SEPA
United States
Environmental Protection
Agency
Region 10
Seattle, WA
March 2011
The Lower Duwamish Waterway cleanup took a big step forward recently when the Lower Duwamish
Waterway Group, a partnership of City of Seattle, King County, Port of Seattle, and The Boeing Company,
submitted a draft study of cleanup alternatives for review by the U.S. Environmental Protection Agency and
Washington State Department of Ecology .
EPA and Ecology invited the public to review and comment on the Draft Final Feasibility Study for the
Lower Duwamish Waterway. We received more than 300 letters from individuals, businesses, interest
groups, tribes, and government agencies and have summarized what we heard in this document.
Who commented?
Most of the letters came from people in
and around the Seattle area. EPA and
Ecology worked hard to inform and
engage local residents, including non-English
speakers. As a result, we heard from many
community members.
We heard from 15 environmental and community
interest groups including People for Puget Sound,
the Duwamish River Cleanup Coalition, the South
Park Neighborhood Association, the Cascade Land
Conservancy, and the Sierra Club.
We heard from more than 40 businesses, many
located along the Duwamish River, including Ash
Grove Cement Company, Delta Marine Industries,
Alaska Marine Lines, Duwamish Shipyard Inc., and
Boom Boys Cranes.
The Suquamish and Muckleshoot Tribes submitted
letters. Three government agencies also submitted
comments; these include the Seattle-King County
Public Health, the Washington State Department
of Transportation, and the National Oceanic and
Atmospheric Administration.
What did we hear?
We received a lot of comments, but the most
common are included below.
Selecting a cleanup method
Many people voiced opinions on a preferred
cleanup alternative. The alternatives most frequently
mentioned were 3C (a combination of dredging,
capping and natural recovery ), 6R (dredging a large
portion of the river), and "DRCC Option 7" (a
different option suggested by the Duwamish River
Cleanup Coalition that includes a more extensive
sediment cleanup than the FS Alternatives and
an emphasis on controlling the upland sources of
contamination).
"I believe that alternative 3 Cprovides the best
solution for the Duwamish in the timeliest manner."
"Only one option (Alternative #6R) provides a
permanent cleanup that ensures it is done once and
done right."
"The more I read, the more I am in favor of
this latest Option #7, specifically addressing
contaminants from upriver and the needs of the
Duwamish River community."
Continued next page
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Your Comments on Lower Duwamish Waterway Cleanup
Each alternative should undergo an
Environmental Justice analysis
Many people asked that an Environmental Justice
analysis be conducted to identify vulnerable
communities affected by the cleanup, and evaluate
how these communities will fare under each of
the alternatives. They asked that this analysis be
included in the Feasibility Study and be a key
consideration in selection of a final remedy.
"EJ populations are disproportionately affected by
the contamination from the Duwamish River and
they will be the ones to bear the brunt of what is
not cleaned up under any selected alternative."
Controlling upland pollution sources
A lot of comments discussed the importance of
reducing pollution entering the waterway to avoid
new contamination and to help keep cleaned-up
areas from becoming contaminated again.
"Upriver pollution source control must be addressed
for an effective and equitable cleanup."
"If upriver sources of contaminants of concern
are determined to be high enough to prevent an
effective cleanup, then an upriver source control
program must be part of the final cleanup plan."
Who pays for the cleanup?
Businesses and individuals stated concerns about the
cost of the project and who will pay for the cleanup.
Many business owners along the Duwamish were
worried that the cost of paying for the cleanup
would put them out of business. Individuals were
concerned about tax-payers bearing the costs of the
cleanup.
"My concern is for the industrial business along the
river. Seattle needs these businesses and the family
wage jobs they provide. Don't make them go out of
business."
"Hove the polluter-pays principle -please keep it up."
"We also appreciated that the costs and impact
of the cleanup will be borne by area businesses,
governments and taxpayers."
Reaching cleanup levels and goals
Some commenters were disappointed with the FS
conclusion that it is not possible to establish cleanup
levels that would allow people to eat an unrestricted
amount of resident fish and shellfish.
Others were satisfied with the Feasibility Study
alternatives and goals.
"The present document is inadequate. We support a
cleanup level that will allow safe eating offish and
shellfish."
"I believe that the list of alternatives outlined in
the Draft Final Feasibility Study is complete,
comprehensive and protective of the environment."
"While all options can potentially reduce the risks by
up to 90percent, none would leave the river clean
enough to ensure that people can fish freely with no
risk to their health.'"
Record of Decision (ROD) and
selecting a remedy design
Many businesses expressed a desire to allow for
flexible cleanup decision making.
"We feel that advance cleanups and the Record of
Decision ('ROD') must provide a flexible decision-
making framework for conducting individual site
cleanup actions and provide incentives and legal
protection for businesses to move forward with and
complete cleanup actions."
"The ROD must provide a process and contain
incentives for waterfront and water-dependent
businesses to initiate and complete cleanup actions."
What happens next?
EPA and Ecology considered all of the comments
we received and have provided a letter to the Lower
Duwamish Waterway Group requiring several
changes to the draft Feasibility Study.
LDWG will revise the Feasibility Study in response
to the Agency comments, and it will be finalized
in 2011.
Some of the Agencies' major comments on the FS
include requirements to:
• Do more sensitivity analyses to better
understand how inputs to the natural recovery
model affect its predictions;
• Reevaluate the assumptions used to estimate
areas, volumes, costs and durations of the
alternatives presented in the FS;
• Incorporate into the FS new treatment
technologies such as amendment of sediments
with granular activated carbon;
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Your Comments on Lower Duwamish Waterway Cleanup
IM^^
Lower Duwamish Waterway
Photo by John Monnat
What happens next?
Continued
• Reconsider whether potential for scour from
ships and tugboats maneuvering in berthing
areas has been adequately addressed in the
alternatives;
• Include a more thorough discussion of source
control activities in the FS;
• Revise the analysis of alternatives to focus
more on the differences among alternatives
in how quickly exposure to contaminants is
reduced, and less on the similarities in long-
term model predictions.
The Agencies will prepare responses to some of
the major comments we received and post them
on our web site. EPA and Ecology will consider
all of your comments as we prepare a Proposed
Plan for the cleanup in early 2012. Watch for the
opportunity to comment on that plan.
Where con you find
more information?
Copies of all the comment letters submitted
are available at www.ldwg.org along with
more information about the Feasibility Study
and other environmental documents. Visit
EPA for more information about the cleanup
at: www.epa.gov/regionlO/duwamish.html
Visit Ecology for more information about
controlling upland sources of pollution and
other cleanups at:
www.ecy.wa.gov/programs/tcp/sites/lower_
duwamish/lower_duwamish_hp.html
Contact the Duwamish River Cleanup
Coalition the Community Advisory Group
for the site, at: www.duwamishcleanup.org
or(206)954-0218
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United States
Environmental Protection
Agency
Region 10
1200 Sixth Avenue, Suite 900, ETPA-081
Seattle, Washington 98101-3140
March 2011
Lower Duwamish Waterway Cleanup
ThanAs
your comments!
what
Learn More on the Web
Lower Duwamish Cleanup Information
www.epa.gov/regionlO/duwamish.html
Controlling upland sources of pollution:Washington State Department of Ecology
www.ecy.wa.gov/programs/tcp/sites/lower_duwamish/lower_duwamish_hp.html
Duwamish River Cleanup Coalition (community advisory group)
www.duwamishcleanup.org
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