United States Region 10 Environmental Protection 1200 Sixth Avenue Agency Seattle WA July 1986 -SEPA /Environmental Action Program For Puget Sound ------- 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 ------- 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 ------- Puget Sound Location WASHINGTON 1 Puget Sound .••V «"•« Of JU»» 09 F4,C# Port Angelas Seattle Bremerton *Tacoma Olympia ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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. ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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. ------- 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 ------- |