US EPA, Region 10
Fact Sheet for Source Control
on the Thea Foss &
Wheeler/Osgood Waterways
Organization of this Fact Sheet
EPA has fielded countless questions about "source control" since the City and EPA
signed the Agreed Order on Consent for pre-remedial investigation and design work
in the Thea Foss and Wheeler/Osgood Waterways in 1994. While the concepts and
ideas behind "source control" are the same for all of the Commencement Bay
waterways, Thea Foss/Wheeler Osgood is unique because stormwater plays a
significant role in the overall source control picture. This fact sheet is divided
into two "chapters", one for source control in general and one for stormwater
because the two subjects are separate but still closely related.
Background
The Thea Foss & Wheeler/Osgood Waterways are part of the Commencement Bay/Nearshore
Tideflats ("CB/NT") Superfund Site. Since 1989, various efforts have been taken to
identify, control and, where feasible, eliminate contaminant sources to the Thea
Foss and Wheeler-Osgood Waterways. These efforts are important because, before
sediment cleanup can occur, sources of the chemicals need to be either eliminated
or reduced to a level so that clean sediments will not be recontaminated. This
fact sheet is intended to provide some basic information about sources and the
approach being taken to control sources to the Thea Foss and Wheeler/Osgood
Waterways.
Types of sources: Sources of chemicals seen in the waterway are generally related
to practices or activities (past or current) that occur around the waterway. In
general, chemicals get into the waterway by:
Direct discharge to the water from industrial operations, stormwater
outfalls, natural seeps, point and nonpoint discharges.
Eroding or leaching from banks or upland soils where, perhaps, spills
occurred in the past or material was deposited (e.g., slag or other wastes).
Groundwater discharge to the waterway where the groundwater itself may be
contaminated or might be moving through contaminated soil/sediment on its way to
the waterway.
Who is responsible for Source Control? How does Source Control
happen?
EPA & Ecology have a cleanup plan for the CB/NT Superfund site ("Source Control
Strategy") that puts Ecology in charge of identifying and controlling upland
sources while EPA focuses on remediating sediments. At sites where the two
authorities overlap (i.e., along the banks & beach lines), EPA and Ecology
determine jurisdiction depending on the type and extend of the contamination and
whether it is more feasible for Ecology or EPA to do the cleanup.
Chapter 1: Source Control in General
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Ecology's Role: Ecology conducts inspections of possible sources of contamination
(including businesses and stormdrains). Ecology samples upland and along the
waterway, reviews discharge data, and conducts inspections to determine whether a
site is a potential or confirmed source of problem chemicals to the waterways.
Based on definitions in EPA's Record of Decision (ROD), Ecology classifies sources
as either: List 1 (potential source), List 2 (probable source) or List 3
(confirmed source). Furthermore, a source may be considered as "major" because it
is most directly linked with sediment impacts. Then, and often in collaboration
with the City, Ecology does more investigation and/or source control work on the
prioritized sources. Ecology uses many regulatory tools to control sources
including the Model Toxics Control Act (MTCA), for groundwater and upland sources,
and pollutant discharge permits, for direct discharges to the waterways.
The following five levels of source control, or "milestones" have been developed
for tracking and reporting source control efforts for each problem area or the
waterways.
Milestone 1: All ongoing, confirmed sources of problem chemicals are
identified as List 1, 2 or 3, have been completed.
Milestone 2: Essential administrative actions (e.g., National Pollutant
Discharge Elimination System "NPDES" permits, MTCA orders, consent decrees) in
place for major sources.
Milestone 3: Essential remedial actions (e.g., construction, soil removal
complete, best management practices are in place) for major sources are
implemented.
Milestone 4: Administrative actions (e.g., MTCA orders, NPDES permits) are
in place for all ongoing confirmed sources plus any new sources that have been
identified.
Milestone 5: Remedial actions for all ongoing sources are implemented.
In the Thea Foss Waterway:
The Head of Thea Foss and Wheeler/Osgood problem areas are complete thru
Milestone 2.
The Mouth of Thea Foss problem area is complete thru Milestone 5.
EPA's Role: EPA maintains an oversight role on Ecology's source control work,
reviewing and approving Milestone reports as they are issued. EPA's role includes:
Consulting with Ecology on NPDES (discharge) permits for the CB/NT area and
any upland source control actions where, for instance, banks may be involved or a
direct source to the waterway may be removed.
Working closely with Ecology and the City on implementation of the Stormwater
Management Plan and major stormwater drain investigations (see Chapter 2).
Working closely with the City on the collection of data and information about
the waterway as part of the agreement requiring enough information be collected to
develop a cleanup plan for sediments in the waterway.
Reviewing and commenting on the City' s proposed shoreline development
permits and environmental reviews of shoreline projects (this is usually in
coordination with other reviewing agencies, including Ecology).
The City's Role: The City of Tacoma has been very actively involved in source
control since it is a PRP (Potentially Responsible Party) in the Thea Foss &
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Wheeler/Osgood Waterways. As the lead PRP for pre-remedial design, the City has
been most visible in directing all the work done to date (e.g., data gathering &
evaluation). Meanwhile, it is important to note that the City is actively
controlling its own sources. A list of the City's efforts include:
Implementing the Stormwater Management Program for Thea Foss Waterway. This
plan was required as part of the City's NPDES permit from Ecology and the Agreed
Order on Consent with EPA. See Chapter 2 for more information on stormwater.
Cleaning up City-owned upland parcels as required by Ecology under the
regulatory authority of the State's Model Toxics Control Act (MTCA).
Working on cleanup of the Coal Gas site as one of several parties involved
with this site - this is another Ecology MTCA site.
Working to coordinate downtown and other shoreline development projects with
EPA's Superfund program as well as the host of other state and federal agencies to
ensure that approvals and permits for development do not conflict with the overall
Superfund cleanup project.
Chemicals & Data
Chemicals of Concern (COCs): Not all the chemicals found in the sediments of the
waterways are thought to be problems from the standpoint of recontamination. Many
of the chemicals found in the waterways came from historical activity that is no
longer occurring. As these activities and sources have changed over time, so too
has our understanding of the chemicals posing a recontamination threat to
sediments. The tentative list of COCs shown below comes from the Round 2 Data
Evaluation Report and will be revised in the Round 3 Data Evaluation Report,
available for review in Summer 1998.
Tentative COC list:
Bis(2-ethylhexyl)phthalate
Dibenzo(a,h)anthracene (an HPAH)
Pesticides (4,4'-DDE & 4,4'-DDD)
- Benzo(g,h,i)perylene (an HPAH)
- Ideno(1,2,3-cd)pyrene (an HPAH)
- PCBs
How does the data correlate to source control? On a large scale, source control
and data are about to converge in the form of EPA's proposal for sediment cleanup.
The data have been collected, analyzed and statistically treated to tell where
chemicals are now, how they're transported and the effect they're likely to have in
sediments. With application of a model, the data provides two pieces of
information related to source control:
the final list of COCs based on current rates of input to the waterways, and
estimates of the levels of control needed to reduce COC inputs to the point
that sediments are not likely to recontaminate (called "source control goals").
While these two pieces of information are very important to EPA's cleanup decision,
it is equally important to remember that sources continue to be investigated and
controlled through the efforts of both Ecology and the City. Source control is a
continuous process. Even as EPA provides the Round 3 Report and a proposed
cleanup plan for public review next summer, source control will continue to occur
up to, and possibly through, remediation.
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Chapter 2: Stormwater in
Thea Foss/Wheeler Osgood
Stormwater: What It Is, How It Fits Into
Source Control
Stormwater is just one of several possible sources of contamination to the Thea
Foss Waterway; however, it is a significant potential source since over 5,700 acres
of land drains to the waterway. Stormwater consists of everything and anything
that can get into the City stormwater collection system including runoff from
yards, driveways, streets, parking lots, and roofs. It also includes runoff from
industrial or commercial areas. EPA required a detailed plan for the management of
sources of contamination to stormwater in the Thea Foss Waterway because it is such
a large drainage area as well as a Superfund site about to undergo cleanup. (The
detailed plan is actually required in a special condition to Ecology's general
NPDES permit for stormwater and is referred to as "SWMP/Thea Foss" .) The rest of
this chapter explains the distinction between municipal and industrial stormwater
and then explains how the City works with Ecology and EPA to control municipal
stormwater.
While stormwater is only one type of discharge to the waterway, there are several
ways to discuss stormwater, depending on your interest. Generally, it helps to
think of stormwater as being either (1) a municipal discharge (as described above)
or (2) an individual (usually industrial or commercial) discharge.
Municipal stormwater discharges
Permit & management
Ecology's general permit does not address individual industrial sites that
may also discharge stormwater (e.g., privately-owned & managed discharges such as
JM Martinac, Superior Oil).
Ecology's general permit puts Tacoma in a class with other cities but the
City has done more than other municipalities in terms of planning and
implementation to meet source control needs because Thea Foss sediments are being
cleaned up under Superfund.
Combined with the requirements of other documents (such as the City's Agreed
Order on Consent with EPA), the SWMP/TFoss establishes an overall "stormwater
process".
Municipal stormwater is difficult to control because
It includes whatever gets into the City's stormwater collection system.
Characterizing the chemicals is difficult because flow volumes are variable,
making it hard to capture samples, and because upstream use of COCs may be
intermittent or seasonal.
Characterizing the chemistry of what happens when large freshwater volumes of
water mixes with saline waters in the waterway is complex.
Industrial stormwater discharges -
They're usually covered by individual NPDES permits
They're generally easier to characterize chemically because what goes into
the stormwater is better known and the actual drainage areas are MUCH smaller and
easier to sample (an exception might be a railroad yard) - and so,
permits may include actual effluent limits, depending on the chemical
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nature of the discharge - and
emphasize best management practices which are ways to prevent
pollutants from getting into stormwater flow in the first place.
The Stormwater Process: The City defined a "stormwater process" (it's outlined in
the SWMP/Thea Foss) and uses it to control COCs in municipal stormwater. This
iterative process allows the City to repeat certain parts of it as needed (e.g., do
inspections as new sources move into the basin, revisit sites for updated best
management practices, public education). The basic process is as follows:
Characterize the effluent - find out if the discharge from a particular
stormdrain contains problem chemicals or COCs.
Identify possible sources of the chemical(s) up the drain line - this may
involve sampling the outfalls to the waterway, coordination with other
municipalities, searching records, conducting inspections of businesses or the
lines themselves. It might also involve significant follow-up if inspections
reveal problem practices that need to be corrected.
Prioritize sources - which is relatively straightforward on a short line or
small drainage, but is a challenging task for large drains such as 237A/B ("Twin
96ers" or "Twins"). For the Twins, the City divided the 4,900 acres into sub-
basins and is prioritizing the areas likely to have sources of problem chemicals/
COCs for attention first.
Decide what actions are needed next, depending on the types of drainages and
potential sources that might be in the basins. For example, the decision may be
where to sample the stormwater line relative to a potential source as opposed to
doing a drive-by inspection. The decision may additionally depend on the whether
the land use is commercial, industrial or residential.
Carry out the work to control the source. The control work may range from
reviewing best management practices with commercial or industrial contributors to
the drain line to issuing orders as allowed by municipal and/or state
administrative codes.
Keep track of decisions made and work done or required. Evaluate whether
source control actions are/have been effective and follow-up as needed (e.g., re-
visit sites, re-sample drain lines or outfall, verify treatments or best management
practices implementation).
Report the results of the process with respect to whether or not source
control has been effective in controlling the release of problem chemicals/COCs to
the waterway.
Other controls
Street sweeping keeps the contribution of dust/dirt and other particulates
down. This is important because particulates settle out into marine sediments and
are often associated with high concentrations of hydrocarbons.
Line inspections which verify connections, flow direction and whether
maintenance may be needed. This is important because stormdrains in the tideflats
are old enough that sanitary waste streams were once included.
Public education to make citizens aware of individual responsibilities (e.g.,
fertilizers, car-washing, oil-changing).
Stormwater Management, How It Works With Source Control: Remembering that
stormwater discharges are only a part of the overall source control picture for
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Thea Foss/Wheeler Osgood, the following loosely parallels the concepts of major/
minor sources and source management described earlier in Chapter 1.
Ecology and EPA worked with the City to identify a list of the stormwater
drains that, in the past or currently, provide contamination to the sediments.
These are generally referred to a the "major" drains and include: 230, 235, the
Twin 96ers (237A & 237B), 248/243 and 254.
The City applied the "stormwater process" to these drains according to the
schedule in the SWMP, which targets completion of source identification and
characterization on the major drains by 12/31/97. An important note: the City is
on track to meet the deadline for it's major drains!
Ecology and the City investigated other drains around the waterway and the
City applied various controls as problems were identified.
The City and Ecology focused part of the resources available for stormwater
on getting better estimates of the pollutants emptying into the waterway. As of
this fall/winter, the City and Ecology are in the process of collecting a second
season of stormwater sediment data
The City is preparing what we currently call Drain-by-Drain Reports for the
major drains. These reports aren't required by the SWMP/Thea Foss, but rather by
agreement between the City and EPA as a way to report the progress of stormwater
source control. The reports basically describe where the City is in the
"stormwater process" on each drain and include information like:
maps
lists of businesses or sources to the drain, which ones were
inspected, what the results of inspections were, follow-up work and visits, as well
as results of catch basin or other sampling
inspections of, and maintenance work on, City-maintained portions of
the drainage
When EPA proposes a cleanup plan for the waterway, a comprehensive stormdrain
report will also be completed and provided for public review. This document will
summarize the City's stormwater source control efforts for the whole Thea Foss
drainage, as opposed to separate drain reports described above.
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Summary: Looking Forward to
Cleaning Up
In summary, Ecology and the City have
accomplished a lot since the Superfund order for
pre-remedial design work was signed in 1994.
While this fact sheet provides some background and an outline of the source control
approach, it's important to understand that there is more to be done. As described
above, source control is a continuous effort. A brief list of source control work
scheduled for completion before sediment cleanup begins includes the Tacoma Coal
Gas Site where Ecology has a MTCA order in place for upland source control. At
this site the remaining concerns focus on the extent to which groundwater moving
into the waterway will recontaminate clean sediments.
The next important pieces of the source control picture are the comprehensive
stormdrain report (Chapter 2) and the Round 3 Data Evaluation Report with source
control goals and a recontamination assessment for the waterways (Chapter 1).
Otherwise, much of the source control work around Thea Foss and Wheeler/Osgood is
complete and Ecology will be working with EPA to complete the Milestone Reports.
Individual discharge permits (e.g., Martinac, Tosco, Unocal) will be re-issued as
they expire (i.e., every five years) and will be available for public review
according to the State's administrative procedures.
Questions? Who to Call
At Ecology
Dave Smith (360) 407-6250
Manager, Urban Bay Action Team (Commencement Bay)
Specific sites may be assigned to different project managers
and Dave will provide the appropriate contact for you.
At EPA
Kris Flint (206) 553-8155
Remedial Project Manager for Source Control
Christine Psyk (206) 553-1748
Remedial Project Manager for Thea Foss/Wheeler Osgood Waterway
At City of Tacoma
Mary Henley (253) 502-2113
Manager of the Superfund Pre-Remedial Design Work
For those with impaired hearing or speech, please contact EPA's telecommunication
device for the hearing impaired (TDD) at (206) 553-1698. To ensure effective
communication with everyone, additional services can be made available to persons
with disabilities by contacting one of the EPA numbers listed above.
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