few of the existing sediment quality values
for the sound were exceeded.  No metal  concentration exceeded  a  LAET or
HAET value, a numerical sediment quality standard, or a PSDDA ML value.
However, several exceedances of PSDDA SL values were found. The SL value
for cadmium was  exceeded at seven stations in Budd  Inlet  and  at  the single
stations sampled in Eld Inlet  and Carr Inlet.  The SL  value for mercury was
exceeded at two stations in Budd Inlet.  The SL  values for silver and lead were
exceeded  at single stations in Budd Inlet.  Although  several  exceedances of
PSDDA SL values  were found, exceedances of the interim performance standards
for metals in reference areas of Puget Sound were relatively small for the nine
metals that have interim standards.  These results suggest that metals contami-
nation at the 17 stations was not substantial.  However,  sediments from stations
                                   XIII

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where SL values were exceeded would require biological testing before they could
be dredged and disposed of at unconfined, open-water disposal sites  in  Puget
Sound.
Organic Compounds

    All organic compounds were evaluated on the basis of dry-weight normal-
ization, which is the traditional method of expressing concentrations  for these
compounds.  In addition, nonionic organic compounds were evaluated  on the
basis  of organic-carbon normalization,  which more accurately assesses  the
potential bioavailability of these compounds.

    The concentrations of most organic compounds in sediments sampled at the
17 stations evaluated in southern Puget Sound were either undetected or relatively
low. However, high concentrations of phenol and 4-methylphenol were found at
numerous stations in Budd Inlet, and an unusually high concentration of tributyltin
(62 /ig/kg)  was found at a single station in that embayment.  Concentrations of
four of the organic compounds detected  in sediment samples from Budd Inlet
exceeded various sediment quality values for Puget  Sound.  Those compounds
included phenol, 4-methylphenol, p,p'-DDD, and indeno(l,2,3-cd)pyrene.

    On the basis of dry weight normalization, concentrations of phenol exceeded
the HART value at five stations and exceeded the LAET value at six additional
stations.  Concentrations of 4-methylphenol at two stations exceeded the LAET
value,  and  concentrations of p,p'-DDD exceeded the HAET value at a single
station.  On  the  basis of organic  carbon normalization,  concentrations  of
p,p'-DDD exceeded the LAET value at a single station.

    The numerical sediment quality standards were exceeded for phenol at 11
stations and for 4-methylphenol at 2 stations.
                                  XIV

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    PSDDA ML values were exceeded  for phenol  at five stations  and for
4-methylphenol at two stations. PSDDA SL values were exceeded for phenol at
six stations and for 4-methylphenol at three stations.  In addition, the SL value
for indeno(l,2,3-cd)pyrene was exceeded at a single station.

    Interim performance standards for organic compounds  in reference areas in
Puget Sound have been developed only for  total low molecular weight polycyclic
aromatic hydrocarbon (LPAH) compounds,  total high molecular weight polycyclic
aromatic hydrocarbon (HPAH) compounds, and total polychlorinated biphenyls
(PCBs).  In the present study, comparisons were made only  for total PCBs.
Comparisons were not made for total LPAH and total HPAH compounds because
most of the individual LPAH and HPAH  compounds  were not detected in the
present study.  Although the interim performance standard for total PCBs was
exceeded at two  stations (i.e., one in Budd Inlet and one in Henderson Inlet),
both values were considerably lower than the LAET value (i.e., the concentration
at which adverse biological effects would be expected).

    The results of the analysis of organic  compounds in sediments from the 17
stations  evaluated in  southern Puget  Sound suggest that although the observed
concentrations  of most compounds were  relatively low, phenol and 4-methyl-
phenol were present at concentrations  that may be  associated with  adverse
biological effects at numerous stations in Budd Inlet. In addition, p,p'-DDD was
present at a single station in Budd Inlet at concentrations that may be associated
with adverse biological effects.
                                   xv

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CHEMICAL CONTAMINANTS IN TISSUE
Fish
    Of the total of 94 chemicals evaluated in muscle tissue of English sole and
starry flounder, only four metals (i.e, arsenic, copper, lead,  and mercury) and
four organic compounds (i.e., total PCBs, di-n-butyl phthalate,  isophorone, and
benzole acid) were detected. The concentrations of all of these detected chemi-
cals, except di-n-butyl  phthalate,  were relatively low.  Four of these  eight
chemicals were identified by Tetra Tech (1988) as having a medium to high
priority with respect to potential concerns for health  risks to humans through
seafood consumption.  Those chemicals include two carcinogens (i.e., arsenic and
total PCBs) and two noncarcinogens (i.e., lead and mercury).

    Although a formal health  risk assessment was  beyond the  scope of the
present study, the health implications of the observed tissue concentrations of the
four priority chemicals were evaluated qualitatively by comparing them with the
results of the risk assessments conducted previously by Tetra Tech (1988).  Based
on this comparative analysis, the plausible upper limit estimates of excess lifetime
cancer risk for the maximum  tissue concentrations of arsenic and total PCBs
observed in the present study were probably in the range of 10~4 to  10~5. The
noncarcinogenic risk index values for the maximum tissue concentrations of lead
and mercury observed in the present study were probably less than 1.0.  To place
these risk values in a regulatory perspective, they all were consistent with EPA's
Superfund site remediation goals, as contained in the National Contingency Plan,
of £ 10~4 for carcinogens and < 1.0 for noncarcinogens (U.S. EPA 1989). This
consistency indicates that the observed concentrations of chemical contaminants
in fish muscle tissue from the seven transects in southern Puget Sound did not
appear to pose an unacceptable  health risk to consumers of these organisms.
                                   XVI

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Clams

    Of the total of 94 chemicals  evaluated in the whole bodies of littleneck
clams, only four metals (i.e, arsenic, copper, lead, and mercury) and no organic
compounds were detected at the two stations evaluated  in  Budd  Inlet.   The
concentrations of all four of the detected metals were relatively low.  Three of
these four metals were considered by Tetra Tech (1988) to have a medium to high
priority with  respect to concerns for potential health risks to  humans through
seafood consumption.   Those chemicals included the carcinogen arsenic and the
noncarcinogens lead and mercury.

    The health implications of the observed tissue concentrations of the three
priority metals were evaluated  qualitatively by comparing  them with the results
of the risk assessments conducted previously by Tetra Tech  (1988). Based on this
comparative analysis,  the plausible upper limit estimate of lifetime cancer  risk
based on the  maximum tissue concentrations of arsenic observed in the present
study was probably in  the range of 10~6 to 10~7. The noncarcinogenic risk index
values associated with  the maximum tissue concentrations of lead and mercury
observed in the present study were each probably less than  1.0.  These results
were consistent with EPA's Superfund site remediation goals, as contained in the
National Contingency Plan, of  < 1CT4 for carcinogens and  < 1.0 for noncarcino-
gens (U.S. EPA 1989)  and indicate that the observed concentrations  of chemical
contaminants  in the whole bodies of littleneck clams from Budd Inlet did not
appear to pose an unacceptable health risk to consumers of these organisms.
SEDIMENT TOXICITY

    Amphipod mortality at the 24 stations sampled in this study ranged from 1
to 18 percent.  All of these  values were less than the interim performance
standard of 25 percent proposed for Puget Sound reference areas (Pastorok et al.
                                   XVII

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1989).  In addition, all but one mortality value (18 percent, Station 8) were less
than the median value of 16.2 percent observed by Pastorok et al. (1989) for 60
samples from Puget Sound  reference areas.   These results  indicate  that the
toxicity of sediments from all 24 stations sampled in this study was well within
the range of conditions found in Puget Sound reference areas,  and that elevated
sediment toxicity did not appear to be a problem at any of the sites evaluated.
However, neither sublethal nor chronic effects of sediment toxicity were evaluated
in this study.
FISH ASSEMBLAGES

    A total of 9,496 fishes, representing IS families and 28 species, was sampled
in this study.   The most abundant family of fishes throughout southern Puget
Sound was Pleuronectidae (i.e., righteye  flounders), which accounted  for
50 percent of the total catch. The most abundant pleuronectids were English sole
and starry flounder, the two species selected for histopathological and bioaccumu-
lation analyses.

    Although English sole and starry flounder were abundant in southern Puget
Sound as  a  whole,  considerable differences  were  found among  individual
transects.  In general, English sole was most abundant at the two transects  located
near the mouths of embayments,  whereas starry flounder was most abundant at
the five transects located  at the heads of embayments.  The total numbers of
species and individuals also showed  large differences  between transects  located
in the  mouths or heads of embayments, with both variables being considerably
lower in the latter environments.  The results of this  study suggest that habitat
differences within the embayments exerted a considerable influence on the charac-
teristics of the  resident demersal fish assemblages.   Because English sole  was
relatively rare or absent at the heads of embayments,  starry  flounder was used for
bioaccumulation analysis at those five transects, and histopathological evaluations
                                   XVIII

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were not conducted at those locations.  Starry flounder was not used for histo-
pathological evaluations because the historical database for this species is limited.
FISH HISTOPATHOLOGY

     Sufficient sample sizes of English sole for histopathological analysis were
obtained at only two of the seven transects (i.e., those in Totten and Carr inlets)
at which demersal fishes were sampled.  The only kinds of liver lesions found at
those two transects were nonspecific responses to injury. These lesions generally
are not indicative of major adverse biological effects. The three kinds of serious
liver lesions found in previous  studies  of English  sole  from  contaminated
environments in Puget Sound (i.e.,  neoplasms, foci of cellular alteration, and
megalocytic hepatosis) were not found in any of the fish collected in this study.
In general, the prevalences of nonspecific responses to injury were relatively low
(all  <17 percent), and  only three of these  conditions (i.e.,  hepatocellular
regeneration, mononuclear infiltrates, and parenchyma! inflammation) were found
in more than 10 percent of the fish from either study area.

     The absence  of neoplasms,  foci of cellular  alteration,  and  megalocytic
hepatosis in English sole from Totten and Carr  inlets suggests  that any potential
chemical contamination in those two areas was not high enough to cause serious
liver lesions in fishes.  Compared with historical data collected in a variety of
environments elsewhere in Puget Sound, the absence of serious liver lesions in
English sole from Totten and Carr inlets  suggests that those two areas were
similar to the reference areas used in previous studies in Puget Sound.
                                    XIX

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CONCLUSIONS

    The results of this study suggest that most of the areas sampled in southern
Puget Sound were not characterized by substantial levels of chemical contamina-
tion or adverse biological effects. However, the concentrations of several organic
compounds in one or more sediment samples from Budd Inlet were high enough
to potentially result in adverse biological effects.  Despite these elevated chemical
concentrations, sediment toxicity was not elevated above Puget Sound reference
levels at any of the Budd Inlet stations, according  to the results of the amphipod
mortality toxicity test.  Sediment toxicity also was not  elevated above reference
levels at any of the other stations  sampled throughout southern Puget Sound.
However, neither sublethal nor chronic effects of sediment toxicity were evaluated
in this  study.  The limited amount of information collected on  fish disease
suggests that fish evaluated from Totten and Carr inlets were not affected by
chemical contamination, as serious histopathological abnormalities were not found
in the livers of any of these individuals.  However, information on fish disease
in Budd Inlet (i.e., the major urban embayment in southern Puget Sound) could
not be evaluated because the target  species  (i.e., English sole) was  not found in
sufficient abundance there. Finally,  the observed concentrations of chemical
contaminants in tissue samples from fishes  and clams did not appear to pose an
unacceptable health risk to consumers of these organisms.
                                    xx

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                                         PUGETSOUND
LEGEND
   • Sediment Station
   O Clam Collection Site
  —i Trawl Transect
                                Cooper
                                 Point.
                                        Percival
                                         Cove
                                                                 OLYMPIA
                             2 miles
          Figure C-1. Sampling station locations in Budd Inlet from the
                     South Sound Reconnaissance Survey.
                                                C-1

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           APPENDIX D

   List of EPA Technical Studies in
Support of Urban Bay Action Programs

-------
Armstrong, L, and A. Copping (Eds.) 1990. Proceedings of the
Forum on Status and Trends of Puget Sound's Biological Resources.
EPA 910/9-90-001;  NTIS PB90-198839.  Environmental Protec-
tion Agency Region 10,  Seattle, WA.

Burke, D.  1989. Sound access search manual.  Prepared by Puget
Sound Institute, University of Washington, as User's Guide for
Sound Access Computer Bibliography.

City of Seattle.  1986.  Lake Union and Ship Canal water quality
management plan: data summary report.  City of Seattle, Office
for Long Range Planning, WA.

City of Seattle.  1987.  Lake Union and Ship Canal water quality
management plan: data  summary report addendum.  City of Seat-
tle, Office for Long Range Planning, WA.

City of Seattle.  -1987.  Lake Union and Ship Canal water quality
management plan:   data summary report.  EPA 910/9-89-037;
NTIS PB90-197906.   City of Seattle, Office for Long Range
Planning, WA.

City of Seattle.  1988.  Lake Union and Ship Canal water quality
management plan: interim action plan. City of Seattle, Office for
Long Range Planning, WA.

Copping, A.C., J. Dohrman, A. Grahm, et al.  1989.  Handbook
on Puget Sound sediments.  Puget Sound Water Quality Authority,
Seattle, WA.

Crecelius, E.A., T.J. Fortman, S.L. Kiesser, etal.  1989.  Survey
of contaminants in two Puget Sound marinas. EPA 910/9-89-014.
NTIS PB90-130709. Battelle Ocean Sciences, Duxbury, MA.

Curl, H.,  E.  Baker, and T.  Bates, et al.  1987.   Contaminant
transport from Elliott Bay and Commencement Bay. EPA 910/9-
88-177; NTIS PB89-143267. National Oceanic and Atmospheric
Administration, Pacific Marine Environmental Laboratory, Seattle,
WA.
                            D-1

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DeWitt, T., G. Ditsworth, and R. Swartz. 1988.  Effects of natural
sediment features on the phoxocephalid amphipod Rhepoxynius
abronius. Mark 0. Hatfield Marine Science Center, Newport, OR.

E.V.S. and Tetra Tech.  1985. Elliott Bay toxics action program.
Cruise Summary Report: Benthic Infauna and  Sediment Quality
Survey, September 25 - October 16, 1985.  E.V.S. Consultants,
Seattle, WA, and Tetra Tech, Inc., Bellevue, WA.

E.V.S. and Tetra Tech.  1985. Elliott Bay toxics action program.
Cruise Summary Report:  Fish Pathology and Bioaccumulation
Survey. September 16 - October 17, 1985.  E.V.S. Consultants,
Seattle, WA, and Tetra Tech, Inc., Bellevue, WA.

Envirosphere  and Cooper.   1985.  Summary of historical Puget
Sound contaminant mass loading analysis.  EPA 910/9-88-235.
Envirosphere Company, Bellevue, WA, and Cooper Consultants,
Bellevue, WA.

Envirosphere  and Cooper.   1985.   NPDES  monitoring
recommendations to improve contaminant loading data availability.
EPA 910/9-88-237.  Envirosphere Company, Bellevue, WA, and
Cooper Consultants, Bellevue, WA.

Evans-Hamilton and D.R. Systems. 1987. Puget Sound environ-
mental atlas.  EPA 910/9-87-171.  Evans-Hamilton, Inc., Seattle,
WA, and D. R.  Systems, Inc., Nanaimo, BC, Canada.

Faigenblum, J.  1988. Chemicals and bacteriological organisms in
recreational shellfish. EPA  910/9-88-245;  NTIS PB90-131129.
Washington State Department of Social and Health Services, Olym-
pia, WA.

Malins, D., and A.  Jensen  (Eds.).  1988.  Aquatic toxicology.
Toxic Chemicals and Aquatic Life:  Research and Management.
Volume 11.  In: Proceedings of symposium on Elsevier Science
Publishers, B.V.-Amsterdam.

PTI.  1988. Briefing report to the EPA Science Advisory Board:
The apparent effects threshold approach. EPA 910/9-89-013; NTIS
PB90-217913. PTI Environmental Services, Bellevue, WA.

PTI.  1988. Sediment quality values refinement: Vol. II:  Evalu-
ation of PSDDA sediment quality values. EPA  910/9-88-247 a &
b;  NTIS PB89-229827 & PB89-229835. PTI Environmental Ser-
vices, Bellevue, WA.
                            D-2

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PTI.  1988.  SEDQUAL contaminated sediments database users
manual. PTI Environmental Services, Bellevue, WA.

PTI.  1988. Elliott Bay action program:  1988 action plan.  EPA
910/9-88-240.  PTI Environmental Services, Bellevue, WA.

PTI.  1988. Sediment quality values refinement:  Volume I:  1988
update and evaluation of Puget Sound AET. EPA 910/9-88-246 a
& b;  NTIS PB89-200398 & PB89-200406.  PTI Environmental
Services, Bellevue, WA.

PTI.  1989.  Everett Harbor action program:  1989 action plan.
EPA 910/9-89-004; NTIS PB89-229819.  PTI Environmental Ser-
vices, Bellevue, WA.

PTI.  1989. Comparison of bioassays for assessing  sediment tox-
icity in Puget Sound.  PTI Environmental Services, Bellevue, WA.

PTI.  1989. Bellingham Bay action program:  initial data summary
and problem identification.  EPA 910/9-89-042;   NTIS  PB90-
219049. PTI Environmental Services, Bellevue, WA.

PTI.  1990.  Protocol  for juvenile Neanthes sediment bioassay.
EPA 910/9-90-011; NTIS PB90-232828.  PTI Environmental Ser-
vices, Bellevue, WA.

PTI.  1990.  The "Urban Bay action program"  approach:   A
focused toxics control strategy.  EPA 910/9-90-002; NTIS PB90-
198847. PTI Environmental Services, Bellevue, WA.

PTI.  1990. Overview and summary recommendations; November
15-16, 1989 Seasurface Microlayer Workshop. EPA 910/9-90-
008; NTISPB90-227331.  PTI Environmental Services, Bellevue,
WA.

PTI.  1990. Sinclair and Dyes inlets action program: 1990 action
plan. EPA 910/9-90-013.  PTI Environmental Services, Bellevue,
WA.

PTI.  1990. Development of a Neanthes sediment bioassay for use
in Puget Sound.  EPA 910/9-90-005; NTIS PB90-202904.  PTI
Environmental Services, Bellevue, WA.

PTI.  1991.  Bellingham Bay action plan.   PTI Environmental
Services, Bellevue, WA.
                           D-3

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FIT. 1991. Budd Inlet action plan.  PTI Environmental Services,
Bellevue, WA.

PTI. 1991. Pollutants of concern in Puget Sound. PTI Environ-
mental Services, Bellevue, WA.

PTI. 1991. Characterization of toxic chemicals in wildlife associ-
ated with Puget Sound. Report and Monitoring Recommendations.
PTI Environmental Services, Bellevue, WA.

PTI. 1991. Contaminant levels in Puget Sound harbor seals.  PTI
Environmental Services, Bellevue, WA.

PTI.  1991.  Dioxin levels in Puget Sound Dungeness crab.  PTI
Environmental Services, Bellevue, WA.

PTI.  1991.  Nutrients and  phytoplankton in Puget Sound.  PTI
Environmental Services, Bellevue, WA.

PTI. 1991. A project manager's guide to requesting and evaluating
chemical analyses.  PTI Environmental Services, Bellevue, WA.

PTI. 1991. Reconnaissance survey of chemical contamination and
biological  effects in southern Puget Sound.  PTI Environmental
Services, Bellevue, WA.

PTI and DOH.  1991. Chemical contaminant levels in Puget Sound
sea cucumbers.  PTI Environmental Services, Bellevue, WA, and
State of Washington Department of Health, Olympia, WA.

PTI and Tetra Tech.  1988.  Elliott Bay action program: analysis
of toxic problem areas. EPA 910/9-88-213;  NTIS PB90-219064.
PTI Environmental Services, Bellevue, WA, and Tetra Tech, Inc.,
Bellevue, WA.

PTI and Tetra Tech.  1988.   Everett  Harbor action program:
analysis of toxic problem areas. EPA 910/9-88-241 &-241a; NTIS
PB90-227117.  PTI Environmental Services, Bellevue, WA, and
Tetra Tech, Inc., Bellevue, WA.

PSWQA.  1988. Proceedings, first annual meeting on Puget Sound
research. Volumes 1 and 2.  Puget Sound Water Quality Authority,
Seattle, WA.

PSWQA.  1988. Puget Sound ambient monitoring program. Puget
Sound  Water Quality Authority, Seattle, WA.
                            D-4

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PSWQA.   1988.   Design of Puget Sound ambient monitoring
program central database.  Puget Sound Water Quality Authority,
Seattle, WA.

PSWQA. 1989. Evaluation of the atmospheric deposition of toxic
contaminants to Puget Sound.  Final Scoping Report.  Puget Sound
Water Quality Authority, Seattle, WA.

PSWQA.   1989.  Managing  nonpoint pollution:  an action plan
handbook for Puget Sound watersheds. Puget Sound Water Quality
Authority, Seattle, WA.'

PSWQA.  1990. Puget Sound update: first annual  report of the
Puget Sound ambient monitoring program.  Puget Sound Water
Quality Authority, Seattle, WA.

PSWQA. 1991. Evaluation of the atmospheric deposition of toxic
contaminants to Puget Sound.  Puget Sound Water Quality Author-
ity, Seattle, WA.

PSWQA. 1991. Puget Sound update:  1991 second annual report
of the Puget Sound ambient monitoring program.   Puget Sound
Water Quality Authority, Seattle, WA.

PSWQA.  1991. Update of the Puget Sound environmental atlas.
Puget Sound Water Quality Authority, Seattle, WA.

PSWQA.   1991.  Puget  Sound access 1991:  A computerized
bibliography for Puget Sound.  Puget Sound Water Quality Author-
ity, Seattle, WA.

Ryan, C.  1987. The urban bay toxics control program: action
team accomplishments.   Washington Department  of  Ecology,
Olympia, WA.

Siddens, L., R. Hoffman, W. Seim, et al.  1986.  Surf smelt and
other marine fishes appropriate for use in chronic toxicity testing
in the Puget Sound area and on the Pacific Coast.  Department of
Fisheries and Wildlife, Oregon State University, Corvallis, OR.

Simenstad,  C., and C. Tanner.  1991.  An estuarine  habitat resto-
ration monitoring protocol for Puget Sound.  University of Wash-
ington, Fisheries Research Institute, Seattle, WA.
                           D-5

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TetraTech.  1985.  Sampling and analysis design for development
of Elliott Bay toxics action plan.  EPA 910/9-88-197. Tetra Tech,
Inc., Bellevue, WA.

Tetra Tech.  1985.  Elliott Bay toxics action program:  Review of
existing plans and activities. EPA 910/9-88-199. Tetra Tech, Inc.,
Bellevue, WA.

Tetra Tech.   1985.  Field report:  Elliott Bay source sampling
program.  September 23 -  October 17, 1985.  Tetra Tech, Inc.,
Bellevue; WA.

TetraTech. 1985. Elliott Bay toxics action program:  interim work
plan.  EPA 910/9-88-198. Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1985.  Everett Harbor action plan: initial data sum-
maries and problem identification.  Draft Report (never finalized).
EPA 910/9-88-195.  Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1986.  Sampling and analysis design for development
of Everett Harbor  action program.  EPA 910/9-87-197.  Tetra
Tech, Inc., Bellevue, WA.

Tetra Tech.   1986.  Development  of sediment quality values for
Puget Sound.  EPA 910/9-88-246; NTIS AD-A148647.  Tetra
Tech, Inc., Bellevue, WA.

Tetra Tech.   1986.  User's manual for the pollutants of concern
matrix. EPA 910/9-87-176. Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1986.  Elliott Bay toxics action program: initial data
summaries and problem identification.  EPA  910/9-88-191;
NTIS PB90-197898.  Tetra Tech, Inc., Bellevue, WA

TetraTech.  1986.  Everett Harbor toxics action program:  review
of existing plans and activities. EPA 910/9-88-192. Tetra Tech,
Inc., Bellevue, WA.

Tetra Tech. 1986.  Guidance manual for health risk assessment of
chemically contaminated seafood. EPA 910/9-88-182; NTIS PB90-
197880. Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.   1986.  Everett Harbor toxics action program:  field
summary report, source sampling,  October 15, 16, and 29, 1986.
Tetra Tech, Inc., Bellevue, WA.
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Tetra Tech.  1988.  Budd Inlet action program: initial data summa-
ries  and problem identification. EPA 910/9-88-230; NTISPB90-
195264.  Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.   1988.  Assessment of potential toxic problems in
non-urban areas of Puget Sound. EPA 503/3-88-002; NTIS PB89-
134332.  Tetra Tech, Inc., Bellevue, WA.

Tetra Tech. 1988. Elliott Bay revised action program: data quality
assurance assessment.  Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988. Elliott Bay revised action program:  data set.
Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988.  Health risk assessment of chemical contami-
nants in Puget Sound seafood. EPA 910/9-88-249; NTK PB89-
200240.  Tetra Tech, Inc., Bellevue, WA.

Tetra Tech. 1988. Pesticides of concern in the Puget Sound basin:
A review of contemporary pesticide usage.  EPA 910/9-88-231;
NTIS PB89-143275. Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988.  Everett Harbor action program: evaluation of
potential contaminant sources. EPA 910/9-88-229; NTIS PB90-
219072.  Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.   1988. Elliott Bay action program:  evaluation of
potential contaminant sources.  EPA 910/9-88-239 a through c;
NTIS PB90-198862. Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988.  Characterization of spatial and temporal trends
in water quality in Puget Sound.  EPA  503/3-88-003;   NTIS
PB89-134290. Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988.  Elliott Bay action program:  The relationship
between source control and recovery of contaminated sediments in
two  problem areas.  EPA 910/9-88-208;   NTIS PB90-198888.
Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988.  Elliott Bay action program:  storm drain
monitoring approach.  EPA 910/9-88-207; NTIS PB90-198896.
Tetra Tech., Inc., Bellevue, WA.
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Tetra Tech.  1988.  Elliott Bay action program:  guidance for
development of monitoring programs to evaluate the success of
source control within drainage basins. EPA 910/9-88-243; NTIS
PB90-198870.  Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988.  Sinclair and Dyes Inlets action program: initial
data summaries and problem identification.  EPA 910/9-88-244;
NTIS PB90-206533.  Tetra Tech, Inc., Bellevue, WA.

Tetra Tech and E.V.S.  1986.  Everett Harbor toxics action pro-
gram: cruise summary report, fish pathology and bioaccumulation
survey,  August 25 to September 2,  1986.  Tetra Tech, Inc.,
Bellevue, WA, and E.V.S. Consultants, Seattle, WA.

Tetra Tech and E.V.S.  1986.  Everett Harbor toxics action pro-
gram:  cruise summary report, benthos,  bioassay,  and sediment
chemistry survey, September 30 to October 15, 1986. Tetra Tech,
Inc., Bellevue, WA, and E.V.S. Consultants, Seattle, WA.

Weston, D.P.  1989. Pollutant bioaccumulations and community
response in the macrobenthos:  1987-1988 studies.  Puget Sound
Institute, University of Washington, Seattle, WA.
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Guidelines for Measuring Environmental
Variables  in Puget Sound
                        U.S. EPA. 1990. Recommended guidelines for measuring selected
                        environmental Variables in Puget Sound. U.S. Environmental
                        Protection Agency Region 10, Seattle, WA.  13 chapters:

                        1.  General QA/QC Considerations for Collecting Environmental
                           Samples in Puget Sound (3/86).

                        2.  Recommended Protocols for Measuring Conventional Sedi-
                           ment Variables in Puget Sound (3/86).

                        3.  Recommended Protocols for Conducting Laboratory Bioassays
                           on Puget Sound Sediments (5/86; in revision).

                        4.  Recommended Protocols for Station Positioning in Puget Sound
                           (8/86).

                        5.  Recommended Protocols for Measuring Metals in Puget Sound
                           Water, Sediment and Tissue Samples (8/86; revised 12/89).

                        6.  Recommended Protocols for Microbiological Studies in Puget
                           Sound (11/86).

                        7.  Recommended Protocols for Measuring Organic Compounds
                           in Puget Sound Sediments and Tissue Samples (12/86; revised
                           12/89).

                        8.  Recommended Protocols for Sampling and Analyzing Subtidal
                           Benthic  Macroinvertebrate Assemblages in  Puget  Sound
                           (1/87).

                        9.  Recommended Protocols for Fish Pathology Studies in Puget
                           Sound (7/87).

                        10. Recommended Protocols for Measuring Conventional Water
                           Quality Variables and Metals in Fresh Waters of the Puget
                           Sound Region (12/89).

                        11. Recommended Protocols for Sampling Soft-Bottom Demersal
                           Fishes by Beach Seine and  Trawl in Puget Sound (12/89).
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12.  Recommended Protocols for Measuring Conventional Marine
    Water Column Variables in Puget Sound (In preparation).

13.  Recommended Protocols for Marine Mammal Tissue Sampling
    and Analysis (In preparation).
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