United States	Region 10
Environmental Protection	1200 Sixth Avenue
Agency	Seattle WA
July 1986
-SEPA /Environmental Action Program
For Puget Sound

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I am pleased to submit Region 10's Environmental
Action Program for Puget Sound. The purpose of this
document is to communicate the problems threatening
Puget Sound and our strategy for addressing them.
The Puget Sound Action Program is the result of the
efforts of: EPA Office of Puget Sound, the Program,
Planning, and Evaluation Branch, EPA's Regional program
offices in consultation with the Washington State
Department of Ecology and the Puget Sound Water
Quality Authority. In developing the Program, we have
attempted to be responsive to the interests of several
Headquarters offices — Office of Enforcement and
Compliance Monitoring, Policy Planning and Evaluation,
and the Office of Estuary Protection — as well as the
needs of the many organizations involved in implementing
it.
Letter to the Administrator
The Puget Sound Action Program will serve as a
guide for our activities in Puget Sound over the next
three to five years. Space does not permit us to convey in
detail the level of effort these activities will entail.
Some activities may be changed to reflect the Puget
Sound Water Quality Authority's Plan, to be completed by
January 2, 1987. Furthermore, as time progresses, the
plan will be updated in response to new and emerging
information.
The strategies, as outlined in our plan, constitute an
ambitious and challenging endeavor. To be successful, it
will require the support of EPA, State and local
governments, and the citizenry of the State of Washington.
U.S. EPA LIBRARY REGION 10 MATERIALS
RXooocmnHfl

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Table of Contents
Region 10
Environmental Action Program for Puget Sound
Executive Summary	Page 2
Problem Statement		Page 5
Summary of Objectives	 	Page 8
Objectives	Page 10
Strategies		Page 12
Headquarters Actions Needed.	Page 25
References		 	Page 28
Maps
Location of Puget Sound			Page 1
Urban Embayments in Puget Sound	Page 6
Timeline for Key Activities	Page 11
i

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Puget Sound Location
WASHINGTON
1
Puget Sound
.••V
«"•« Of JU»» 09 F4,C#
Port Angelas
Seattle
Bremerton
*Tacoma
Olympia

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Executive Summary
The water quality of Puget Sound, an estuary of
immense value and importance to the Pacific Northwest,
is threatened by contamination with toxic and
conventional pollutants. Past pollution control efforts,
while addressing some pollution sources, have lacked the
integrated system-wide approach needed to address
current and anticipated problems. The Puget Sound
Environmental Action Program presents Region 10's plan
for addressing the problems of Puget Sound. The program
describes a geographic, multi-media approach to problem
identification, control, and enforcement. Success in
developing and implementing the many initiatives
described in this program depends on the close
cooperation between EPA Region 10, the Washington
State Department of Ecology, and the Puget Sound Water
Quality Authority. The cooperation among the Region's
air, water, and hazardous waste programs is needed as
well. Technical, financial, and staff support from
headquarters will help Region 10 carry out its
responsibilities under the program.
Puget Sound's 2,200 square miles of bays and inlets
and over 2,000 miles of shoreline is one of the most
biologically productive and recreationally important
estuarine areas in the country. Its shorelines, waters, and
rich marine life symbolize the quality of life to 2.5
million people who populate its borders. The Sound is
also the center for the Region's commercial, maritime,
and industrial activities.
Studies by EPA, NOAA, and others have revealed
that highly toxic and persistent pollutants are
contaminating the Sound's environmental and biological
systems. While much of the foeus has been on the acute
and immediate problems of urban bays, concern is growing
over the long-term, cumulative impacts of these
contaminants on the health of the Sound. This concern is
in response to evidence that toxic and conventional
contaminants are appearing at all levels of the food chain,
and that these contaminants are being found in areas of
the Sound far removed from urban/industrial centers.
Furthermore, concern over human health risks posed by
these contaminants in Puget Sound seafood has resulted in
the closure of many commercial and recreational shellfish
harvesting areas and in issued warnings against eating fish
caught in several urban bays.
2

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Executive Summary
The Puget Sound Environmental Action Program
details Region 10's response to these problems. Five
major objectives and a series of activities to be carried
out to achieve each objective make up the program. The
goal is to expeditiously eliminate or significantly reduce
discharges of specifically targeted problem pollutants.
The action program will result in a comprehensive,
integrated approach for addressing the pollution problems
of Puget Sound.
The first objective calls for a fuller understanding
of the toxicant-related problems in Puget Sound indicated
by adverse biological effects and bioaccumulation.
Current knowledge about the Sound is being mapped.
Surveys and studies will be undertaken to fill in the gaps
of our knowledge about the nature, location, extent,
and severity of the Sound's pollution problems. While the
focus will be on the urban bays where the most severe
problems are located, we will also undertake studies to
assess what will be the long-term effects of toxicants on
the Sound's biological systems. The risks to human health
from consumption of contaminated Puget Sound seafood
will also be studied and assessed.
The second objective will reduce the input of
problem chemicals in Puget Sound to safe levels,
particularly in the urban bays. A major emphasis of this
objective is to develop and implement a program to
identify and reduce discharges of "chemicals of concern."
This approach will target key dischargers of "chemicals of
concern" for toxics control. Ambient and biomonitoring
requirements will also be added to these discharge
permits. Storm drains and combined sewer overflows
(CSO's) are also a major source of pollution in Puget
Sound. These sources of pollution will be addressed
through the development and implementation of
strategies for volume reduction and permitting. Other
activities under this objective include: implementing
Urban Bay Action Plans, tracking municipal compliance
3
with secondary treatment requirements, and completing
the dredge spoil disposal analysis.
The purpose of the third objective is to target
compliance and enforcement efforts under a geographic
enforcement initiative to reduce and deter inputs of
problem pollutants ("chemicals of concern") into Puget
Sound. These efforts are the key to the success of our
program to clean-up and protect Puget Sound. Emphasis
will be placed on urban bays and toxic discharge controls.
Key activities include identifying unregulated
dischargers and bringing them into compliance; stepped up
monitoring and inspection of regulated dischargers;
employing Urban Bay Action Teams to carry out
enforcement and compliance strategies developed for
priority urban bays; use of criminal enforcement
capabilities; and cleaning up existing hazardous waste
sites.
The fourth objective calls for the design and
implementation of a comprehensive ambient water quality
monitoring program. This objective responds to the need
for a comprehensive Sound-wide monitoring program.
This would allow for better tracking of clean-up progress
and a means for identifying emerging problems.
The final objective calls for the development of
management tools, institutional structures, and long range
program support to clean up Puget Sound. A priority
under this objective is to develop and implement protocols
and data management tools to assure that the information
collected on Puget Sound is of high quality and that it is
efficiently managed for the greatest use. Other
initiatives under this objective include the establishment
of a Puget Sound Institute to focus and coordinate
long-term Puget Sound research at the University of
Washington, and the fostering of public understanding and
participation in Puget Sound initiatives.

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EPA Region 10 is responsible for many of the
activities described in the Puget Sound Action
Program. These activities will require an extensive
commitment of the Region's resources. However, our
resources are limited and in order to achieve our
objectives we will need the support of
headquarters. We have identified the following areas
where headquarters could provide valuable assistance:
1)	Support Toxic Control Activities through
developing biomonitoring and toxic discharge
limits for NPDES permits, and providing
training and enforcement support for state
agencies.
2)	Support the Development of Regional
Sediment Criteria by providing for better
coordination and support between regional and
headquarters sediment criteria efforts and
support'for setting discharge limits to meet
interim sediment quality values.
3)	Support Development of Enhanced
Biomonitoring Tools by providing funding or
technical assistance for development of chronic
bioassays and for identification of pollution
sensitive west coast species for use in ambient
and biomonitoring.
4)	Support Toxic Hotspot Remedial Action Pilot
Project by providing funds to support a
dredging project for the removal of a toxic
hotspot in Puget Sound.
5)	Streamline Enforcement referral process by
allowing the Region to tailor the level of
referral support on a case-by-case basis.
Executive Summary
6)	Loan headquarter's staff to Region where
they could provide support in writing NPDES
permits, 308 letters, and in writing defensible
biomonitoring requirements into permits. This
would be extremely helpful to Region 10 and
would provide a short term rotational
assignment for headquarter's staff.
7)	Increase commitment for regional staff by
headquarters. Headquarters currently supports
only one of the four staff positions in the
Office of Puget Sound (OPS). While the Region
has supported the other three positions,
anticipated cutbacks in FY '87 may prevent the
region from doing so next year. Headquarters
support for these positions would ensure
successful implementation of the
Environmental Action Program for Puget Sound
by OPS.
4

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Problem Statement
Environmental Problems
Puget Sound is one of the most biologically
productive and recreationally important estuarine areas in
the United States. The 2,200 square miles of bays and
inlets and over 2,000 miles of shoreline support a rich and
diverse commercial and sport fishery. Much of the
commerce, industry, and tourism in the Northwest centers
on Puget Sound. Its shorelines, waters, and marine life
symbolize the quality of life in the Northwest.
The quality of Puget Sound and the beneficial uses
that it supports have been threatened by toxic and
conventional pollutants. Studies have revealed that
pollutants have contaminated the Sound's environment
and impacted its biological communities.
Puget Sound receives wastes from approximately 2.5
million people as well as from an array of industries.
Wastes are directly discharged to the Sound from publicly
owned treatment works and from facilities associated
with food processing, construction, chemical
manufacturing, marine industries, wood finishing, metal
and petroleum refining, and from agricultural and forest
practices. Erosion, urban and rural runoff, and
atmospheric emissions also contribute contaminants.
Many of these wastes contain toxic and hazardous
materials such as PCB's, PAH's, mercury, cadmium,
arsenic, lead, and potentially harmful pathogens.
Evidence of degradation of the Sound's environment
and biological systems has been observed at many levels:
The sediments of urban bays and harbors contain
highly toxic and persistent materials. Sediments
contain high concentrations of PCBs, aromatic
hydrocarbons, chlorinated butadiens, and heavy
metals.
5
Benthic communities in urban bays are showing signs
of stress. Communities were found to be of low
diversity and to be dominated by a few species.
Pollution in sediments has caused deformities in and
death of shellfish and fish embryos, and has
impaired the development of benthic worms.
Tissues and organs of bottom-dwelling fish of urban
bays exhibit higher than expected incidences of
lesions and contain elevated levels of toxics.
Between 15 and 89% of the English Sole in urban
bays had liver lesions and other abnormalities, while
the rate for English sole from Carr Inlet, a
reference area, was zero percent.
PCBs and mercury are found in marine birds and
mammals. Harbor seals of the south Sound area have
concentrations of PCBs higher than almost any
other seal population in the world.
Levels of bacterial contaminants in shellfish beds of
rural bays are elevated. Forty-one percent of the
commercial shellfish harvesting areas in
Puget Sound are closed and 10% are conditionally
approved for commercial harvest.
Paralytic shellfish poisoning has spread beyond
historical boundaries. There are indications that it is
associated with elevated nutrient loading.
Recetit studies by Battelle Laboratories and NO A A
have found pollutants in the microlayer of the water
column in the waters of Elliott Bay, Commencement
Bay, and Port Angeles Harbor at levels high enough
to kill fish eggs, cause chromosomal damage in fish
embryos, and slow growth of fish cells. Hatch
success rates of fish eggs held in water samples

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taken from these bays ranged from 0 to 38%, and of
those that did hatch many had deformed spines.
These rates compare to a rate of 85-90% for eggs
held in water from Sequim Bay, an unpolluted area.
Presence of contaminants in the food chain has
raised concern over the potential human health risks
posed by consuming Puget Sound seafood. Shellfish
exposed to harmful pathogens and, in urban bays, to toxic
contaminants have caused state health officials to close
many areas to commercial and recreational harvest.
Bottom-dwelling fish in urban bays are contaminated with
toxic and carcinogenic substances. State health officials
have issued warnings against consuming seafood caught in
several urban bays as a result of a cancer risk
assessment.
While urban bays have been the focus of much of the
studies on Puget Sound's pollution problems, there
is evidence that h^avy metals and other pollutants are
showing up in the sediments of embayments far removed
from urban development and industrialized activity. This
factor along with the presence of toxic contaminants in
the upper levels of the food chain have prompted concern
over the cumulative impacts of pollution on the long-term
health of the Sound. This concern is based on the
recognition that large areas of the Sound are poorly
flushed and that its assimilative capacity is limited. Data
indicates that most of the pollutants entering the Sound
remain in the system.
Apart from the impacts on marine organisms and
human health, pollution may also impair the quality of life
associated with Puget Sound. Great value is placed on
Puget Sound's waters, beaches and marine life. These
are, however, the very assets that are in danger of being
severely altered from the contamination of the Sound by
conventional and toxic pollutants.
Problem Statement
Everett Harbor
Everett
URBAN BAYS
Shi/sho/e Bay
Seattle
Elliott Bay
NSJMacoma
Commencement Bay
ACTIONS TO DATE
Growing public concern over the condition of Puget
Sound has resulted in several initiatives for action.
Agencies at all levels of government have recognized that
traditional methods of pollution control, while they have
6

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Problem Statement
improved water quality, have fallen short of the
integrated system-wide approach needed for current and
anticipated environmental problems. Initiatives
undertaken include:
Establishment of the Puget Sound Water Quality
Authority by the State of Washington to develop
and oversee a comprehensive water quality
management plan for Puget Sound.
Creation of the Puget Sound Initiative, (now the
Puget Sound Estuary Program), to coordinate the
efforts of federal, state, and local agencies having
regulatory, research, and resource management
responsibilities in Puget Sound in order to develop
strategies to address problems in the Sound.
Washington State Department of Ecology's Shellfish
Strategy.
Puget Sound Dredge Disposal Analysis is currently
being carried out through the joint efforts of COE,
EPA, and the Washington State Departments of
Ecology and Natural Resources.
Washington State Department of Ecology's South
Sound Study.
Specific efforts by EPA to date include:
Development of "action plans" for urban bays where
the problems are most severe. In 1985 the focus has
been on Commencement Bay, Elliott Bay, and
Everett Harbor.
Working with the COE to develop criteria for
environmentally safe levels of contaminants in
marine sediment.
7
Working with the State of Washington to quantify
the amounts of pollutants entering the Sound and to
reduce inputs to acceptable levels through NPDES
permits and by developing new control strategies.
Field studies with NOAA in Elliott Bay and
Commencement Bay to determine the extent of
transport of pollutants to the central basin of the
Sound.
EPA is also supporting studies to quantify the total
loading of pollutants to the Sound by source, type, and
amount. From this will be developed a model to relate
source inputs to depositional areas, help evaluate the
nature and extent of existing problems, develop
integrated abatement and protection programs, and
forecast future water quality impacts.

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Summary of Objectives
1. Know and understand the toxicant-related problems
in Puget Sound as indicated by adverse biological
effects and bioaccumulation.
We know that organisms can be harmed, both
acutely and chronically, upon exposure to chemicals,
but we do not possess a clear understanding of
routes of contamination or sublethal effects. It is
suspected that the tissue of fish and shellfish caught
in the Sound may contain potentially harmful levels
of chemical contaminants. Whether the
consumption of these organisms poses a threat to
human health is not known, but recent studies
indicate that more advanced species which feed on
marine organisms are accumulating potentially
carcinogenic chemicals in their tissues. To ensure
the protection both of the biological resources and
human health, more information is needed to
adequately characterize and understand
toxicant-related problems in Puget Sound.
Much of the information needed will be
generated through field and laboratory
investigations. The urban bay toxics action
programs will provide extensive empirical data
about site specific biological impacts and possible
sources of the impacts. Lab studies will identify the
chemicals or groups of chemicals responsible for
problems observed in the field. To address human
health issues, a risk assessment will be conducted
using chemical concentration data collected
from Puget Sound seafood. Development of an
environmental atlas, which identifies sources of
pollution and current environmental conditions, will
provide a common reference for agencies focusing
action on protecting the Sound.
Reduce the input of problem chemicals to Puget
Sound to safe levels, especially in urban bays.
Chemical contamination in Puget Sound has
been identified as an issue of priority concern. In
recent years significant levels of toxic contaminants
have been discovered in the water and sediments of
urban bays. There is growing concern that certain
areas, far removed from urban or industrial activity,
may also be sinks for contaminants discharged miles
away.
8

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Summary of Objectives
As a means of reducing toxic contamination in
Puget Sound, the ageney will continue to fund toxics
action programs in priority urban embayments and
to conduct surveys to identify problems in
non-urban areas. The programs will emphasize
intensive field surveys to characterize
environmental conditions and biological impact, and
will be combined with site investigations designed to
identify and control sources of pollution. Enhanced
permit requirements, increased enforcement
activity, and the development of tools for regulating
sediment contamination will reduce, and eventually
prevent, the further addition of toxic substances to
the Sound.
3. Target compliance and enforcement efforts to
reduce and deter inputs of problem pollutants.
In order to more effectively control the inputs
of contaminants to Puget Sound, a comprehensive
program, known as the Geographic Enforcement
Initiative (GEI), is being developed to coordinate and
focus increased emphasis on permitting, compliance,
and enforcement activities. The GEI brings
inspection resources from numerous programs as
well as an administrative, civil and criminal focus
for enforcement activities on the Sound. To
enhance the effectiveness of the GEI, new
regulatory tools are being developed. Use of these
tools, including discharge permits for storm drains
and control of CSOs, will greatly improve the
agency's ability to characterize discharges and to
ensure monitoring and control of toxic substances
entering the estuary.
9
4. Design and implement a comprehensive monitoring
program.
Design and implementation of an integrated,
Puget Sound estuary-wide monitoring program will
enable EPA to more accurately assess current
conditions in Puget Sound. This effort will result in
an improved ability to identify potential problems,
to take action before significant adverse impacts
occur, and to determine how and to what extent
remedial and abatement actions have improved
environmental quality. The monitoring program
which is being developed will build on existing
programs through the coordination and
enhancement of numerous, but currently
fragmented, programs at the federal, state and local
level.
5. Develop management tools, institutional structure,
and long range program support to clean up Puget
Sound.
In the past few years, significant improvements
have been made in the technical and institutional
management of the Sound, and in coming years this
momentum will be continued. Significant emphasis
is being placed on the coordination and management
of Puget Sound activities through participation on
interagency management and technical advisory
committees. Standard protocols defining acceptable
levels of quality control for the collection and
analysis of Puget Sound data are currently being
developed and wide adoption and use of these
protocols is expected. The development of an
integrated Puget Sound data and information
management system has begun and should improve
our ability to identify, predict, and prevent
environmental problems.

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Puget Sound 5-Year Work Program
OBJECTIVES ARE TO:
1. Know and understand the toxicant-related problems iii Puget Sound as
indicated by adverse biological effects & bioaccumulation.
2. Reduce the input of problem chemicals to Puget Sound to safe levels,
especially in urban bays.
3. Target compliance and enforcement efforts to reduce and deter inputs of
problem pollutants.
4. Design and implement a comprehensive monitoring program.
5. Develop management tools, institutional structure, and long range program
support to clean up Puget Sound.

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Timeline for Key Activities
1985
Know the Problem.
Atlas
Human Health Risks
Determining Chronic Effects
Reduce Chemical Inputs.
Urban Bay Plans
Commencement Bay
Elliott Bay
Everett Harbor
Shilshole Bay
Toxic Permits
First Phase 115)
Second Phase (25)
Storm Drains
Monitoring Program.
Design
Implement
Puget Sound Water Quality Authority.
Puget Sound Water Quality Management Plan
Update on Plan
11
1987
1988
1989
1990

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Strategies
OBJECTIVE 1: Know and Understand the Toxicant-Related Problems in Puget Sound as Indicated by Adverse
Biological Effects & Bioaccumulation
1-3 Year
Objective?
1. In Urban Bays: Conduct
sampling and analysis to develop
a detailed understanding of the
nature, location, extent and
severity of toxicant caused
problems, problem chemicals
and sources.
2. Map & define the present
knowledge of biological effects,
chemical concentrations and
resources in P.S.
3. Identify the nature and
extent of human health risks
from consuming P.S. seafood.
4. Identify if airborne contam-
inants are a significant contrib-
ution to P.S.
Actions Planned
° Complete Commencement Bay
Analysis (Feasibility Study)
° Complete Elliott Bay
Analysis
0 Complete Everett Harbor
Sampling and Analysis
° Complete Shilshole Bay
Sampling and Analysis
° Complete Sinclair Inlet
Sampling and Analysis
° Complete Budd Inlet
Sampling and Analysis
Complete P.S. Atlas
Survey shellfish at
commercial & recreational
sites, together with sediment
chemistry
Finfish Survey
Macroalgae Survey
Health risk assessment
based on previous studies
Followup as appropriate
Air emission inventory/
survey
Reconnaissance air
deposition survey
Schedule
Responsibility
EPA
Contact
Progress
Indicator

4/87
Ecology
B. Courson
Consultant
Report
10/86
EPA-WD
J. Underwood
Consultant
Report
6/87
EPA-WD
J. Underwood
Consultant
Report
7/88
EPA-WD
J. Underwood
Consultant
Report
7/89
EPA-WD
J. Underwood
Consultant
Report
7/89
EPA-WD
J. Underwood
Consultant
Report
10/86
EPA/PSDDA/PSWQA
J. Underwood
Atlas

10/87
DSHS/EPA
J. Underwood
Analysis results
Risk assessment

EPA-ATD
G. Abel
Survey Results
12

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Strategies
OBJECTIVE 1: Know and Understand the Toxicant-Related Problems in Puget Sound as Indicated by Adverse
Biological Effects & Bioaccumulation
1-3 Year
Objective
5. Determine if and where there
are chronic effects from chemicals
to the biological system.
6. Set interim criteria levels
for sediment contamination for
dredging disposal & for identifying
remedial actions in urban bays.
7. Determine if chemicals in the
microlayer are causing biological
effects.
Actions Planned
0 Identify best available
sensitive indicators,
chronic biological tests
° Confirm through lab tests
0 Confirm through on-site
tests
0 Develop protocols
° Initiate field surveys/
monitoring to detect
chronic effect
° Report on chronic effects,
likely causes, significance
° Identify co-occurring
chemicals that appear to
cause biological effects
° Associate field measure-
ments of biological effects
with chemical levels in
sediment.
° Set interim criteria for
use in urban bay studies
° Analyze new data, review
interim criteria.
° Complete NOAA funded
reconnaissance study
Schedule Responsibility
2/87
6/88
10/88
3/90
8/86
6/86
6/87
11/88
EPA
EPA
EPA
EPA
PSDDA/EPA
PSDDA/EPA
EPA
EPA
NOAA
EPA
Contact
J. Underwood
J. Underwood
J.	Underwood
J.	Underwood
J. Underwood
J. Underwood
J. Underwood
J. Underwood
Progress
Indicator
Adopted tests
Test results
Test results
Protocol Manual
Study Plan, survey
Atlas update
Consultant Report
Consultant Report
Consultant Report
Consultant Report
NOAA Report
13

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OBJECTIVE 2: Reduce the Input of Problem Chemicals to Puget Sound to Safe Levels, Especially in Urban Bays
1-3 Year	EPA
Objective	Actions Planned	Schedule Responsibility Contact
1. Institute toxic chemical
reduction approach to point sources.
Complete chemicals of	7/86	EPA-WD
concern matrix
Develop overall draft	10/86	EPA-WD
toxic control strategy
and approach, to be
coordinated with Ecology.
Identify & prioritize initial 7/86
set (15) of sources for
toxics reduction program
Establish needs & schedules
Identify & prioritize	12/86
remaining sources for toxics
reduction program
Establish needs & schedule.
For the 15 priority sources:
(1)	Add biomonitoring re- 10/86	EPA-WD
quirements to discharger
through orders or permits
(2)	Add effluent monitoring 10/86	EPA-WD
requirements for
priority dischargers
through orders or permits
(3)	Add ambient monitoring 10/86	EPA-WD
requirements for
priority dischargers
through orders or permits
As needed, initiate cor-	10/87	EPA-WD
rective actions
Assess workload required	3/87	EPA-WD
for toxics control approach
and compliance monitoring/
followup
Reassess and affirm strategy 10/87	EPA-WD
for toxics controls based
upon experience with initial
15 dischargers
J. Underwood
J. Underwood
EPA/(Ecology)	H. Geren
H.	Geren
H.	Geren
H.	Geren
H.	Geren
H.	Geren
H.	Geren
Strategies
Progress
Indicator
Matrix Done
Strategy draft
Priority List
15 dischargers sub-
mitting biomonitoring
reports
15 dischargers sub-
mitting effluent mon-
itoring reports
15 dischargers sub-
mitting ambient
monitoring reports
Enforcement Actions
Analysis
Recommendations
Strategy
14

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Strategies
OBJECTIVE 2: Reduce the Input of Problem Chemicals to Puget Sound to Safe Levels, Especially in Urban Bays
1-3 Year
Objective
Actions Planned
° For the remaining priority
sources:
(1)	Add biomonitoring re-
quirements to discharger
through orders or permits
(2)	Add effluent monitoring
to requirements for
priority dischargers
through orders or permits
(3)	Add ambient monitoring
to requirements for
priority dischargers
through orders or permits
0 Develop approach for
determining source discharge
limits (using consultant work
in Commencement Bay)
° Modify permits to include
chemical units for
priority dischargers
Schedule Responsibility
10/87
10/87
10/87
10/87
1/88
EPA-WD
EPA-WD
EPA-WD
EPA-WD
EPA-WD
EPA
Contact
H.	Geren
H.	Geren
H.	Geren
H.	Geren
H.	Geren
2. Develop and implement approach
to control toxics from storm
drains.
° Develop storm drain approach
using work done in remedial
investigation by Consultant
in Commencement Bay
° Identify Class I (priority)
storm drain discharges for
12/87 data submittal require-
ments
° Issue guidance for data to be
submitted in 12/87
° Apply approach to develop
specific orders/permits
identified in urban bay plans
for Commencement Bay, Elliott
Bay and Everett Harbor
6/87	EPA-WD	H.	Geren
6/87	EPA-WD	H.	Geren
6/87	EPA-WD	H.	Geren
12/87	EPA-WD	H.	Geren
Progress
Indicator
Remaining dischargers
submitting bio-
monitoring reports
Remaining dischargers
submitting effluent
monitoring reports
Remaining dischargers
submitting ambient
monitoring reports
Consultant Report on
Remedial Action Plan
Permi ts
Procedure, Policy,
Guidance
Priority List
Guidance, Memos
Permi ts
15

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OBJECTIVE 2: Reduce the Input of Problem Chemicals to Puget Sound to Safe Levels, Especially in Urban Bays
Strategies
1-3 Year
Objective
3. Develop & implement approach
to control toxics from CSO's
per state law HB 815.
4. Complete Urban Bay Plans
Implement Urban Bay Plans
through Action Teams
(Resource issue with Ecology)
6. Meet Deadlines For Municipal
Compliance Plan
Actions Planned
Schedule Responsibility
(1)	Begin processing permit 1/88
appli cations
(2)	Issue priority permits 6/88
Include controls on storm- 10/88
water runoff for all NPDES
industrial permits for
Elliot Bay, Commencement Bay
and Everett Harbor as determined
necessary
Develop volume reduction
strategy per state require-
ment
Assess application of RCRA 10/87
requi rements
Elliott Bay plan complete 10/87
Commencement Bay plan	6/87
Everett Harbor plan complete 10/88
Shilshole Bay plan complete 10/88
Sinclair Inlet & Budd Inlet 10/91
plan complete
Elliott Bay plan complete	7/89
Commencement Bay plan complete 7/90
Everett Harbor plan complete 2/90
Shilshole Bay plan complete 10/89
Sinclair Inlet & Budd Inlet 12/92
plan complete
Confirm priority ranking
for municipal STP
construction grants on
Puget Sound
"All dischargers at	10/86
secondary treatment or
on legal schedule or in
referral process
0 Secondary treatment	6/92
requirements met at all
municipalities
Ecology
EPA-WD
EPA-WD
Ecology/EPA-WD
EPA-WD
EPA-WD
EPA-WD
Ecology
Ecology
Ecology
Ecology
Ecology
Ecology/EPA-WD
Ecology/EPA-WD
EPA
Contact
Ecology/EPA-WD J. Underwood
H. Geren
H. Geren
J.	Underwood
J.	Underwood
J.	Underwood
J.	Underwood
J.	Underwood
C. Noah-Nichols
Ecology/EPA-WD H. Geren
H. Geren
Progress
Indicator
Permi ts
Strategy
Assessment
Final Plan
Final Plan
Final Plan
Final Plan
Interim Plan
Action Team hi red &
working
Action Team hired &
working
Action Team hi red &
worki ng
Action Team hired &
worki ng
Action Team hired &
worki ng
Consent decrees
STPs on line
16

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Strategies
OBJECTIVE 2: Reduce the Input of Problem Chemicals to Puget Sound to Safe Levels, Especially in Urban Bays
1-3 Year
Objective
7. Develop approach for dealing
with toxic hot spots including
options for solutions and
associated data needs, cost
estimates, etc., for each
option.
8. Institute chemical reduction
through dredged material
disposal siting and management
(PSODA)
Actions Planned
° Design and carry out
prototype toxic hot spot
removal and upland
disposal in Commencement
Bay to test procedures,
technology, and costs
° Implement appropriate
remedial action for
priority hot spots
° Identify acceptable
open water, unconfined
disposal sites
0 Determine interim
biological and chemical
criteria for defining
sediment acceptable for
open water, unconfined
disposal
° Develop management plan
and responsibility for
dredged material disposal
and management for open
water, unconfined disposal
° Adopt and implement
unconfined dredged material
management program
° Develop concept paper &
a decision memo for study of
alternatives to unconfined
di sposal
0 Define procedure and
requirements for confined
and/or upland disposal
° Adopt and implement program
for confined and/or upland
disposal of contaminated
dredged materials
Schedule Responsibility
(assistance
requested
from HQ)
EPA-WD/HQ
7/87
7/87
7/87
9/87
PSDDA/EPA-WD
PSDDA/EPA-WD
PSDDA/EPA-WD
DNR/Ecology
EPA
Contact
J. Underwood
M. Lagerloef
H. Lagerloef
M. Lagerloef
M. Lagerloef
M. Lagerloef
M. Lagerloef
M. Lagerloef
Progress
Indicator
Completion of
prototype cleanup
# hot spots
cleaned up
EIS
EIS
EIS
Decision re: study
17

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OBJECTIVE 3: Target Compliance and Enforcement Efforts to Reduce and Deter Inputs of Problem Pollutants
Strategies
1-3 Year
Objective
Identify unregulated toxic
discharges into PS and bring
sources into compliance
Storm Drains^
Illegal Dumping
Poor Mgmt of
Reg. Pesticides
(Wood treaters)
Hazardous Chemical
Substances or
Mixtures (ex.
sandblasters)
Ai rborne
Contaminants
Actions Planned
Schedule Responsibility
EPA
Contact
Orders for information	EPA-WD
Field surveys to target sources	EPA-WD
Develop allowable discharge limits	EPA-WD
or BMP's
Enforcement	EPA-WD
Eliminate storm drains causing	Ecology
known problems
Field surveys to identify sources
Enforcement/Criminal i nvesti gati ons
Develop best management practices
Provide technical assistance to
state
Compli ance i nspecti ons
Orders; Enforcement
Investigate subpoenas	EPA-ORC
TSCA sec 11(c) served
Identify chemicals of concern 7/87	EPA-OPS
Identify priqrity air sources FY 88	ATD
and contaminant routes
WOO/Parkin
WOO/Parki n
WOO/Parki n
WOO
EPA-ESD/Criminal D. McClary
Investigators
EPA-ESD
EPA-ESD
EPA-ESD
EPA-ESD/ATD/ORC/HWD
B. Schmidt
B. Schmidt
i
Hamill or
Dabroski
J. Underwood
G. Abel
Progress
Indicator
it of orders
Di scharge 1imi ts
Indi ctments/
Convictions
Inspection Reports
# of areas
"screened" clean, or
"targeted" as dirty
List & chemicals
Air emissions of
chemicals of concern
^ These activities are also shown under Objective 2.
18

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Strategies
OBJECTIVE 3:	Target Compliance and Enforcement Efforts to Reduce and Deter Inputs of Problem Pollutants
1-3 Year
Objective	Actions Planned	Schedule Responsibility
2. Identify toxic dischargers
and control/eliminate discharges
into PS
Toxic management
approach for NPOES
di scharges1
7/86
Municipal Treatment
facilities^
Develop action plans to control
sources, determine sediment
remedial actions.
Identify & prioritize initial
set (15) of dischargers of
chemicals of concern
Develop guidance for	7/86
biomonitoring, ambient monitoring,
and chem. discharge measurements
Develop state capability to do 7/87
tests
Enforce against majors, sig. minors
EPA Admin orders as necessary
Compliance inspections
Upgrade to secondary
Enforce pretreatment regulations
Oversight
Pretreatment compliance inspections
in targeted areas
Enforcement followup
Elliott Bay Final action plan	6/87
0 Commencement Bay action plan	6/87
° Everett Harbor action plan	10/87
EPA-WD
EPA-WD
EPA-WD
EPA-WD
EPA-WD
Ecology/EPA-WD
Ecology
Ecology
EPA-WD
Local Agencies/
EPA-WD
Local Agencies/
EPA-WD
EPA-WD
Ecology
EPA/Ecology
EPA
Contact
WOO
H. Geren
H. Geren
WOO/H. Geren
WOO
WOO/H. Geren
WOO/H. Geren
WOO/H. Geren
J. Underwood
B. Courson
J. Underwood
Progress
Indicator
Toxics Discharged
from reg. sources
Action Plan
Action Plan
Action Plan
1. These activities are also shown under Objective 2.
19

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Strategies
OBJECTIVE 3: Target Compliance and Enforcement Efforts to Reduce and Deter Inputs of Problem Pollutants
1-3 Year
Objective
Actions Planned
Schedule
4. Clean up existing Hazardous Waste Sites
Commencement Bay
Eagle Harbor
(Dependent on
making the NPL)
Harbor Island
Source control program
(See Obj. 2 above)
PCB Mitigation Plan
Determine if & where remedial
action may be warranted (ROD)
Decision on next phase of
superfund project for Comm. Bay
Enforcement Policy
Evaluate remedial actions (FS)
6/87
10/87
10/87
Completed
6/86
Evaluate data from state survey
of Eagle Harbor sediments
Evaluate data from RCRA	7/86
enforcement action
Determine additional data needs, 8/86
develop workplan to acquire data
Gather additional data, analyze 10/87-6/88
to determine extent of contamination
in the harbor, on the Wyckoff
property an,d whether contaminants
are migrating off-site
Evaluate need for remedial	6/88-3/89
measures (FS)
Select and implement remedial 7/89
measures (ROD)
Approve Phase I of Remedial 6/86
Investigation Plan (prepared by
Ecology)
Investigation planned to start 1/87
Evaluate data from Phase I	6/87
investigation to determine
extent of contamination on Island
Responsibility
Ecology
Ecology/EPA-WD
EPA-HWD
Ecol ogy/EPA-HWD
Ecology/EPA-HWD
EPA-HWD
EPA-HWD
EPA-HWD
EPA-HWD
EPA-HWD
EPA-HWD
Ecology/EPA-HWD
Ecology/EPA-HWD
Ecology/EPA-HWD
EPA
Contact
B.	Courson
B.	Courson
B.	Courson
B.	Courson
B.	Courson
B.	Courson
B.	Courson
B.	Courson
B.	Courson
B.	Courson
B.	Courson
B. Courson
B. Courson
Progress
Indicator
Plan
Report
Decision/Recom-
mendation to HQ
Evaluation Report
Evaluation Report
Report
Decision Memo
Recommendations to HQ
Plan
Report
20

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Strategies
OBJECTIVE 3: Target Compliance and Enforcement Efforts to Reduce and Deter Inputs of Problem Pollutants
1-3 Year
Objective
Strandley
Eliminate point source
biological contamination
Municipal Treat-
ment facilities
Federal Facilities
Septic Tanks
Agricultural
Activities
Actions Planned
Determined need for further inves-
tigation (are contaminants
migrating off of the Island,
affect on biota, etc)
Develop Phase II of field survey
(same timing as PSEP)
Analyze data to identify sources,
migration pathways, source control
requirements, remedial measures (FS)
Implement remedial measures
Excavate & store PCBs,
Excavate & store dioxin
Stabilize/Prevent further migration
Compliance inspections
Upgrade to secondary
Enforce fecal coliform standards
Upgrade inadequate outfalls
CSO's
Eliminate raw discharges into Sound
Salmon Beach
Fort Ward
Increase use of environmental
auditing at Fed. Facilities
to detect & solve pollution problems
205j Projects
205(j) Projects
Schedule Responsibility
8/87
9/87
8/88
3/89
1986
EPA-HWD
EPA-HWD
EPA-HWD
EPA-HWD
PRPs
EPA-HWD
Ecology/EPA
Ecology
EPA-WD
EPA
Contact
B.	Courson
B.	Courson
B.	Courson
B.	Courson
B.	Courson
WOO
C. Smi th
DSHS/Ecology/Couties WOO
SCS/Counties/Ecology WOO
Progress
Indicator
Report
Workplan
Report
Report
Amt. of specific
effluents
discharged
# of facilities
that are audited
21

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OBJECTIVE 4: Design and Implement Comprehensive Monitoring Program
1-3 Year
Objective	Actions Planned	Schedule
Design monitoring program to
meet management needs for the
Sound
2. Implement monitoring program
0 Propose monitoring program	11/86
options—complete Contractor
Study
° Preferred option selected;	6/87
Monitoring program adopted
with assigned roles and
funding
° Field sampling underway	6/87
per design
° Routine evaluation of	1/88
data and reports distributed
0 Atlas and State of the	1/89
Sound in biannual updates
to reflect monitoring results
Responsibil itv
EPA/PSWQA
PSWQA
EPA
Contact
J. Underwood
J. Underwood
J. Underwood
Strategies
Progress
Indicator
Contractor
PSWQA Plan
Include in FY 88 SEA
22

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Strategies
OBJECTIVE 5: Develop Management Tools, Structure, and Long Range Program Support to Clean Up Puget Sound
1-3 Year
Objective
1. Develop a plan to address
a long term cause/effect
model
2. Develop and implement
management tools that
promote more efficient
and effective management
3.	Establish and implement a
Puget Sound Institute to
Focus/coordinate long-term
Puget Sound research at the
University of Washington
4.	Foster public understanding
of and participation in
PS initiatives through
development and
implementation of public
outreach programs
Actions Planned
° Evaluate the NOAA funded
source/fate/effects model
° Evaluate other parallel
efforts in system
understanding and
representation
0 Initiate development of a
pollutant loading data base
0 Identify objective needs for
use of model in PS
0 Establish and Implement
standard protocols
for more consistent and
reliable data collection
and analysis
0 Establish a PS regional
Data Management system
to facilitate data
exchange and data analysis
° Fund Post-doctoral work
Maintain citizen
advisory committees for
urban bays
Maintain traveling
exhibit funded by Science
Center
Support Adopt-a-Beach
Program
Schedule Responsibility
1/88
1/88
6/87
10/87
EPA-WD
EPA-WD
EPA-WD
PSEP
10/86	EPA-WD
8/86
PSWQA/EPA-WD
U of W/EPA
Ongoing, OPS
each bay
7/86
7/86
OPS
OPS
EPA
Contact
J. Underwood
J. Underwood
H. Geren
J. Underwood
J. Underwood
J.	Underwood
J.	Underwood
J.	Underwood
J.	Underwood
J.	Underwood
Progress
Indicator
Evaluation &
Recommendation
Evaluation &
Recommendation
Recommendation
notebook
available by
10/86
Format agreement
Data bibliography
established
Cooperative
Agreement
Cooperative
Agreement
Cooperative
Agreement
23

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Glossary of Abbreviations
Amt:	Amount
CSO:	Combined Sewer Overflows
DNR:	Washington State Department of Natural Resources
DSHS:	Washington State Department of Social and Health Servi
Ecology: Washington State Department of Ecology
Enf:	Enforcement
F.S.:	Feasibility Study
HB 815:	House Bill 815
EPA-ATD: Region 10's Air and Toxics Division
EPA-ESD: Region 10's Environmental Services Division
EPA-HWD: Region 10*s Hazardous Waste Division
EPA-OPS: Region 10's Office of Puget Sound
EPA-ORC: Region 10's Office of Regional Council
EPA-WD:	(Region 10's Water Division
NOAA:	National Oceanic and Atmospheric Administration
NPL:	National Priority List
PCBs:	Polychlorinated Biphenyls
PRPs:	Principle Responsible Parties
PS:	Puget Sound
PSDDA:	Puget Sound Dredge Disposal Analysis
PSEP:	Puget Sound Estuary Program
PSWQA:	Puget Sound Water Quality Authority
Reg:	Regulated
R.I.:	Remedial Investigation
R.O.D.: Record of Decision
SCS:	U.S. Soil Conservation Service
SEA:	State, EPA Agreement
STP:	Sewage Treatment Plant
Subs:	Substances
TSCA:	Toxic Substances Control Act
WOO:	Region 10's Washington Operations Office
U of W:	University of Washington
24

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Headquarters Actions Needed
During the past few years, Region 10 has made
substantial progress toward developing an improved
understanding of the impact of man's activities on the
water quality and biological resources of Puget Sound.
Enhanced control of many pollutants through
implementation of pretreatment and wastewater
permitting requirements, and installation of municipal and
industrial waste treatment facilities have gone a long way
toward controlling water pollution, protecting marine fish
and shellfish, and minimizing the risks to public health.
Information generated by the urban bay and system-wide
studies have enhanced the region's ability to characterize
the current health of the Sound and to understand the
impact of human activities on estuarine environmental
quality.
As evidenced in the foregoing sections, Region 10 is
employing a variety of techniques in addressing Puget
Sound environmental problems. Through coordinated
efforts, the region is striving to develop a comprehensive
program which involves a near-term search for solutions
to current environmental and management problems,
together with enhanced long-term research and
monitoring to improve predictive capabilities.
Support of the Puget Sound program requires
extensive commitment, both in terms of staff and funding
requirements. Current resource limitations prevent the
Region from undertaking all of the activities that have
been identified as critical to maintaining the quality of
the Sound. More extensive involvement by headquarters
in certain aspects of the program may be necessary to
achieve the program's goals. Headquarters' assistance in
the following areas makes sense not only because these
efforts will directly benefit the region, but more
importantly because the products which result will have
utility nationwide. Headquarters' assistance is requested
for the following activities:
25
I.
Support for Toxic Control Activities
Source control of toxic discharge to the Sound is our
top priority. We are aggressively moving forward in
instituting additional biomonitoring and chemical
monitoring requirements on permittees, and preparing for
limiting specific toxic chemical discharges. We are
finding that assistance will be extremely important to us
in making this approach work. Key areas are listed below.
Develop permittee biomonitoring requirements
(i.e., technical basis, policy guidance,
recommended protocols).
Provide training support for state agency staff
concerning enhanced chemical and biological
monitoring requirements.
Provide funding support to state agencies for
enforcement and toxics source control efforts
in Puget Sound (i.e., 104b funds).
Provide resources/technical support for
development of approach to storm drain and
CSO permitting and development of models for
storm drain and CSO permits.

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Provide resources/technical assistance
for the development of an approach to establish
permit discharge limits for toxics in urban bays.
Provide resources/technical assistance in
developing tools for tracing pollutants from
sources to deposition areas (i.e.,
"finger-printing techniques".
II. Support for the Development of Regional Sediment
Criteria
The Action Plans for the urban bays will be founded
upon interim sediment criteria to seek the basis for
source reductions, remedial actions and priority setting.
These interim criteria will be needed in FY 87, far in
advance of the headquarters criteria setting schedule.
Additionally, Substantial field cause and effect data
is being collected as part of the characterization effort in
each urban bay. This data will be useful in associating
chemicals to biological effects and helping us determine
fruitful next steps in establishing interim criteria. Two
suggestions are offered for enhancing work in this area:
Better coordination and support between the
regional and headquarter sponsored efforts to
develop criteria for use in the management of
contaminated marine sediments. Specifically,
allocating some criteria/standards funds to
Region 10 to carry out parts of the sediment
criteria appropriate to Puget Sound urban bay
work would add to the technical basis of our
work and more effectively build support into
the national effort.
Headquarters Actions Needed
Provide funding/technical assistance to support
development of an approach to establish
discharge limits which will prevent exceeding
interim sediment quality values.
HI. Support for Development of Enhanced Biomonitoring
Tools
Key to the success of the toxic control approach is
the ability to measure biological effects, particularly at
the chronic level. We are finding this to be extremely
limiting to us as we move forward. There do not appear
to be good chronic tests available, particularly with
critters native to Puget Sound. We have excellent
scientists and facilities to work in this area (University of
Washington, EPA's Newport Lab, etc.) but lack funding
support.
Provide funding/technical assistance for the
development of chronic bioassays for use in
testing a variety of media.
Provide funding/technical support for the
identification of pollution sensitive west coast
species which can be used in ambient and
biomonitoring.
IV. Support for Toxic Hotspot Remedial Action Pilot
Project
An important element of the long term solution of
Puget Sound toxics problems is what to do with
26

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Headquarters Actions Needed
the toxic hot spots in the urban bays. One option is
to physically remove the more severely
contaminated hot spots and dispose of them upland
in properly managed sites. Commencement Bay
superfund site has both the "hot spots" and upland
sites in close proximity. A demonstration project
would provide regional and national information on
procedures, concerns, costs and other facets of this
option.
Provide funding to support a dredging
demonstration project for the removal of an
urban bay toxic hotspot with disposal in a
confined or upland site.
V. Enforcement Referrals
Regional resources currently involved in extensive
enforcement referral support could be better used in field
work on the toxics control strategy. Streamlining the
referral process offers great opportunity for improved use
of limited staff, increased regional morale and more
effective and expeditious enforcement actions.
Streamline the enforcement referral process by
allowing the Region to tailor the level of
referral support on a case-by-case basis as
opposed to a standard level of support for all
cases.
VI. Opportunities for Loaned Staff from Headquarters
Both the Region and Headquarters could benefit
from a Headquarters rotational assignment
27
to the field. Specific areas where extra staff would
be of assistance include:
Writing NPDES permits
Writing 308 letters
Helping with enforcement actions
Providing assistance in writing defensible
biomonitoring requirements into permits
VII. Increase Commitment for Regional Staff
Currently the Office of Puget Sound (OPS) has four
position with only one position supported by
Headquarters. The additional three positions have been
supported by the Region. With the anticipated cutbacks
in FY'87, funding may no longer be available to cover the
three positions. Headquarters support for these positions
would ensure that OPS successfully implements the
Environmental Action Program for Puget Sound.

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References
Puget Sound Water Quality Authority, 1986. Issue Papers:
Combined Sewer Overflows
Comprehensive Monitoring of Puget Sound
Contaminated Sediments and Dredging
Industrial and Municipal Dischargers
Industrial Pretreatment
Nonpoint Source Pollution
Oil Spill Response
Public Involvement in Water Quality Policy Making
Tetra Tech, 1984. tyecision-Making Approach for the
Commencement Bay Nearshore/Tideflat Superfund
Project. Prepared for the Washington State Department
of Ecology. Tetra Tech, Inc., Bellevue, Washington.
64 pp. TTB010F
Tetra Tech, 1986. Elliot Bay Toxics Action Program:
Initial Data Summaries and Problem Identification.
Prepared for U.S. EPA Region 10 and Washington
Department of Ecology. Tetra Tech, Inc., Bellevue,
Washington. 181 pp.
Tetra Tech, 1985. Elliot Bay Toxics Action Program:
Intern Work Plan. Prepared for the U.S. EPA Region 10
and Washington Department of Ecology. Tetra Tech,
Bellevue, Washington. 35 pp. TTB062F
Tetra Tech, 1986. Everett Harbor Toxics Action
Program. Initial Data Summaries and Problem
Identification. Prepared for U.S. EPA Region 10, Office
of Puget Sound. Tetra Tech, Bellevue, Washington.
U.S. Environmental Protection Agency, 1986. Urban Bay
Approach, Toxics Control Strategy. Unpublished draft.
U.S. EPA Region 10, Office of Puget Sound.
28

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