Summary of Attachments for the Fourth Five-Year Review Report for Commencement Bay Nearshore/Tideflats Superfund Site, Pierce County, Washington.


Fourth Five-Year Review Report For
Commencement Bay Nearshore/Tideflats Superfund Site
Pierce County, Washington

Summary of Attachments

OU 01 Attachments

OU 01 Attachment 1 - List of Documents Reviewed

OU 01 Attachment 2 - Historic and Current Fish and Shellfish Advisory Signs
OU 01 Attachment 3 - 1985 Fish Advisory in Commencement Bay
OU 01 Attachment 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound
OU 01 Attachment 5 - Fish and Shellfish Data [Note: it has multiple attachments]

OU 20, 22,19 Attachments

OU 20, 22, 19 Attachment 1 - List of Documents Reviewed

OU 20, 22, 19 Attachment 2 - Site Inspection Checklist for OU 20 and OU 22

OU 3 Attachments

OU 3 Attachment 1 - List of Documents Reviewed

OU 3 Attachment 2 - 2014 Technical Memorandum on Water Quality and I&M
OU 3 Attachment 3 - Public Input on Tacoma Tar Pits Site
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs
OU 3 Attachment 5 - ARARs Review Summary

-------
OU 01 Attachment 1 - List of Documents Reviewed

-------
OU 01 Attachment 1 - List of Documents Reviewed

General / Sediments OU 01, OU-Wide

The Washington State Department of Health (DOH). 2006. Human Health Evaluation of
Contaminants in Puget Sound Fish. October 2006.

Department of Social and Health Services (DSHS). 1985. Precautions Listed for Fishing in Certain
Areas of Puget Sound [including Commencement Bay]. April 12, 1985.

The U.S. Environmental Protection Agency (EPA). 1989. EPA Superfund Record of Decision:
Commencement Bay, Near Shore/Pide Flats. EPA ID: WAD980726368. OU 01, 05. Pierce
County, WA. 09/30/1989.

EPA. 1992. Source Control Strategy: Commencement Bay Near shore / Pideflats Superfund Site.
USEPA SF 1097231. May 1992.

EPA. 1997. EPA Superfund Explanation of Significant Differences: Commencement Bay, Near
Shore/Pide Flats. EPA ID: WAD980726368. OU 01. Pierce County, WA. 07/28/1997.

EPA. 2001. Comprehensive Five-Year Review Guidance. EPA 540-R-01-007. OSWERNo.
9355.7-03B-P. June 2001.

EPA. 2002. Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites.

Available at: http://www.epa.gov/superfund/policy/remedy/pdfs/92-85608-s.pdf

EPA. 2007. Framework for Selecting and Using Pribal Fish and Shellfish Consumption Rates for
Risk-Based Decision Making at CERCLA and RCRA Cleanup Sites in Puget Sound and the Strait
of Georgia. August 2007.

EPA. 2009. Five-Year Review Report. Phird Five-Year Review Report for Commencement Bay
Nearshore/Pideflats Superfund Site, Pacoma, Washington. Prepared by the U.S. Environmental
Protection Agency, Region 10. December 23, 2009.

Hanowell. 2008. Email communication on 12/12/2008 from Ray Hanowell (TPCHD) to Liz Carr,
forwarded to Karen Keeley (EPA). Subject: Historical and Current Fish and Shellfish Advisory Signs in
CB/NT.

McBride. 2012a. Phone communication on 10/31/12 from Dave McBride (WDOH) with Karen Keeley
(EPA). Subject: DOH crab advisory for Puget Sound.

McBride. 2012b. Phone communication on 11/15/12 from Dave McBride (WDOH) with Karen Keeley
(EPA). Subject: Crab tissue data for Puget Sound and state advisories.

National Marine Fisheries Service (NMFS). 2013. Status Review of the Eastern Distinct
Population Segment of Steller Sea Lion (Eumetopias jubatus). Available at:

http://www.nmfs.noaa.gov/pr/pdfs/statusreviews/stellersealion_eastern_statusreview.pdf

Tuttle. 2012a. Email communication on 11/7/12 from Lindsay Tuttle (TPCHD) to Karen Keeley (EPA).
Subject: 2012 Photograph of Advisory Warning Signs in Thea Foss Waterway, Commencement Bay.

1

-------
OU 01 Attachment 1 - List of Documents Reviewed

Tuttle 2012b. Phone communication on 11/5/12 from Lindsay Tuttle (TPCHD) with Karen Keeley
(EPA).

Tuttle 2012c. Email communication on 11/19/12 from Lindsay Tuttle (TPCHD) with Karen Keeley
(EPA). Subject: Thea Foss Fish Advisories.

Hylebos Waterway

AM EC Geomatrix. 2010. CERCLA Mitigation Requirements Evaluation Taylor Way Properties
Tacoma, Washington.

AM EC Geomatrix. 2012. Memo - SMA 42 IB Proposed Mitigation.

Anchor QEA, LLC. 2012. Draft Final Operations, Monitoring, and Maintenance Plan Mouth of
Hylebos Waterway (Segments 3,4, and 5) Tacoma, Washington.

Conestoga-Rovers & Associates (CRA). 2010a. Draft Production Well Investigation Report
Groundwater and Sediment Remediation.

CRA. 2010b. Work Plan Additional Production Well Investigation - Existing Well Geochemistry
Evaluation Groundwater and Sediment Remediation.

CRA. 2011. Draft Data Gap Evaluation for Site Characterization Groundwater and Sediment
Remediation.

CRA. 2013 a. Draft Evaluation of Remedial Technologies Groundwater and Sediment
Remediation.

CRA. 2013b. Remedial Action Construction Report (RACR) Segment 3/4 Dredging and
Disposal and Slip 1 Near shore Confined Disposal (NCD) Facility Mouth of Hylebos Waterway
Consent Decree.

CRA. 2014a. Draft Conceptual Site Model Report Groundwater and Sediment Remediation.

CRA. 2014b. Remedial Action Construction Report - Segment 5 and Slip 1 Mouth of Hylebos
Problem Area Commencement Bay Nearshore/Tideflats Superfund Site Tacoma, Washington.

Dalton, Olmsted & Fuglevand, Inc (DOF). 2009a. Year 10 Cap Monitoring Report Schnitzer
Steel of Tacoma Shoreline Cap Hylebos Waterway, Tacoma, Washington Administrative Order
on Consent No. 10-98-0133.

DOF. 2009b. Soil Characterization Work Plan Wypenn Site Tacoma, Washington.

DOF. 2009c. Sediment Sampling and Analysis Plan Schnitzer Steel of Tacoma, Hylebos
Waterway, Tacoma, Washington.

-------
OU 01 Attachment 1 - List of Documents Reviewed

DOF. 2010a. Memo Sampling and Analysis Plan Addendum for Data Gaps Post Removal of
Woodwaste/Slag Containment Cell 3009 Taylor Way Tacoma, Washington.

DOF. 2010b. Sediment Sampling and Analysis Plan. Schnitzer Steel of Tacoma. Hylebos
Waterway, Tacoma, Washington.

DOF. 2011a. Sediment Sampling Data Report. Schnitzer Steel of Tacoma. Hylebos Waterway,
Tacoma, Washington. January 2011.

DOF. 2011b. Summary Report. Contaminant Investigation. Former Tacoma Steam Plant Site.
Tacoma, Washington.

DOF. 201 lc. Remedial Action Construction Report. Head of Hylebos Waterway Problem Area.
Commencement Bay Nearshore/Tideflats Superfund Site. Tacoma, Washington.

DOF. 2012. Pre-OMMP Sediment Sampling Data Report. Head of Hylebos Waterway Problem
Area. Head of Hylebos Waterway of the CB/NT Superfund Site Tacoma, Washington.

Department of Ecology. 2010. Memorandum: CALBAG Metals Facility and Head of Jylebos
Sediment Data.

Department of Ecology. 2011. Memorandum to Mr. Babcock: Draft "Data Gap Evaluation for
Site Characterization " Submittal.

GeoEngineers. 2011. Draft Sediment Monitoring Report. Hylebos Bridge Rehabilitation Project.
Post-Construction Monitoring. Tacoma, Washington.

GeoEngineers. 2013. Memorandum: Environmental Sampling and Analysis Plan - PSE Tacoma
Future Fuels Project.

Grette Associates. 2010a. General Metals of Tacoma. DBA Schnitzer Steel, Inc. Hylebos
Waterway Debris Removal. Annual Maintenance Plan.

Grette Associates. 2010b. Technical Memorandum: Clear Creek Phase II Invasive Vegetation
Removal Monitoring.

Grette Associates. 2011. Technical Memorandum: 2011 Clear Creek Phase II Riparian Planting
Area Invasive Vegetation Removal Monitoring.

Grette Associates. 2012a. Technical Memorandum: Clear Creek Habitat Improvement Project-
Phase II Contingency Plan Final Monitoring Report, 2012.

Grette Associates. 2012b. Slip 5 Mitigation Site Final Monitoring Report, 2011 (Year 6) RD/RA
Consent Decree. Mouth of Hylebos Waterway Problem Area. Commencement Bay
Nearshore/Tideflats Superfund Site.

-------
OU 01 Attachment 1 - List of Documents Reviewed

HartCrowser. 2011. Memorandum: October 4, 2010 Environmental Cap Inspection Summary.
Piers 24 and 25 Embankment Remediation Project. Mouth of the Hylebos Waterway Problem
Area, Tacoma, Washington.

HartCrowser. 2013. Final Remedial Action Construction Report. Piers 24 and 25 Embankment
Remediation Project E1934. Mouth of the Hylebos Waterway Problem Area, Tacoma,
Washington.

HartCrowser. 2014a. Operations, Maintenance, and Monitoring Plan. Piers 24 and 25
Embankment Remediation Project E1934. Mouth of the Hylebos Waterway Problem Area,
Tacoma, Washington.

HartCrowser. 2014b. Institutional Control Plan Piers 24 and 25 Embankment Remediation
Project El934 Mouth of Hylebos Waterway Problem Area, Tacoma, Washington.

Herrera and NewFields. 2014. Data Report Draft Hylebos Waterway Federal Navigation Channel
Dredged Material Characterization Tacoma, Washington.

Occidental Chemical Corporation. 2011. Memo - Performance Evaluation Report and Groundwater
Migration Control Proposal.

Pacific International Engineering. 2000. Exhibit E Clear Creek Habitat Improvement Project - Phase II.

Port of Tacoma. 2011. Outer Hylebos Mitigation Site Contingency Plan Puyallup land Transfer Consent
Decree.

U.S. Army Corps of Engineers. 2014. Hylebos Mitigation Site Evaluation - Year 1 - Final Report.
Sitcum Waterway

HartCrowser. 2013. Data Report, Third Round ofStage 1, Groundwater Quality Monitoring, Sitcum
Waterway Remediation Project, Port of Tacoma, Washington. Prepared for Port of Tacoma. June 12,
2013.

Port of Tacoma. 1994. Operations, Maintenance, and Monitoring Plan, Sitcum Waterway Remediation
Project. June 3, 1994.

Port of Tacoma. 2008. letter to EPA re: Sitcum Waterway Consent Decree (C93-5462), Groundwater
Quality Monitoring Report, Stage 1, Second Round (2008). June 2, 2008.

Middle Waterway

Anchor Environmental, LLC (Anchor). 2001. Final Data Evaluation Report for Middle Waterway
Problem Area. Commencement Bay Nearshore/Tideflats Superfund Site. Tacoma, Washington. April 9,
2001.

Anchor. 2005. Final Revised Operations, Monitoring, and Maintenance Plan - Areas A and B. February
14,2005.

-------
OU 01 Attachment 1 - List of Documents Reviewed

Anchor QEA. 2011. Final Year 5 Monitoring Report: Middle Waterway Problem Area- Areas A and B
Commencement Bay Nearshore/ Tideflats Superfund Site. June 30, 2011.

Anchor QEA. 2013 a. Final Additional Response Action Completion Report. May 2013.

Anchor QEA. 2013b. Final Year 8 Monitoring Report: Middle Waterway Problem Area- Areas
A and B Commencement Bay Nearshore/ Tideflats Superfund Site. July 2013.

Hart Crowser. 2005. Operations, Monitoring, and Maintenance Plan. Middle Waterway Problem Area C.
Sediment Management Units 51a and 51b. Commencement Bay Nearshore/Tideflats Superfund Site,
Tacoma, Washington. April 27, 2005.

Hart Crowser. 2010. Year 5(2009) Monitoring Report. Middle Waterway Problem Area C. Sediment
Management Units 51a and 51b. Commencement Bay Nearshore/Tideflats Superfund Site.
February 5, 2010.

Hart Crowser. 2011. Year 6 (2010) Monitoring Report. Middle Waterway Problem Area C.
Sediment Management Units 51a and 51b. Commencement Bay Nearshore/Tideflats Superfund
Site. June 16, 2011.

Hart Crowser. 2013 a. Technical Memorandum: Supplemental Work in Middle Waterway Area C.
June 28, 2013.

Hart Crowser. 2013b. Year 10 (2013) Monitoring Report. Middle Waterway Problem Area C.
Sediment Management Units 51a and 51b. Commencement Bay Nearshore/Tideflats Superfund
Site. June 24, 2013.

Thea Foss / Wheeler-Osgood

City of Tacoma. 2010. Thea Foss and Wheeler-Osgood Waterways Remediation Project. Year 4
Monitoring - Annual Operations, Maintenance, and Monitoring Report. December 15, 2010.

City of Tacoma. 2011. Thea Foss and Wheeler-Osgood Waterways Remediation Project. Year 5
Monitoring Annual Operations, Maintenance, and Monitoring Report. October 12, 2011.

City of Tacoma. 2012. Memorandum. OMMP Revisions Based on Years 5 and 6 Monitoring.

City of Tacoma. 2013. Thea Foss and Wheeler-Osgood Waterways Remediation Project. Year 7
Monitoring Annual Operations, Maintenance, and Monitoring Report. November 15, 2013.

City of Tacoma. 2014. Thea Foss and Wheeler-Osgood Waterways 2013 Source Control and
Water Year 2013 Stormwater Monitoring Report, City of Tacoma. March 2014.

Floyd | Snider. February 2014. Memo: Murray Morgan Bridge Rehabilitation: Verification
Sediment Sampling Results.

-------
OU 01 Attachment 1 - List of Documents Reviewed

PacificCorp. 2014. Head of Thea Foss Waterway Remedial Design/Remedial Action Progress
Report No. 82, October 1, 2013 through December 31, 2013.

Tetra Tech EC, Inc. 2009. Results of Year 5 Operations, Maintenance, and Monitoring Plan
Sampling Head of the Thea Foss Waterway Remediation Project.

Tetra Tech EC, Inc. 2010. Results of Year 6 Operations, Maintenance, and Monitoring Plan Site
Activities Head of the Thea Foss Waterway Remediation Project.

Thea Foss / Wheeler-Osgood, continued

Tetra Tech EC, Inc. 2011. Results of Year 7 Operations, Maintenance, and Monitoring Plan
Sampling Head of the Thea Foss Waterway Remediation Project.

Tetra Tech EC, Inc. 2013. Results of Year 9 Operations, Maintenance, and Monitoring Plan Site
Activities Head of the Thea Foss Waterway Remediation Project.

6

-------
OU 01 Attachment 2 - Historic and Current Fish and Shellfish Advisory Signs

-------
OU 01 ATTACHMENT 2 - Historic and Current Fish and Shellfish Advisory Signs

Historic and Current Fish and Shellfish Advisory Signs in CB/NT

Page 1

-------
OU 01 ATTACHMENT 2 - Historic and Current Fish and Shellfish Advisory Signs

Page 1 of 1

Ray Hanowell - Commencement Bay Waterways Fish Advisory

From:	Ray Hanowell

To:	Carr, Liz

Subject:	Commencement Bay Waterways Fish Advisory

CC:	Dibiase, Frank; Tuttle, Lindsay

Liz,

Our advisory to not eat fish and shellfish from the waterways of Commencement Bay is based upon the EPA
study, Assessment of Human Health Risk from Ingesting Fish and Crabs from Commencement Bay, EPA 910/9-
85-129, April 1985. This report was prepared by Versar, Inc. for James Krull, at the Department of Ecology,
under EPA Contract No. 68-03-3149.1 loaned out my copy of the report a few years ago and it hasn't yet been
returned,

Based upon the findings of this study, we posted signs in 1985 in the City Waterway (now called the Thea Foss
Waterway), the Blair Waterway, and the Hylebos Waterway. The original signs were in English only and were
replaced in 1996 with signs in a number of languages,	1996 map accompanied this email follows.

Over the years, the Blair and Hylebos signs have disappeared and have not been replaced, since we don't think
folks are fishing/shellfishing in these areas. We've maintained signs in the Thea Foss Waterway, replacing our
old signs with DOH signs several years ago and with newer DOH signs fairly recently.

We check on the signs periodically and often see folks fishing near the signs, so the signs are not very effective
at stopping people from fishing and shellfishing. We have talked with a number of fishermen and tried to explain
that they are increasing their risk of cancer but the response has generally been, "we have never gotten sick
and don't think there is a real concern."

I hope this information is helpful.

Thanks, Ray

Page 2

about;blank

12/12/2008

-------
Map of the Fish Consumption Warning Sign Locations in the Waterways of Commencement
Bay, October 18, 1996.

£ New multi-lingual sign

^ Old warning sign, in english only (these signs weren't replaced because they are in good
condition, difficult to get to, and/or are in industrial areas that don't have public access).

Page 3

-------
OU 01 ATTACHMENT 2 - Historic and Current Fish and Shellfish Advisory Signs

December 26, 2008

DOH file name: TPCHD Commencement Bay Waterways_FINAL_01_08_09.doc

TO:	Files

FROM: Joan Hardy, Dave McBride

RE:	Use of Signs in Commencement Bay Waterways

Background

Washington State Department of Health (DOH) conducted a human health
assessment for contaminants in fish in Puget Sound (2006). This assessment
was done, in part, to consider fish consumption in the context of the entire
Sound rather than to consider consumption issues using a more localized
approach. The goals of risk communication for fish consumption in Puget
Sound were to make any consumption guidance advice clear and consistent.

In November, 2008, Tacoma-Pierce County Health Department (TPCHD)
requested that DOH review consumption advice for the Commencement Bay
Waterways, which include the Thea Foss Waterway, the Blair Waterway,
and the Hylebos Waterway. Fish tissue data from this area were not
available for use in the 2006 health assessment. TPCHD previously had
posted signs recommending that the public not eat fish or shellfish in this
area.

Discussion

TPCHD based its recommendation of "no consumption of fish or shellfish"
on an EPA study entitled "Assessment of Human Health Risk from Ingesting
Fish and Crabs from Commencement Bay" (EPA 910/9-85-129, April
1985). Issuing such advice is not consistent with DOH protocols that
recommend issuing consumption guidance only when it is based on fish
and/or shellfish contaminant data. However, certain circumstances may
warrant advice in the absence of data; for example, sites such as urban
embayments with known or suspected contamination.

Ecology's Toxics Cleanup Program, Southwest Regional Office, was
concerned that shellfish harvest from the waterway would disturb their
proposed cap of sediment contaminants. They prefer using signs that state:
"Do not eat crab, shellfish or bottom feeding fish due to pollution."

An additional concerned raised by Shellfish and Water Protection Office
(SWPO), DOH, is harm to human health based on high coliform counts.

Page 4

-------
OU 01 ATTACHMENT 2 - Historic and Current Fish and Shellfish Advisory Signs

The SWPO previously issued a "Do not eat shellfish" advisory due to
biological pollution in the Commencement Bay waterways.

Alternative DOH language to "Do not eat crab, shellfish or bottom fish is
"Bottomfish, shellfish, and crab maybe unsafe to eat due to pollution."
DOH considered this sign, which is our current recommendation for use in
Puget Sound when data are missing. However, DOH concluded that the
message "Do not eat crab, shellfish, or bottom fish" would be appropriate in
this circumstance, based on:

•	Ecology's concern of disturbing the sediment cap by fishing,

•	Pierce County's previous use of "Do not eat shellfish, or fish" signs,
and

•	DOH's OSWP advisory for the area: "Do not eat shellfish due to
biological pollution."

Recommendation

Signs for fish and shellfish consumption along the Commencement Bay
Waterways, Pierce County, should read:

"Do not eat crab, shellfish or bottom feeding fish due to pollution."

This message is clear, concise, and consistent with current signs in Pierce
County and the Duwamish River. Further, the message is protective of fish
and shellfish consumers.

Page 5

-------
OU 01 ATTACHMENT 2 - Historic and Current Fish and Shellfish Advisory Signs

- — T

W11, 2e?h. *h°)

nx\ nmA|£.

Vietnamese	^	^

Khong nen an cua, ngheu so hoac loai ca sinh song hay an
nhtfng thuf cr day ntforc vi bi nhiem ban.

ryHnflfulRTa, rufifuSISSjfl i2l tflijfij |n'1fU1, UjrmjiUiruiol
UfliHIun in m n fijH j S itil til runJ £ njn2 fi 1

mnjjnunyi), aouiuiBcDan, math m9i^g)Jii£3nu jJunJU*i?Ji£SJu;fJj)-

B CBS3M c 3arpnBHeHweM eoflbi Henb3« ynoTpe6/iflTb 8 nmny Kpa6oB,
MonntocKOB w pbi6y, KOTopaa o6irraeT wjim nwTaeTCH y flHa

For more information, call toll-free:
Fish Advisory 1-877-485-7316

Hotline:

www.doh.wa.gov/fish

Shellfish Safety 1-800-562-5632

Hotline:	www.doh.wa.gov/shellfishsafety.htm

%Health

Contact local health agency:

n

2012 Photograph of Advisory Warning Signs in Thea Foss Waterway, Commencement Bay.
Source: Lindsay Tuttle, TPCHD, personal communication, November 7, 2012.

Page 6

-------
OU 01 ATTACHMENT 2 - Historic and Current Fish and Shellfish Advisory Signs

Warning sign

Warning sign

Warning sign

Warning sign

Warning Sign



,QThi>S"

Warning Sign

Foss Waterway - Tacoma

Printed: 11/19/12 9:29 AM
Scale 1:11,408	^

0	475 950 ft.

The map features are approximate and are intended only to provide an indication of said feature. Additional areas that have not been mapped may be present This is not a survey. Orthophotos and other data may not align.
Pierce County assumes no liability for variations ascertained by actual survey. All data is expressly provided AS IS and WITH ALL FAULTS. Pierce County makes no warranty of fitness for a particular purpose.

SourcJ^jjiGJ&a^ Tuttle, TPCHD, personal communication, November 19, 2012.

-------
OU 01 ATTACHMENT 2 - Historic and Current Fish and Shellfish Advisory Signs

Eye alt 13113 ft

Advisory Warning Signs in Blair and Hylebos Waterways, 2012, provided by TPCHD.

Page 8

-------


OU 01 AT IACHMENT 2 - Historic and Current Fish and Shellfish Advisory Signs



Location Sign 1.

-------
OU 01 ATTACHMENT 2 - Historic and Current Fish and Shellfish Advisory Signs

Location Sign 2

restricted

area

authorized

personnel^

-------
OU 01 ATTACHMENT 2 - Historic arid Current Fish and Shellfish Advisory Signs

Location Sign 3

; M



CONSUMPTION

NOT ttCOMWHOfO

s h

i

& ~ &

-------
OU 01 Attachment 3 - 1985 Fish Advisory in Commencement Bay

-------
OU 01 ATTACHMENT 3 - 1985 Fish Advisory in Commencement Bay

1985 Fish Advisory in Commencement Bay

Page 1

-------
OU 01 ATTACHMENT 3 - 1985 Fish Advisory in Commenceme

&,£"< « M\ f

JOHN'SPELL V.Vs

Governor

\f\j (jr	ALAN | CIEBS

Secreiary

STATE OF \\ a5K!\CTO\'

DEPARTMENT OF SOCIAL AND HEALTH SERVICES

Olvrr.ip.e. Ha.hr.gion 9bSC-i

RECE;
APR 161385

FOR FURTHER INFORMATION: Contact Floyd Frost, (205) 464-6289

DSHS-HEAITH f-WICES

NEWS RELEASE

NO: 82-218

FOR IMMEDIATE RELEASE

Howard Shuman

Public Affairs Administrator
(206) 753-2745

PRECAUTIONS LISTED FOR FISHING IN CERTAIN AREAS OF PUGET SOUND

OLYMPIA -- Fishermen in certain areas of Puget Sound should take extra
precautions, according to Dr. John Beare, director of the State Division of
Health.

The recent release of study results by the National Marine Fisheries
Service, (NOAA), has raised concerns about the potential hazards of eating
fish caught in Commencement, Elliot and Port Gardner Bays of Puget Sound.
The studies, conducted between 1978 and 1981, were performed to determine the
level of chemical pollution in Puget Sound and to assess if .its fish and other
marine life had been adversely affected.

Results indicate that potentially toxic chemicals are present in the
sediments of the bays adjacent to industrial urban centers. The sites studied
are near the mouth of the Puyallup, Duwamish and Snohomish Rivers. Bottom
fish, and shellfish in these waters have been shown to have higher concentra-
tions of chemical pollutants than specimens collected in non-urban areas.
However, a small sample of fish and shellfish caught in these areas has shown
chemical concentrations within the ranges now considered to be "safe" for human
consumption -- for the chemicals tested. The studies also found a higher level
of tissue abnormalities in fish caught in areas near urban centers when

(

compared with fish caught in other areas.' USEPASF ^

6.5.1 " 000023

Page 2

1317545

continued . .

-------
OU 01 ATTACHMENT 3 - 1985 Fish Advisory in Commencement Bay	%

-	2 -	"

Based on a review of the NOAA study, and in consultation with the

v

Seattle-King County, Snohomish and Tacoma-Pierce County Health Department,

Beare offered the following advice:

1.	Fishermen whose habit is to fish along the Seattle, Tacoma or Everett
waterfront should be aware that chemical wastes have been detected

in those parts of Puget Sound.

2.	Because of the chemical contamination and the uncertainty about
possible health effects, the Health Division recommends that
individuals not fish or gather shellfish from parts of Elliot,

Commencement and Port Gardner Bays adjacent to industrial areas.

This recommendation pertains particularly to bottom fish such as
sole and cod, which have the greatest exposure to chemical waste.

3.	Should it~be necessary to fish in these areas, it would be Drudent

to eat only the fish muscle (flesh). Strip away and discard the skin,
fat, internal organs and head. This is recommended because muscle
tissue contains the lowest levels of chemical contamination.

Consumption should be limited to an occasional fish. Since the liver
contains the highest concentration of chemical contaminants, the
liver should not be eaten from any fish caught anywhere in these bays.

There is no cause for concern that migratory fish, such as salmon and
steelhead, are in any way affected, Beare said. Further, there is no evidence *
that levels of synthetic organic chemicals reported to date can cause any
acute or chronic health problem. The above recommendations are precautionary
and advisory and recognize the limitations of current knowledge on the toxicity
of many synthetic organic chemicals.	(

For further information, call Floyd Frost, (206) 464-6289.

Page 3

-	30 -

-------
OU 01 Attachment 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound

-------
OU 01 ATTACHMENT 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound (Source: DOH 2006)

Page 1

-------
OU 01 ATTACHMENT 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound (Source: DOH 2006)

Human Health Evaluation of
Contaminants in Puget Sound Fish

October 2006

Prepared by

The Washington State Department of Health
Division of Environmental Health
Office of Environmental Health Assessments
Olympia, Washington

Division o f Environmental Health

Page 2

-------
OU 01 ATTACHMENT 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound (Source: DOH 2006)

Table ES-1. Meal recommendations for rockfish from Puget Sound listed by Washington State
Department of Fish and Wildlife recreational marine areas.

Recreational
Marine Area

(see Figure FS-1)

Consumption
(iiiidance lor rockl'ish
from Puget Sound

Kxeeptions

(soo Figure FS-2)

East Juan de Fuca
Strait

No more than 1 meal/week

None

San Juan Islands

No more than 1 meal/week

None

8.1

Deception Pass,
Hope Island, and
Skagit Bay

No more than 1 meal/week

None

8.2

Port Susan and
Port Gardner

No more than 1 meal/week -
with noted exceptions

No more than 2 meals per month: Mukilteo-Everett
and Port Gardner.

Admiralty Inlet

No more than 1 meal/week

None

Seattle-Bremerton
Area

No more than 1 meal/week -
with noted exceptions

No consumption: Elliott Bay (east of imaginary
boundary from Duwamish Head to Pier 91, including
the Duwamish River) and Sinclair Inlet (west of Dyes
Inlet and Mitchell Point).

Tacoma-Vashon
Area

No more than 1 meal/week -
with noted exceptions

No more than 2 meals per month: Commencement
Bay (SE of imaginary boundary between Sperry Ocean
dock and Cliff House Restaurant).

Hood Canal

No more than 1 meal/week

None

South Puget
Sound

No more than 1 meal/week

None

NOTE: Meal size equals eight ounces of uncooked fish for an average-sized adult.

English Sole and Other Flatfish

English sole was the only flatfish sampled and analyzed by PSAMP. While differences in life
history may result in varied contaminant concentrations between species, DOH used chemical
results from English sole tissue analyses to develop consumption recommendations for all Puget
Sound flatfish. WDFW sport fish regulations use the term "bottomfish" to define numerous
species. Meal limits specified for flatfish may not be applicable to other bottomfish such as
lingcod.

The following table is a summary of consumption guidance for all consumers of Puget Sound
English sole and other flatfish. Note that consumption of English sole and other flatfish from
urban bays should be limited (Everett, Eagle Harbor, Commencement Bay) or avoided
(Duwamish Waterway). Before fishing, anglers should consult WDFW fishing guidance for
catch limits.

Page 3

-------
OU 01 ATTACHMENT 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound (Source: DOH 2006)

Table ES-2. Meal recommendations for English sole and other flatfish from Puget Sound listed
by recreational marine areas (see Figure ES-3).

Recreational
Marine Area . ..

Figure FS-1)

Consumption (iuidaiice lor

Knglish Sole and other
Klairish from Puget Sound

Kxceptions

(see Figure FS-3)

East Juan de Fuca
Strait

No meal limit

None

San Juan Islands

No meal limit

None

8.1

Deception Pass,
Hope Island, and
Skagit Bay

No meal limit

None

8.2

Port Susan and
Port Gardner

No meal limit - with noted
exceptions

No more than 2 meals per month: Everett-
waterfront from Mukilteo ferry dock to City of
Everett. Based on extrapolation from sediment
concentrations.

Admiralty Inlet

No meal limit

None

Seattle-Bremerton
Area

No meal limit - with noted
exceptions

No consumption: Duwamish Waterway
(includes Harbor Island East and West
Waterways)

No more than 1 meal per month: Sinclair Inlet
(west of Dyes Inlet and Mitchell Point).

No more than 2 meals per month: Elliott Bay
(east of imaginary boundary from Duwamish
Head to Pier 91).

No more than 1 meal per wk: Eagle Harbor
and Port Orchard (waterway separating
Bainbridge Island and Kitsap Peninsula).

Tacoma-Vashon
Area

No meal limit - with noted
exceptions

No more than 2 meals per month: Inner
Commencement Bay (SE of imaginary boundary
between Sperry Ocean dock and Cliff House
Restaurant).

No more than 1 meal per wk: Outer
Commencement Bay (SE of imaginary boundary
between Boathouse Marina and Brown's Point).

Hood Canal

No meal limit

None

South Puget
Sound

No meal limit

None

NOTE: Meal size equals eight ounces of uncooked fish for an average sized-adult.

Puget Sound Salmon

DOH recommends the following with respect to Chinook and coho salmon in Puget Sound:

• Chinook salmon from Puget Sound may be consumed once (eight ounces) per week (or
four times per month).

o Anglers who catch resident Chinook salmon (also known as blackmouth) in the Puget
Sound winter blackmouth fishery should limit their consumption to two eight-ounce
meals per month. A Chinook caught in the Puget Sound wintertime fishery weighing

Page 4

-------
OU 01 ATTACHMENT 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound (Source: DOH 2006)

Figure ES-2. Meal limit recommendations for rockfish from urban areas of Puget Sound. Area
designations are consistent with WDFW recreational marine areas. The general meal limit
recommendation for rockfish throughout Puget Sound is 1 meal per week.

,Tyee Manna |

Commencement
Bay

CHd Tewt£._

Area 8-1 \



s.

Whidbey
Island

Area 9

t Pier 91 1

Area 10

Legend

No consumption

1	meal per month

2	meals per month

1 meal per week ( 4 meals per month)
No Limits

Everett

'' Mukilteo I
Ferry Doc* |

Island

t*3*

6rdgej

Area 10

J*

ItlamJ

Page 5

19

-------
OU 01 ATTACHMENT 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound (Source: DOH 2006)

Figure ES-3. Meal limit recommendations for English sole and flatfish from urban areas of
Puget Sound. Area designations are consistent with WDFW recreational marine areas.

Area 10

Area 6-1 \

Wfoidbey
Island

Legend

No consumption

1	meal per month

2	meals per month

1 meal per week ( 4 meals per month)
No Limits

Area 8-2

Everett

\

Mukifteo
Ferry Dock |

Area 9

B&ntmctjie

Oyws info?

H&rtQr

fV

™ L %	Rrirt-ii

Pgmt
.WNte

f] ^Marteefl
Fi> _Bndgej^k

,uU

Area 10

StfJCtttrf

<4*



Boatfrxise
W*nna

Cl«fl Hcvsfl
Raalauranl

Duwarmsh
Head

Page 6

20

-------
OU 01 ATTACHMENT 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound (Source: DOH 2006)

Table 1. Puget Sound English sole (ES) and rockfish (R) sampling stations classified by urban,
near-urban, or non-urban setting.*

I rban stations

Near urban stations

Nun urban stations

Commencement Bay (Thea Foss)

ES, R

Budd Inlet

ES

Apple Cove Point

ES

Commencement Bay 2

ES, R

Bellingham Bay (outer)

ES

Birch Point

ES

Duwamish

ES

Blakely Rock

R

Carr Inlet 1

ES

Eagle Harbor

ES

Brown's Point

R

Case Inlet 1 (South
Case Inlet)

ES

Elliott Bay (Seattle Waterfront)

ES, R

Cherry Point

ES

Case Inlet 3 (North
Case Inlet)

ES

Elliott Bay 2 (Harbor Island)

ES, R

Commencement Bay 3
(Ruston)

ES

Day Island

R

Elliott Bay 4 (Myrtle Edwards)

ES, R

Commencement Bay 4
(Old Tacoma)

ES, R

Discovery Bay

ES

Fuller Shipwreck (Elliott Bay)

R

Commencement Bay 5
(Brown's Point)

ES, R

Double Bluff

R

Mukilteo-Everett

ES, R

Dalco Passage

R

Fern Cove

ES

Outer Commencement Bay

ES

Dash Point

ES

Foulweather

R

Port Gardner

ES, R

Dyes Inlet

ES

Hood Canal

ES, R

Sinclair Inlet

ES, R

Elliott Bay 5 (Alki)

ES

Hood Canal M

ES

Sinclair Inlet (Tribal)

R

Gig Harbor

R

Hood Canal S

ES





Lakota

R

McAurther Bank

ES





Liberty Bay

ES

Nisqually

ES





Port Orchard

ES

Orcas Island

ES, R





Port Townsend

ES

Outer Birch Point

ES





Sinclair Inlet 2 (Outer
Sinclair)

ES, R

Pickering Passage

ES





Sinclair Inlet 3

ES

Possession Point

ES





Sinclair Inlet 4 (Battle
Point)

ES

Port Ludlow

ES





Sinclair Inlet 5 (Blake
Island)

ES

Port Madison

ES









Point Roberts

ES









Port Susan

ES









San Juan Islands

R









Saratoga Passage

ES









Shilshole

ES









Strait of Juan de Fuca

ES









Strait of Georgia

ES









Vendovi Island

ES









Wollochet

ES

* Urban, near-urban, and non-urban stations were determined by WDFW (West et al. 2001) and updated for this
report.

Page 7

25

-------
OU 01 ATTACHMENT 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound (Source: DOH 2006)

Figure 2. Puget Sound sites where English sole were sampled by WDFW for the Puget Sound
Assessment and Monitoring Program.

Page 8

27

-------
OU 01 ATTACHMENT 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound (Source: DOH 2006)

Figure 1. Puget Sound sites where rockfish were sampled by WDFW for the Puget Sound
Assessment and Monitoring Program.

Page 9

26

-------
OU 01 ATTACHMENT 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound (Source: DOH 2006)

Tissue Analysis

A detailed description of analytical methods used to measure contaminants in Puget Sound fish
sampled and analyzed by PSAMP is available (West et al. 2001). The following provides a
summary of information described in the WDFW report. Chemical analyses for organic and
inorganic compounds followed procedures from the Puget Sound Estuary Program (PSEP 1989a,
1989b). These protocols reference USEPA Contract Laboratory Program Procedures (EPA
1986a, 1986b) and incorporate additional Quality Assurance/Quality Control (QA/QC)
requirements.

All metals, including mercury, were analyzed as total elemental concentrations and reported as
parts per million wet weight (ppm). Separate digestates were prepared for mercury using the
nitric acid/sulfuric digestion method then analyzed by the cold vapor atomic absorption method.
DOH assumed that total mercury concentrations were available as methylmercury because 90 -
100% of total mercury is typically in the form of methylmercury in adult fish (EPA 2001a).

Organic compounds were extracted from tissue samples by soxhlet extraction (for 1989 and 1990
samples) or sonication with a methylene chloride and acetone mix (for 1991, 1992, and 1993
samples). Beginning in 1991, all extracts were cleaned by gel permeation chromatography. The
extracts were split, one for pesticide and PCB analyses and the other for base/neutral/acid-
extractable (BNA) compounds.

Pesticides and PCBs were analyzed using gas chromatography-electron capture detection
(GC/ECD), with Aroclor mixtures used as standards for quantifying PCB concentrations and
reported as parts per billion (ppb) wet weight. In 1989 and 1990, a dual megabore column was
used on the GC/ECD, but in 1991, 1992, and 1993, a dual narrow-bore column better suited to
analyzing low concentrations was substituted. Starting with 1992 rockfish samples, new
chromatography software was used for quantification of pesticides and PCBs, allowing
laboratory chemists to more accurately quantify low concentrations of these chemicals. Because
of these method changes, PCB data from 1989 and 1990 were not included in this evaluation.
Chromatographic peaks used to quantify individual Aroclors may have contributions from
multiple Aroclors, resulting in overestimation of an individual Aroclor level. Total PCBs in
tissue can be overestimated when inflated results for individual Aroclors are summed.

A congener-specific screening method and estimation of total PCBs and pesticides (using high
performance liquid chromatography with photodiode array - HPLC/PDA) was adopted in 1997
(Krahn et al. 1994). The method provided measures of 15 of 209 PCB congeners (77, 101, 105,
110, 118, 126, 128, 138, 153, 156, 157, 169, 170, 180, and 189). In 1997 and 1998, a number of
tissue samples were analyzed using both the Aroclor-PCB (GC/ED) and the congener-PCB
(HPLC/PDA) method. Results of both methods are included in this report. The HPLC/PDA
method avoids overestimation of PCB concentration inherent in the Aroclor-summation
procedure but may underestimate total PCBs because it only analyzes a fraction of PCB
congeners.

Page 10

-------
OU 01 ATTACHMENT 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound (Source: DOH 2006)

Total PCBs were estimated in this report using two methods:

• Arithmetic summation of individual Aroclors (1248, 1254, and 1260), and

• Analytical measurement of total PCBs by the HPLC/PDA screening method (measuring
the concentration of 15 of 209 PCB congeners). This method provided estimates of "total
PCBs" from measurements of total area under the congener curve. These results were
later adjusted to derive an Aroclor-equivalent concentration based on observed trends
from samples analyzed using both methods.

WDFW staff validated 1989 and 1990 data and, beginning in 1991, an independent QA/QC
chemist reviewed tissue chemistry data. Internal QA/QC reports are available from WDFW on
request. For this report, one-half of the detection value was used when chemicals were not
detected above the analytical detection level. The average detection limit for Aroclors was 2.0
ppb and <1.0 ppb for individual congeners by the HPLC/PDA method.

Risk Assessment

The following is an overview of steps used by DOH to determine whether or not fish consumers
are potentially overexposed to contaminants in fish and to develop meal recommendations for
consuming these fish (Figure 4).

• The first step is to determine how much fish is consumed by potentially-exposed anglers,
tribal members, additional high-consuming populations, and other citizens. DOH
typically uses mean and 90th (or 95th) percentile population-specific consumption rates to
estimate average and high-end exposures.

• The second step is to obtain contaminant data (in this case from PSAMP) or to analyze
fish samples for contaminant concentrations to estimate levels in fish tissue.

• Using this information, DOH can establish what contaminants people are exposed to and
estimate the doses a person would receive from consuming fish.

• The next step is to determine if the calculated exposure dose is potentially unsafe. This is
done in this report by comparing the calculated exposure dose to an oral reference dose
(RfD) specific to each chemical of concern. A reference dose is a level of exposure
below which non-cancer adverse health effects are not likely to occur. Further, lifetime
increased cancer risk attributable to carcinogenic contaminants (i.e., PCBs) in fish is
calculated and presented.

• Finally, if a population is over-exposed (i.e. PCB HQ > 1) based on a representative
consumption rate, DOH then calculates acceptable meal limits based on non-cancer
endpoints. A reference dose is considered protective of both non-cancer and cancer
health effects for contaminants evaluated in this assessment (i.e., PCBs and mercury).

Page 11

-------
OU 01 ATTACHMENT 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound (Source: DOH 2006)

• The highest mean PCB level in English sole was found at the Duwamish station (168
ppb). This area is undergoing cleanup under EPA's Superfund process. DOH recently
issued a fish advisory that recommends avoiding resident fish species within the Lower
Duwamish Waterway (e.g., English sole, flounder and perch).

• Several other stations (e.g., Harbor Island, Sinclair Inlet, Commencement Bay - Thea
Foss, and Eagle Harbor) were located where sediment cleanups have occurred or are
occurring. The second highest mean PCB level in English sole was observed at Sinclair
Inlet (123 ppb) where sediment cleanup is being conducted by the U.S. Navy. The high
level of contaminants in English sole from these areas resulted in more restrictive meal
limit calculations for these sites (Appendix D, Table D2).

Table 11. Calculated meal limits for English sole at non-urban, near-urban and select urban
locations of Puget Sound.

Calculated

Average

meals per

Calculated meals

Mercury

Average PCI*

month

per month based

concent ration

concentration

based on

on additive

Location

(ppiii)

(ppb)

mercury

PCBs

endpoint

Non-urban

0.051

9.3

locations

Near-urban
locations

0.053

17.2

9.3

7.3

Elliott Bay a

0.080

69.0

2.3

2.2

Sinclair Inlet

0.074

121

1.3

Commencement
Bay b

0.069

60.9

2.6

2.5

a Comprised of Elliott Bay, Elliot Bay 2, and Elliott Bay 4 stations.

b Comprised of Commencement Bay, Commencement Bay 2, and Outer Commencement Bay stations.

English sole - based on PSAMP sediment PCB concentrations

PCB concentration in sediment appears to be the major factor influencing PCB concentration in
English sole muscle tissue for a given location. In order to address the lack of sampling in some
Puget Sound urban bays, WDFW determined a relationship based on PSAMP sediment and
tissue data to predict English sole PCB concentrations where fish were not sampled (O'Neill and
West 2006). In conjunction with mean sediment PCB concentrations from PSAMP, the
following equation was used to estimate PCBs in English sole tissue at these sites:

[;mPCB] = el64*\sPCB'f35*e()U*Age

Where:

mPCB = concentration of PCBs in muscle as sum of 3 Aroclors, ng/g, wet wt.,
sPCB = concentration of PCBs in sediments as sum of 3 Aroclors, ng/g, dry wt.,

Age = fish age in years.

Although the resulting predicted concentration in fish tissue is an estimate, it is useful to
calculate meal limits for locations where sediment concentrations are known but where English

Page 12

-------
OU 01 ATTACHMENT 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound (Source: DOH 2006)

Table D1 (cont.). Estimated meals per month for rockfish from Puget Sound, based on
contaminant concentrations for each station and chemical.

l.oialioil

Rlll'k I'isll
Species

T\ |K"

Menu r\

Tiilal PCIJs (Anii'liirs)

l ulal l>C Us
(Sum hI' 15 iiin»eners)

I .akota

Quillback

1

4 | 0.295 |

4 | 62.8 | 3

0 | NA | NA

Ki-uvationalMana»emeiil Area 12

Hood Canal

Quillback

(

8

0.183

4



7.7

21

0

NA

NA

Copper

(

1

0.170

5

1

6.5

2-

0

NA

NA

RecreationalManagemenl Area 13

Day Island

Quillback

(

6

0.098

8

0

\( lis

5 congeners)

Location

T\ po

\

Mo;ni
ippim

Mo;ils
moiilli

\

Mo;m
(pph)

\1e;iK

llkilllll

\

Mo;in
(pph)

Mo;ils

IlkHllll

Recreational Management Area 6

Discovery Bay

C

3

0.093

9

3

3.9

41

0

NA

NA

Strait of Juan
de Fuca

C

6

0.050

16

6

7.0

23

0

NA

NA

Recreational Management Area 7

Bellingham
Bay (outer)

C

9

0.031

26

9

3.8

42

0

NA

NA

Birch Point

C

6

0.034

24

6

5.1

32

0

NA

NA

Cherry Point

C

3

0.038

21

0

NA

NA

3

13.9

12

McAurther
Bank

C

3

0.043

19

3

3.2

50

0

NA

NA

Orcas Island

C

3

0.027

30

3

3.6

45

0

NA

NA

Outer Birch Pt.

C

3

0.047

17

3

3.1

52

0

NA

NA

Point Roberts

C

3

0.020

40

3

4.8

33

0

NA

NA

Strait of
Georgia

C

34

0.051

16

21

5.8

28

15

11.2

14

Vendovi Island

I and C

44

0.038

21

23

I

II
C

3.8

42

014

7.8

21

Recreational Management Area 8-1

Saratoga
Passage

C

6

0.072

11

6

20.2

8

0

NA

NA

Recreational Management Area 8-2

Mukilteo-
Everett

C

2

0.040

20

0

NA

NA

0

NA

NA

Port Gardner

C

34

0.048

17

21

17.5

9

8

22.4

7

Port Susan

C

3

0.070

11

0

NA

NA

1

5.5

29

Recreational Management Area 9

Possession
Point

C

6

0.057

14

6

11.7

14

0

NA

NA

Page 13

120

-------
OU 01 ATTACHMENT 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound (Source: DOH 2006)

Table D2 (cont.). Estimated meals per month for English sole from Puget Sound, based on
contaminant concentrations for each station and chemical.



Memirv

Tolal P( lis
(Aroclors)

lot

(sum of

,il PC Bs
5 congeners)

Location

T\ |v

N

Menu

ippim

Mc;iK

IlkHllll

N

Menu
ipph)

Me;ils

IIIOIIlll

N

Menu

ipphi

Mollis

IIIOIIlll

Port Ludlow

C

3

0.070

11

3

6.7

24

0

NA

NA

Port Townsend

C

12

0.049

16

12

9.7

17

0

NA

NA

Recreational Management Area 10

Apple Cove Pt.

C

6

0.063

13

6

9.8

16

0

NA

NA

Duwamish

C

9

0.064

13

6

168

1

3

164

1

Dyes Inlet

c

6

0.047

17

6

28.0

6

0

NA

NA

Eagle Harbor

c

12

0.095

8

6

42.6

4

6

52.3

3

Elliott Bay

C and I

63

0.079

10

29
I

21
C

64.4

2

15

75.8

2

Elliott Bay 2

C

3

0.095

8

2

26.5

6

3

85.9

2

Elliott Bay 4

C

3

0.080

10

0

NA

NA

3

21.0

8

Elliott Bay 5

C

3

0.072

11

3

16.7

10

3

22.4

7

Liberty Bay

C

6

0.046

17

6

23.3

7

0

NA

NA

Port Madison

C

3

0.046

17

3

13.3

12

0

NA

NA

Port Orchard

C

6

0.067

12

6

36.8

4

0

NA

NA

Sinclair Inlet

C and I

58

0.074

11

24
I

21
C

121

1

15

122

1

Sinclair Inlet 2

C

3

0.071

11

0

NA

NA

3

22.8

7

Sinclair Inlet 3

C

3

0.063

13

0

NA

NA

3

63.8

3

Sinclair Inlet 4

C

3

0.061

13

0

NA

NA

3

38.8

4

Sinclair Inlet 5

C

3

0.086

9

0

NA

NA

3

31.0

5

Shilshole

C

6

0.059

14

5

22.9

7

0

NA

NA

Recreational Management Area 11

Commenceme
ntBay

C and I

57

0.068

12

35
I

20
I

63.0

3

14

79.1

2

Commenceme
nt Bay 2

C

3

0.067

12

0

NA

NA

3

82.4

2

Commenceme
nt Bay 3

C

3

0.049

16

0

NA

NA

3

34.2

5

Commenceme
nt Bay 4

C

3

0.051

16

0

NA

NA

3

43.2

4

Commenceme
nt Bay 5

C

3

0.062

13

0

NA

NA

3

55.5

3

Dash Point

C

6

0.082

10

6

28.5

6

0

NA

NA

Fern Cove

C

3

0.072

11

3

19.3

8

0

NA

NA

Outer
Commenceme
nt

C

6

0.075

11

6

41.8

4

0

NA

NA

Recreational Management Area 12

Hood Canal

C

36

0.059

14

21

6.4

25

15

11.8

14

Hood Canal M

C

6

0.038

21

6

3.5

46

0

NA

NA

Hood Canal S

C

6

0.030

27

6

4.8

33

0

NA

NA

Page 14

121

-------
OU 01 ATTACHMENT 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound (Source: DOH 2006)

Table D2 (cont.). Estimated meals per month for English sole from Puget Sound, based on
contaminant concentrations for each station and chemical.













lotal PC lis

Total PC lis







Mercury





(Aroclors)

(sum of

5 congeners)







Moan

\1e;ils



Mo;iii

Mo;ils



Mo;iii

Mo;ils

Location

T\ po

N

(ppm)

IIIOIII ll

N

i pph i

IlkHllll

\

(pphi

IIIOIIlll

Recreational Management Area 13

Budd Inlet

C

9

0.035

23

9

8.8

18

0

NA

NA

Carr Inlet

C

6

0.052

15

6

14.0

11

0

NA

NA

Case Inlet 1

C

6

0.045

18

6

16.0

10

0

NA

NA

Case Inlet 3

C

3

0.040

20

3

8.3

19

0

NA

NA

Nisqually

C

24

0.061

13

12

21.5

7

15

24.0

7

Pickering

C

6

0.032

25

6

9.2

17

0

NA

NA

Wollochet

C

6

0.055

15

6

26.3

6

0

NA

NA

NOTE: Meal = eight ounces
N = sample size

Type: I = individual sample, C = composite sample
NA = Not available

Table D3. Estimated meals per month for Chinook salmon from Puget Sound, based on
contaminant concentrations for each station and chemical.

Location

Mercury

Total PC"lis (Aroclors)

Type

N

Mean
(ppm)

Meals/
month

\

Mean
(PPh)

Meals/month

In-river Fisheries

Nooksak River

C

18

0.087

9

28

37.9

4

Skagit River

C and I

18 C

0.100

8

31
26 C

40.6

4

Duwamish River

C and I

18 C

0.102

8

341
31 C

57.2

3

Nisqually River

C and I

12 C

0.085

9

11
19 C

41.9

4

Deschutes River

C and I

12 C

0.108

7

121
22 C

60.4

3

Marine Fisheries

Central Sound

C

22

0.074

11

18

75.7

2

Apple Cove Pt.

C

12

0.062

13

12

90.8

2

Central Sound

C

4

0.070

11

0

NA

NA

Sinclair Inlet

c

6

0.099

8

6

45.5

4

South Sound

c

6

0.113

7

16

70.6

2

Budd Inlet

c

0

NA

NA

10

55.5

3

South Sound

c

6

0.113

7

6

95.7

2

NOTE: Meal = eight ounces
N = sample size

Type: I = individual sample, C = composite sample
NA = Not available

Sht4|ng = Total sample size, mean, and meals/month for all marine fishery stations in Central and South Sound.

Page 15

122

-------
OU 01 ATTACHMENT 4 - Summary of PCBs and Mercury in Fish Tissue from Puget Sound (Source: DOH 2006)

Table 3. (cont.) Summary of mercury (ppm, wet weight) and PCBs (ppb, wet weight) measured
in four species of rockfish, English sole, Chinook salmon and coho salmon from Puget Sound.



Mercury

Total
PCBs (Aroc

ors)a

Total PCBs (Aroclor
Equivalent)b

n

Range (ppm)

Mean

(ppm)

n

Range
(ppb)

Mean
(ppb)

n

Range
(ppb)

Mean (ppb)

ENGLISH SOLE

577

0.017-0.14

0.060

434

2-462

38.6

169

4-214

46.6

Urban

256

0.023-0.140

0.072

191

6-462

73.6

82

12-214

74.1

Near-urban

81

0.020-0.118

0.053

57

3-76

17.2

27

13-96

36.2

Non-urban

240

0.017-0.130

0.051

186

2-52

9.3

60

4-39

13.7

SALMON



















Chinook



















All of Puget
Sound

106

0.051-0.160

0.093

210

11-223

54.0

NA

NA

NA

In-riverc

78

0.058-0.160

0.096

176

11-223

50.2

NA

NA

NA

Marined

28

0.051-0.130

0.082

34

21-212

73.2

NA

NA

NA

Central Sound

22

0.051-0.120

0.074

18

21-170

75.6

NA

NA

NA

South Sound

6

0.092-0.130

0.113

16

24-212

70.6

NA

NA

NA

Coho



















All of Puget
Sound

225

0.008-0.110

0.039

221

5-126

31.8

224

16-106

35.5

In-riverc

183

0.008-0.110

0.038

175

5-98

31.1

139

17-82

34.6

Marined

32

0.028-0.071

0.051

46

8-126

34.4

42

21-106

42.1

Minter Creek and
Wallace River
Hatcherv

10

0.020-0.043

0.029

NA

NA

NA

43

16-106

32.1

Central Sound

26

0.028-0.069

0.049

20

8-61

18.3

10

30-59

46.8

South Sound

6

0.045-0.071

0.057

26

18-126

46.8

32

21-106

40.6

Note: Means reflect equal weighting of individual and composite samples.
a Sum of Aroclors 1248, 1254, and 1260.

b Approximation of equivalent Aroclor concentration from HPLC data.

0 "In-river" refers to nearshore areas near rivers and river mouths from which salmon most likely originated.
d "Marine" refers to offshore areas where the origins of salmon are unknown.

Estimating Exposure to Contaminants in Puget Sound Fish

Fish Consumption Rates

Numerous Puget Sound human seafood consumption surveys have been conducted.
Consumption surveys that ask how much fish is being eaten, how often, and which species are
being consumed can be used to estimate exposure rates from eating contaminated fish. DOH
considered four regional seafood consumption surveys for Puget Sound. Members of the
Suquamish Indian Tribe (Suquamish 2000) and the Tulalip and Squaxin Island Tribes (Toy et al.
1996) were interviewed in two separate studies to estimate Puget Sound Native American
consumption rates. A survey of the Asian Pacific Islander (API) community was conducted by
EPA (EPA 1999b) to estimate consumption rates. Recreational anglers from four Puget Sound
areas were surveyed in two studies by NOAA (Landolt et al. 1985, 1987).

Page 16

38

-------
OU 01 Attachment 5 - Fish and Shellfish Data [Note: it has multiple attachments]

-------
OU 01 ATTACHMENT 5 -

Fish and Shellfish Data

CB/NTFYR - 2014

Historical Fish and Crab/Shellfish Tissue Data for PCBs and Mercury

1. Historical Fish (English sole) and Crab Tissue Data. Remedial Investigation for the
CB/NT Site - 1984

The CB/NT Remedial Investigation1 (Tetra Tech 1985) included collection and analysis of
English sole tissue from five discrete samples at each of 15 locations (trawl transects) in
Commencement Bay and 2 locations in Carr Inlet (Reference Area) (Versar 1985). The study
area included all waterways: Hylebos, Blair, Sitcum, Milwaukee, St. Paul, Middle, and Thea
Foss (formerly City) Waterways, and the Ruston-Point Defiance Shoreline (see Attachment KK-
1 for station locations). For the five samples at each location, five individual fish were randomly
selected from 60 fish that were collected for histopathological analysis. Samples were collected
in mid-1984. Fish tissue samples were analyzed for PCBs and other contaminants (mercury
was not analyzed). Sampling was biased to larger sole (230 mm total length, or greater than 3
years old).

While not a statistically valid approach, data were averaged for Thea Foss and Hylebos

Waterways for data presentation purposes only, as shown in Table KK1. Data were only
summarized for Thea Foss and Hylebos Waterways because these were the problem areas where
PCBs were present.

Table KK1. Total PCB Concentrations in English sole muscle tissue sampled in 1984 from
Thea Foss and Hylebos Waterways in Commencement Bay reported in the CB/NT Remedial
Investigation (Tetra Tech 1985; Versar 1985).

Sample Location

Total P( lis (pph wet weight)

Mean

Standard Deviation

Thea Foss, Head

470

215

Thea Foss, Mouth

238

176

Hylebos, Head

536

517

1 See Section 2.2.4 'Field Sample Design', Section 2.7 'Bioaccumulation', Section 3.1.2.3 'Bioaccumulation', and
Section 3.2 'Public Health Assessment' of the RI (Tetra Tech 1985). Data collection and analysis are provided in
Versar 1985, "Assessment of Human Health Risk from Ingesting Fish and Crabs from Commencement Bay."

2 Each fish (whole body minus liver and head) was tagged with a code number, wrapped in aluminum foil, stored on
ice and returned to the shore-based laboratory for tissue removal. In the laboratory, both fillets were removed, and
cut into a 6 g portion for metals analyses and a 36 g portion for organics analyses. No tissue composites were
analyzed. Total PCB (Aroclor) analyses were performed using EPA Method 608 (tissue) and analysis with
extraction/GC/ECD.

3 Data were averaged and presented in this table by Laura Buelow, EPA Region 10.

OU 01 Attachment 5

-------
OU 01 ATTACHMENT 5 - Fish and Shellfish Data

Sample Location

Tola! PCBs (pph wel weigh!)

Hylebos, Middle

300

185

Hylebos, Mouth

143

96

Carr Inlet, Reference

36



The RI also included collection and analysis of crab tissue data, collected from two species:
Dungeness crab (Cancer magister) and red rock crab (Cancerproductus) (p. 9, Versar 1985).
Three samples (i.e, 3 crabs) were collected from the head of Thea Foss Waterway, two samples
were collected from the mouth of Thea Foss Waterway, and one sample was collected from the
middle of Hylebos Waterway. Other sampled waterways are shown in Table KKl-Crab-PCB.
Muscle tissue samples4 were analyzed for PCBs (Table KKlCrab-PCBs) and for mercury (Table
KKlCrab-Hg). In addition to Thea Foss and Hylebos Waterways, crab samples were collected
in other waterways and in the Carr Inlet reference area. In all cases, the method detection limit
was used in the calculation of means if a substance (e.g., specific Aroclor) was not detected.

Table KK1. Crab-PCB. Total PCB Concentrations in edible Dungeness and red rock crab meat
sampled in 1984 from Commencement Bay RI (Versar 1985).

Sample Location

Tola! PCBs (pph wel weight)



Mean

Standard Deviation

Thea Foss, Head; 3 samples

83

25

Thea Foss, Mouth; 2 samples

40

14

Hylebos, Middle; 1 sample

120 (single sample)

0

Middle Waterway; 2 samples

40

14

Sitcum Waterway; 4 samples

233

200

St. Paul Waterway; 1 sample

20 (single sample)

0

Milwaukee Waterway (not a
problem area); 5 samples

74

38

Blair Waterway (not a problem
area); 1 sample

130 (single sample)

0

Carr Inlet, Reference; 3 samples
and 4 samples, respectively

22

23

3
5

4 Crabs were collected from the trawl catches at each study site. Crab pots were also fished near each trawl transect
to provide additional specimens. Each crab (whole body) was tagged, placed in a polyethylene bag, held live on ice,
and returned to the shore-based laboratory for tissue removal. Muscle tissue from body and leg were removed and
cut into a 6 g portion for metals analysis and a 36 g portion for organics analysis. Total PCB (Aroclor) analyses were
performed using EPA Method 608 (tissue) with extraction using GC/ECD.

2

OU 01 Attachment 5

-------
OU 01 ATTACHMENT 5 - Fish and Shellfish Data

Table KK1. Crab-Hg. Mercury (methylmercury) concentrations in edible Dungeness and red
rock crab meat sampled in 1984 from Commencement Bay RI (Versar 1985).

Sample Location

Mercury (ppm wet weight)



Mean

Standard Deviation

Thea Foss, Head; 3 samples

0.06067

0.01332

Thea Foss, Mouth; 2 samples

0.0780

0.01414

Hylebos, Middle; 1 sample

0.22

0

Middle Waterway; 2 samples

0.05

0.01414

Sitcum Waterway; 4 samples

0.167

0.10543

St. Paul Waterway; 1 sample

0.04

0

Milwaukee Waterway (not a
problem area); 5 samples

0.11

0.05916

Blair Waterway (not a problem
area); 1 sample

0.04

0

Carr Inlet, Reference; 3 sample
and 4 samples, respectively

0.040U
0.048

0

0.01347

Very limited crab tissue data were collected in Commencement Bay. Based on this limited data
set, PCBs in crab tissue were elevated in Commencement Bay compared to Carr Inlet (Reference
Area), and as reported in Versar (1985), mercury in crab tissue was lower in Commencement
Bay (10.3 ppb ww, mean of all waterways) than in Carr Inlet (44.6 ppb ww).

Based on analytical methods used for PCBs in tissue during the 1980s, most research scientists
do not support the use of these historical RI data in evaluating long-term trend analyses of PCB
concentrations in fish and crab tissue.

2. Historical Fish (English sole) Tissue Data - Washington DOH Summary - 1991 to 2001

In 2006, Washington DOH published the Human Health Evaluation of Contaminants in Puget
Sound Fish (Washington DOH 2006). The report (p. 24) stated:

From 1989 to 2001 WDFW collected English sole annually with an otter trawl in the
months of April and May, at numerous locations throughout Puget Sound. ... Most
English sole samples were composites comprising 20 individuals per composite. Each
station was comprised of three composite samples (total number of fish at one station

3

OU 01 Attachment 5

-------
OU 01 ATTACHMENT 5 - Fish and Shellfish Data

would be 60). Equal amounts of skinned muscle tissue were collectedfrom individual
fish. Sampling methods for fish tissue are described in West etal. (2001).

Analytical methods are discussed in West et al. 2001 and in DOH (2006; p. 30). DOH stated that
because of changes in analytical methods for PCBs, PCB tissue data from 1989 and 1990 were
not included in the DOH human health evaluation (WDOH 2006; pp. 30-31; reproduced herein
in Attachment KK-3). The WDFW fish tissue data utilized by DOH are not currently available
in Ecology's Environmental Information Management (EIM) system, and raw data must be
obtained from Jim West of WDFW (james.west@dfw.wa.gov).

DOH estimated total PCBs in their report using two methods:

• Arithmetic summation of individual Aroclors (1248, 1254, and 1260)

Based on the 1991-2001 fish tissue data, DOH (2006) reported an average concentration of 60.9
ppb PCBs in English sole muscle tissue in Commencement Bay, as shown in Table KK2.

Station locations are shown in Attachment KK-3.

Table KK2. From Washington DOH (2006; Table 11). Calculated meal limits for
English sole at non-urban, near-urban and select urban locations of Puget Sound.

Location

Average
Mercury
concentration
(l)|)in)

Average PCIJ
concentration
(l>l>b)

Calculated
meals per

month
based on
mcrciirv

Calculated
meals per

month
based on
PC lis

Calculated meals
per month based
on additive
endpoint

Non-urban
locations

0.051

9.3

9.8

Near-urban
locations

0.053

17.2

9.3

7.3

Elliott Bav a

0.080

69.0

2.3

2.2

Sinclair Inlet

0.074

121

1.3

Commencement
Bav b

0.069

60.9

2.6

2.5

aComprised of Elliott Bay, Elliott Bay 2, and Elliott Bay 4 stations.

bComprised of Commencement Bay (Thea Foss), Commencement Bay 2, and Outer Commencement Bay
stations. Only the Commencement Bay (Thea Foss) station was located near the problem areas addressed by
Superfund cleanup actions. Station locations are shown in Attachment KK-3.

OU 01 Attachment 5

-------
OU 01 ATTACHMENT 5 - Fish and Shellfish Data

DOH (2006; Table C3) also reported average concentrations of 63 ppb total PCBs in
Commencement Bay (Thea Foss) and 41.8 ppb total PCBs in Outer Commencement Bay. Total
PCBs, based on the sum of 15 PCB congeners, ranged from 34.2 ppb to 82.4 ppb (Table KK3).

Table KK3. From Washington DOH (2006; Table D2 from Appendix D). Estimated meals per
month for English sole from Puget Sound, based on contaminant concentrations for each station
and chemical.

l.ocnlion

Mercury

Total P( lis
(Aroclors)

lot

(sum of

al PC lis

5 congeners)

1 \ po

N

Mo;m
ippni)

\1e;iK

IIIOIIlll

\

Mo;iii
i pph i

Mo;ils

IIIOIIlll

\

Mo;iii
(pphi

Mo;ils

IIIOIIlll

Recreational Management Area 11

Commencement
Bay

C and I

57

0.068

12

35
I

20
I

63.0

3

14

79.1

2

Commencement
Bay 2

C

3

0.067

12

0

NA

NA

3

82.4

2

Commencement
Bay 3

C

3

0.049

16

0

NA

NA

3

34.2

5

Commencement
Bay 4

C

3

0.051

16

0

NA

NA

3

43.2

4

Commencement
Bay 5

C

3

0.062

13

0

NA

NA

3

55.5

3

Dash Point

C

6

0.082

10

6

28.5

6

0

NA

NA

Fern Cove

C

3

0.072

11

3

19.3

8

0

NA

NA

Outer
Commencement
Bay

C

6

0.075

11

6

41.8

4

0

NA

NA

NOTE: Meal = eight ounces. Station locations are shown in Attachment KK-3.

N = sample size

Type: I = individual sample, C = composite sample
NA = Not available

DOH also reported data for rockfish tissue from Commencement Bay. Rockfish data were
reported for average concentrations of PCBs and mercury in rockfish tissue as shown in Table
KK4. Station locations in Commencement Bay are shown in Figure 1 of DOH 2006 (see
Attachment KK-3).

5

OU 01 Attachment 5

-------
OU 01 ATTACHMENT 5 - Fish and Shellfish Data

Table KK4. From Washington DOH (2006; Table 10). Rockfish meal limit calculations based

on area-specific chemical concentrations for brown, copper, and quillback

rockfish.

Location

Average
Mercury
concentration
(ppni)

Average PCI*
concentration
(ppb)

Calculated
meals per

month
based on
mcrciirv

Calculated
meals per

month
based on
PC lis

Calculated
meals per

month
based on
additive

Non-urban
locations

0.218

5.8

3.7

28

3.4

Near-urban
locations

0.225

45.1

3.6

3.6

2.2

Commencement
Bay3

0.099

53.6

8.1

3.0

2.7

Elliott Bay b

0.340

140

2.4

1.1

1.0

Port Gardner
Everett0

0.267

46.0

3.0

3.5

1.9

Sinclair Inletd

0.748

198

1.1

1.1

0.6

a Comprised of Commencement Bay (Thea Foss), Commencement Bay 2, and Commencement Bay 4 stations. See
DOH 2006 Figure 1 re-produced in Attachment KK-3.

b Comprised of Elliott Bay, Elliott Bay 2, Elliott Bay 4, and Fuller Shipwreck stations.

0 Comprised of Mukilteo-Everett and Port Gardner stations
d Comprised of Sinclair Inlet and Sinclair Inlet Tribal stations.

3.	Historical Shellfish (Mussel) Tissue Data. Washington State Pesticide Monitoring
Program - 1995

In May 1995, the Washington Department of Ecology collected samples of mussels (Mytilus
trossulus, formerly M edulis) from the mouth of Hylebos Creek at the head of Hylebos
Waterway (Ecology 1996) (see Attachment KK-2; Ecology 1996). The sample consisted of a
composite of 30 or more mussels. PCB results were reported as follows:

• PCB 1248 = 18 ppb ww; PCB 1254 = 46 ppb ww; and PCB 1260 = 6J ppb ww. PCBs
were reported at 72 ppb total PCBs (Ecology 1996; p. 8).

Ecology reported that none of the mussel samples (in the entire study area) had PCB residues
that would be considered a concern for consumption by wildlife (Ecology 1996; p. v).

4.	Historical Fish (English sole) Tissue Data - EPA EMAP - 2000

In July 2000, the U.S. EPA Environmental Monitoring and Assessment Program (EMAP;

Hayslip et al. 2000) collected English sole in Hylebos Waterway. Station location information
and tissue data for PCB congeners are provided in Attachment KK-4.

5.	Historical Fish (English sole) Tissue Data - WDFW - PSAMP - 2002 to 2004

6

OU 01 Attachment 5

-------
OU 01 ATTACHMENT 5 - Fish and Shellfish Data

After 2001, WDFW modified their sampling schedule in Commencement Bay to collect samples
every two years. Thus, English sole data were not collected in 2002 or 2004, but data were
collected in 2003. In 2003, WDFW modified the composite sampling approach to collect six
composite samples of 20 fish each per station location. WDFW made this change because it was
determined that earlier compositing schemes (using three composite samples of 20 fish each for
each station location) may not be statistically valid.

A historical perspective on the "Progression of PCB Analysis in PSAMP Fish Sampling
Program" (Godtfredsen et al. 2012) is provided in Attachment KK-5. The WDFW did not
provide 2003 data to EPA.

6. Historical Fish (Pacific staghorn) Data - NOAA - 2003

In 2003, NOAA collected and analyzed Pacific staghorn tissue data from Middle Waterway and
in the vicinity of the Olympic View Resource Area. A station location map and data are
available in Ecology's EIM system, and are reproduced in Attachment KK-6. Total PCB tissue
concentrations ranged between 43 and 140 ppb ww in samples from Middle Waterway, and
between 59 and 130 ww in samples from Olympic View Resource Area.

7. Historical Fish (English sole) Tissue Data - WDFW - 2005 - 2011

In 2005 to 2011, the WDFW PSAMP collected English sole from Thea Foss Waterway in
Commencement Bay. Information and data from this sampling effort was provided to EPA by
James West (personal communication, October 1, 2012). As described previously, analytical
methods are described in the "Progression of PCB Analysis in PSAMP Fish Sampling Program"
(Godtfredsen et al. 2012), which is provided in Attachment KK-5.

Sampling was conducted in 2005, 2007, 2009, and 2011 during the spring (April/May) of each
year. Samples were collected at the "Baseline Station5" located in Thea Foss Waterway in
Commencement Bay (Attachment KK-7). All fish were collected by bottom trawl, following
environmental sampling protocols developed by the Puget Sound Estuary Program (PSEP 1990),
and more recently summarized in a WDFW SOP ("Standard Operating Procedures For
Collecting Benthic Fish and Macroinvertebrates Using a Bottom Trawl in Puget Sound")
provided as Appendix D6 to a recent WDFW QAPP. Fish were weighed (to the nearest gram)
and measured [fork length (FL)]. Minimum fish size was 23 cm (which was the same minimum
fish size as used during the CB/NT RI sampling event) and is considered representative of adult
fish. Fish sex and fish ages were determined in all sampled sole. Fish age was estimated to the
nearest year by counting the number of clearly defined opaque zones in interopercular bones
under a binocular dissecting microscope. For 2005, 2007, and 2009, six composite samples were

5 Latitude 47.2594559 and Longitude -122.4361766.

6 http://wdfw.wa.gov/publications/01436/wdfw01436.pdf

OU 01 Attachment 5

-------
OU 01 ATTACHMENT 5 - Fish and Shellfish Data

analyzed at the station, and in 2011 only two composite samples were analyzed. Each sample is
a composite of twenty fish.

Fish muscle tissue was sampled and analyzed for the sum of 40 PCB congeners (ng/g wet
weight) and gravimetric lipids (percent). According to WDFW (James West, personal
communication, April 7, 2011), 2005 was the first year that WDFW used a GC/MS sum of

congener method with a consistent extraction technique . The rationale for selecting the 40
congeners for PCB analysis is that they were the most common and abundant congeners in
environmental samples from this region, and are representative of the most bioaccumulative PCB
congeners in this region (James West, personal communication, October 1, 2012). J. West
indicated that other congeners are rare in tissue. Also, WDFW has analyzed fish tissue using the
high-resolution analysis of 209 PCB congeners and J. West stated that data show that the low-
resolution analysis of 40 congeners captures all of the important congeners (i.e., none of the
important congeners are missed by doing low-resolution instead of high-resolution analysis of
PCB congeners). Further discussion on this issue is found in Attachment KK-5.

WDFW PSAMP tissue data are not currently available in Ecology's EIM system, but may be
obtained from J. West (iames.west@dfw.wa.gov). For this report, WDFW provided the English
sole tissue sample results that are shown in Table KK5.

7 The filet was used for the sample. The filet tissue was removed in checkerboard pattern, excluding skin and
organs, such as stomach).

8 Prior to 2005, WDFW used either a different extraction method or a different analytical method, which all required
significant corrections for method biases that are not simple (see Technical Memorandum in Attachment KK-5).
Due to these concerns with earlier analytical methods and results, WDFW did not provide EPA with tissue data prior
to 2005, and WDFW recommends that those earlier data not be used in any trends analyses of PCB concentrations in
fish tissue.

OU 01 Attachment 5

-------
OU 01 ATTACHMENT 5 - Fish and Shellfish Data

Table KK5. Fish and Shellfish Data from WDFW

Sample ID

Species

Year

Station ID

LatNum

LongNum

Matrix

Compo-
site N

nMale

nFem

nUnk

MFUnkRatio

Mean

Composite

Length

(Fork

Length,

mm)

Mean
Composite
Age (years)

Gravimetric
Lipids (%)

SumPCBs
2x17
(ng/g
wet)

SumPCBs40
Congeners
(ng/g wet)

Mean

and

Range

05CB-ESM01

ENGLISH

2005

Thea Foss

47.2594559

-122.436177

muscle

20

14

6



14:6:0

268.5

5.5

0.394124535

84.82

66

75 +/- 8
66to83

05CB-ESM02

ENGLISH

2005

Thea Foss

47.2594559

-122.436177

muscle

20

14

6



14:6:0

260.55

5.8

0.427886379

87.54

69

05CB-ESM03

ENGLISH

2005

Thea Foss

47.2594559

-122.436177

muscle

20

12

8



12:8:0

274

6.35

0.311222339

90.86

69

05CB-ESM04

ENGLISH

2005

Thea Foss

47.2594559

-122.436177

muscle

20

6

4

10

6:4:10

258.25

5.3

0.427550028

110.22

85

05CB-ESM05

ENGLISH

2005

Thea Foss

47.2594559

-122.436177

muscle

20

15

5



15:5:0

253.65

5.75

0.397348976

100.38

77

05CB-ESM06

ENGLISH

2005

Thea Foss

47.2594559

-122.436177

muscle

19

12

2

5

12:2:5

249.105263

6.05

0.455935109

104.3

83

07CB-ESM01

ENGLISH

2007

Thea Foss

47.2594559

-122.436177

muscle

20

13

7



13:7:0

265.15

6.93

0.223731809

69.18

53

40 +/- 9
28to53

07CB-ESM02

ENGLISH

2007

Thea Foss

47.2594559

-122.436177

muscle

20

7

13



7:13:0

269.25

6.1

0.200551533

49.58

38

07CB-ESM03

ENGLISH

2007

Thea Foss

47.2594559

-122.436177

muscle

20

9

11



9:11:0

264.95

6.47

0.235373033

58.24

45

07CB-ESM04

ENGLISH

2007

Thea Foss

47.2594559

-122.436177

muscle

20

11

9



11:9:0

242.85

5.8

0.266469727

41.04

32

07CB-ESM05

ENGLISH

2007

Thea Foss

47.2594559

-122.436177

muscle

20

9

11



9:11:0

251.25

5.7

0.164638482

39.6

28

07CB-ESM06

ENGLISH

2007

Thea Foss

47.2594559

-122.436177

muscle

20

9

11



9:11:0

254.2

6.6

0.261432205

54.78

43

09CB-ESM01

ENGLISH

2009

Thea Foss

47.2594559

-122.436177

muscle

20

10

10



10:10:0

275.4

6.5

0.177982135

91.52

67

85 +/- 26
62tol30

09CB-ESM02

ENGLISH

2009

Thea Foss

47.2594559

-122.436177

muscle

20

12

8



12:8:0

266.45

6.25

0.210885491

174.32

130

09CB-ESM03

ENGLISH

2009

Thea Foss

47.2594559

-122.436177

muscle

20

14

6



14:6:0

271.85

7.45

0.127508613

98.68

73

09CB-ESM04

ENGLISH

2009

Thea Foss

47.2594559

-122.436177

muscle

20

16

4



16:4:0

255.8

6.2

0.146260352

103.88

76

09CB-ESM05

ENGLISH

2009

Thea Foss

47.2594559

-122.436177

muscle

20

12

8



12:8:0

249.3

5.5

0.18694131

134.6

99

09CB-ESM06

ENGLISH

2009

Thea Foss

47.2594559

-122.436177

muscle

20

11

9



11:9:0

257.6

6.05

0.1365926

83.78

62

11CB-ESM01

ENGLISH

2011

Thea Foss

47.2594559

-122.436177

muscle

20

10

8

2

10:8:2

265



0.270899147

95

71

71to92

11CB-ESM02

ENGLISH

2011

Thea Foss

47.2594559

-122.436177

muscle

20

10

10

0

10:10:0

290.2





120

92

9

OU 01 Attachment 5

-------
OU 01 ATTACHMENT 5 - Fish and Shellfish Data

Results in Table KK5 are provided for two different methods: 1) as "two times the sum of 17
PCB congeners" (note: one of the congeners co-elutes so the sum is actually two times the sum
of 18 PCB congeners; see Table 1 in Attachment KK-5); and, 2) as the sum of 40 PCB congeners
(note: six of the congeners co-elute so the sum is actually two times the sum of 46 PCB
congeners; see Table 1 in Attachment KK-5). WDFW indicates that two times the sum of 17
PCB congeners is a better comparison to total PCBs (Aroclors) than using the sum of 40 PCB
congeners.

8. Historical Crab Tissue Data. Commencement Bay - WDFW - 2011 and 2012

James West of WDFW (October 31, 2012) indicated that WDFW collected crab and spot prawn
from Puget Sound in 2011 and 20129. Crab and spot prawn tissue are being analyzed for
contaminants, and data will be available for WDOH to use in evaluating potential health impacts
to humans who eat these species. In 2012, a QAPP ("Toxic Contaminants in Dungeness crab
{Cancer magistef) and Spot Prawn (Pandalusplatyceros) from Puget Sound, Washington,
USA") was completed for ongoing work, and is available at this link:

http://wdfw.wa.gov/publications/01436/wdfw01436.pdf

In Commencement Bay, five samples of crab tissue were collected from the bottom trawl (as part
of the fish sampling effort) at the Thea Foss Waterway location. Samples were analyzed for
normal PSAMP parameters (41 PCB congeners, PBDE, metals, PAHs).

Historical Non-urban Puget Sound Tissue Dataset for Total PCBs: English sole and Crab -
1989-2006

For comparison purposes, this section provides information on a recent compilation of total PCB
concentrations in fish and crab tissue collected from non-urban Puget Sound locations outside of
known contaminated sites.

In WDOH 2006, Table 3 summarizes mercury (ppm, wet weight) and PCBs (ppb, wet weight)
measured in four species of rockfish, English sole, Chinook salmon and coho salmon from Puget
Sound, in urban, near-urban, and non-urban areas (see Attachment KK-3).

In 2009, the remedial investigation for the Lower Duwamish Waterway Superfund Site in
Seattle, WA, included a summary of PCB and PCB congener data in fish and crab tissue (see
Attachment KK-12). These data may be useful for comparison purposes in later evaluations in
Commencement Bay.

9 Jim West (WDFW) indicated to EPA that WDFW collected Dungeness crab from Commencement Bay, but crab
muscle was not analyzed for PCBs. In 2005, WDFW collected crabs from some of the English sole trawl locations -
crab muscle, paired with egg samples for maternal crabs, was analyzed for PCBs (it is not clear if data were
collected in Thea Foss Waterway). Data have not yet been published.

OU 01 Attachment 5

-------
OU 01 ATTACHMENT 5 - Fish and Shellfish Data

In 2012, EPA Region 10 compiled a non-urban Puget Sound tissue data set from various studies
as part of the RI/FS (AECOM 2012) for the Lower Duwamish Waterway Superfund site. Total
PCB concentrations in fish and crab collected from non-urban Puget Sound locations outside of
known contaminated sites. Total PCB concentrations (ug/kg wet weight) were summarized and
are provided in Attachment KK-8. Data summaries in Attachment KK-8 include some WDFW
PCB tissue data for the time period prior to 2005 - as described in earlier sections, J. West
(WDFW) recommends that EPA not use any PCB tissue data prior to 2005 for PCB tissue trend
analyses in Commencement Bay.

11

OU 01 Attachment 5

-------
OU 01 ATTACHMENT 5 - Fish and Shellfish Data

References

EPA. 1989. Record of Decision for Commencement Bay Nearshore/Tideflats Superfund Site.
EPA Region 10, Seattle, WA.

EPA. 1997. Explanation of Significant Differences for Commencement Bay
Nearshore/Tideflats Superfund Site. EPA Region 10, Seattle, WA.

Godtfredsen, K., S. McGroddy, J. West, L. Kissinger, E. Hoffman, and D. Hotchkiss. 2012.
Technical Memorandum: 6/20/12 Meeting Notes: PCB Analysis in Tissue. Final text revised by
consensus on 12/5/12.

Progression of PCB Analysis in PSAMP Fish Sampling Program

Hayslip, G., L. Edmond, V. Partridge, W. Nelson, H. Lee, F. Cole, J. Lamberson , and L. Caton.
2006. Ecological Condition of the Estuaries of Oregon and Washington. EPA 910-R-06-001.
U.S. Environmental Protection Agency, Office of Environmental Assessment, Region 10,
Seattle, Washington, http://www.epa.gov/emap2/west/html/docs/eceow.html

O'Neill S, West J, and Hoemann J. 1998. Spatial Trends in the Concentration of Polychlorinated
Biphenyls (PCBs) in Chinook (Oncorhynchus tshawytschd) and Coho Salmon (O. kisutch) in
Puget Sound and Factors Affecting PCB Accumulation: Results from the Puget Sound Ambient
Monitoring Program. Puget Sound Research 1998.
http://www.psat.wa.gov/Publications/98 proceedings/pdfs/2b oneill.pdf

TetraTech. 1985. Commencement Bay Nearshore/Tideflats Remedial Investigation. EPA-
910/9-85-134b. Prepared for Washington Department of Ecology and U.S. EPA. Tetra Tech,
Inc., Bellevue, WA.

Versar. 1985. Assessment of Human Health Risk from Ingesting Fish and Crabs from
Commencement Bay. Prepared by Hayslip et al. (Versar) for Washington Department of
Ecology, under contract to EPA. EPA 344/9H35-129.

Washington Department of Ecology. 1996. Washington State Pesticide Monitoring Program,
Pesticides and PCBs in Marine Mussels, 1995. Publication 96-301. Environmental
Investigations and Laboratory Services Program, Olympia, WA.
httys://fortress. wa. gov ecy publications summarypav.es 96)301.html

Washington Department of Ecology. 2010. Urban Waters Initiative, 2008, Sediment Quality in
Commencement Bay. April 2010. Publication No. 10-03-019.
https://fortress.wa.gov/ecy/publications/publications/1003019.pdf

Washington Department of Health. 2006. Human Health Evaluation of Contaminants in Puget
Sound Fish. Washington DOH, Division of Environmental Health, Olympia, WA.
http://www.doh.wa.gOv/portals/l/Documents/Pubs/334-104.pdf

12

OU 01 Attachment 5

-------
OU 01 ATTACHMENT 5 - Fish and Shellfish Data

Washington Department of Health. 2006. Puget Sound Fish Consumption Advice. Fact Sheet.
October 2006. Washington DOH, Division of Environmental Health, Olympia, WA.
http ://www. doh. wa. gov/Portal s/1 /Documents/Pub s/334-098.pdf

West, J, O'Neill S, Lippert G, and Quinnell S. 2001. Toxic contaminants in marine and
anadromous fishes from Puget Sound, Washington: Results of the Puget Sound Assessment
Monitoring Program fish component, 1989 - 1999. Technical Report FTP01-14, Washington
Department of Fish and Wildlife, Olympia, WA.

West, James E. James West, Washington Department of Fish and Wildlife, Personal
Communication with Laura Beulow, EPA Region 10, Seattle, WA. Email and Excel
Spreadsheet of Sample Locations and Data for English sole, 2005 through 2009. April 7, 2011.

West, James E. James West, Washington Department of Fish and Wildlife, Personal
Communication with Karen Keeley, EPA Region 10, Seattle, WA. Email and Excel Spreadsheet
of Sample Locations and PCB Data for English sole, 2005 through 2011. October 1, 2012.

West, James E. James West, Washington Department of Fish and Wildlife, Personal
Communication with Karen Keeley, EPA Region 10, Seattle, WA. Crab and spot prawn tissue
analyses. October 31, 2012.

13

OU 01 Attachment 5

-------
Attachment KK-1. Station locations for fish and crab trawl locations in Commencement Bay, 1985 (Source: Versar
1985)

Attachment KK-1. Station locations for fish and crab trawl locations in Commencement Bay, 1985 (Versar
1985).

Page 1

OU 01 Attachment 5

-------
Attachment KK-1. Station locations for fish and crab trawl locations in Commencement Bay, 1985 (Source: Versar
1985)

719

718 -

o

n
-w
c

m

m
3

o

70S

HYLEBOS WATERWAY

Bloacc./Pathology Survey Transact*

707

T~T-—r—-j—r-^l	— I —I		1		1— I	I	T

1,524 1,526 1.523 1,53 1.532 1-534 1.536 1.538 1.54

(Millions)

1,542

Page 2

OU 01 Attachment 5

-------
#• • • 1 t • •

Attachment KK-1. Station locations for fish and crab trawl locations in Commencement Bay, 1985 (Source: Versar

BLAIR WATERWAY

(Thousands)

Page 3

OU 01 Attachment 5

-------
Attachment KK-1. Station locations for fish and crab trawl locations in Commencement Bay, 1985 (Source: Versar
1985)

SITCUM AND MILWAUKEE WATERWAYS

(Thousands)

Page 4

OU 01 Attachment 5

-------
Attachment KK-1. Station locations for fish and crab trawl locations in Commencement Bay, 1985 (Source: Versar
1.985)

St. Paul and Middle Waterways

Bloacc./Pathology Survey Tran**ets
-1,519 	 	

-1.5195

-1.52

-1.5205

/"Ni

m
c.

,521

I

-1.5215

-1,522

— 1,5225

-1.525

708	708 .	710	712

(Thousands}

Page 5

OU 01 Attachment 5

-------
Attachment KK-1. Station locations for fish and crab trawl locations in Commencement Bay, 1985 (Source: Versar
1985)

CITY WATERWAY

(Thousands)

Page 6

OU 01 Attachment 5

0 ) r

-------
Attachment KK-1. Station locations for fish and crab trawl locations in Commencement Bay, 1985 (Source: Versar

1985)	RUSTON SHORELINL

Bioacc ./Pcth ©logy Survey Transects

731
730 -
729 -
728

727 -
726 -
725 -
724 -
723 -
722,
721
720
719
718
717
716
715 H
714
713
712

1.436

v^S-7

S ~72t.

KS—725

r_^,HRS-71E

70E

70S

1.5

1.504

1.508
(Millie ns)

1.51 2

1 .hi 6

Page 7

OU 01 Attachment 5

-------
WASHING'ON S T A' E
DEPARTMENT OF

ECOLOGY

Washington State Pesticide Monitoring Program

Pesticides and PCBs in
Marine Mussels, 1995

March 1996

Publication No 96-301
printed on recycled paper

6

Page 1

OU 01 Attachment 5

-------
ATTACHMENT KK-2. Washington State Pesticide Monitoring Program (Source: Ecology 1996)



Table 3. Pesticides and PCBs Detected in 1995 WSPMP Mussel Samples (ug/Kg (ppb) wet wt.)

Pad ill a Duwamish Hylebos Chambers Budd
Compound Bay Waterway Waterway Creek Inlet Ilwaco

DDT & Analogs













4,4'-DDT

0.12 J

2.8 NJ

5.6 NJ

nd

nd

0.91

4,4'-DDE

0.57 J

1.4

6.2

0.33 J

0.70

6.5

4,4'-DDD

0.05 J

0.88 J

3.8

nd

0.45 J

1.8

2,4 -DDT

nd

0.61 J

1.6

nd

nd

0.25 J

2,4'-DDE

nd

nd

0.14 J

nd

nd

nd

Cvclodienes













dieldrin

nd

0.22

0.74

0.16 N

nd

0.43 J

endosulfan I

0.15 J

nd

24

nd

0.66 NJ

0.18

endosulfan II

nd

nd

12.

nd

nd

nd

endosulfan sulfate

nd

nd

7.9

nd

nd

nd

cis-chlordane

nd

0.97

1 2

0,37 J

0.49 J

0.33 J

trans-chlordane

nd

0.91

1.0

nd

0.58

0.50

cis-nonachlor

nd

0.20 J

0.32 J

nd

nd

nd

trans-nonachlor

nd

0.66 NJ

1.0 NJ

0.38

0.34

nd

heptachlor

nd

nd

nd

nd

nd

0,01 J

heptachlor expoxide

nd

nd

ncl

nd

nd

0.14 J

Benzene Hexachloride













alpha BHC

0.06 J

0.06 J

0.11 J

nd

0.07 J

nd

gamma BHC

nd

nd

0.08 J

nd

nd

nd

Misc. Chlorinated Pesticides











hexachlorobenzene

0.03 J

nd

0.45

nd

nd

0.14 J

DCPA (dacthal)

nd

nd

nd

nd

nd

0.33

Phenols













pentachloroanisole

nd

0.05 J

0.30 J

nd

0.15 J

nd

Polvchlorinated Biphenvls











PCB-1248

nd

nd

18

nd

nd

nd

PCB-1254

2 J

32

46

6

21

6 N

PCB-1260

nd

12 J

6 J

2 J

nd

nd

% lipid

0.8

1.1

1.2

1.0

1.4

1.1

% non-polar lipid

0.1

0.1

0.4

0.1

0.1

0.1

% moisture

90

87

86

87

84

89

nd = not detected J

= estimated value N =

: tentatively identified



Page 7

Page 2

OU 01 Attachment 5

-------
ATTACHMENT KK-2. Washington State Pesticide Monitoring Program (Source: Ecology 1996)

Appendix A. Location and Size of 1995 WSPMP Mussel Samples

Sample	Length (ram)

	Site	Date Latitude (N) Longitude (W) No.	N = (mean + /-2sd)

Padilla Bay (1) 5/17 48 30.4 122 28.9 20-8041 84 31+/-6
Duwamish Waterway (2) 5/17 47 34.4 122 21.2 20-8042 57 40 + /-8
Hylebos Waterway (3) 5/17 47 15.6 122 21.4 20-8043 45 45 + Z-9
Chambers Creek (4) 5/17 47 11.0 122 34.7 20-8044 33 51+/-8
Budd Inlet (5) 5/25 47 02.9 122 53.6 21-8046 30 52 + Z-7
Columbia R. nr Ilwaco (6) 5/16 46 17.2	124 03.1	20-8040 56	40 + /-7

(1)	Old pilings near Joe Leary Slough, one mile north of research station

(2)	Hast shore of west waterway, just upstream of Fisher Mills

(3)	Railroad bridge pilings at mouth of Hylebos Creek

(4)	South shore of creek mouth at Thomas M. Chambers monument

(5)	Head of East Bay at culvert at mouth of Moxlie Creek

(6)	Fort Canby State Park boat launch

Page 3

OU 01 Attachment 5

-------
ATTACHMENT KK-2. Washington State Pesticide Monitoring Program (Source: Ecology 1996)

Appendix C. Historical Data on Pesticides/PCBs in Washington Mussels

(ug/Kg (ppb) wet wt

.)







Commencement



Columbia

Compound

Year

Elliott Bay

Bav

Budd Inlet

River

t-DDT

1975(1)

na

na

na

na



1976(2)

na

na

na

0.3*



1977(2)

na

na

na

0.8*



1978(2)

na

na

na

na



1981 (3)

na

6.8

na

na



CO

3

na

nd

na

na



1986(4)

17

4.3

1.8

9.8



1987(4)

4.6

2.6

2.6

4.7



1988(4)

6.4

0.8

3.2

8.2



1995®

5.1

16

1.2

3.4

dieldrin

1981

na

nd

na

na



1982

na

nd

na

an



1986

1.6

0.7

0.6

0.6



1987

0.3

1.8

0.9

0.9



1988

0.4

nd

0.4

0.5



1995

nd

0.1

nd

0.4

t-chlordane**

1981

na

nd

na

na



1982

na

nd

na

na



1986

3.5

1.8

0.9

1



1987

0.8

2.5

1.7

0.6



1988

1.3

0.2

1.4

0.8



1995

1.2

1.5

0.5

0.5

gamma BHC

1981

na

n d

na

na



1982

na

n d

na

na



1986

0.04

0.2

0.2

0.1



1987

nd

0.09

0.2

0.04



1988

0.2

0.02

0.1

0.1



1995

nd

0.08

nd

n d

hexachlorobenzene

1981

na

nd

na

na



1982

na

nd

na

na



1986

nd

nd

nd

nd



1987

nd

0.09

0.04

nd



1988

0.3

0.4

0.2

0.1



1995

nd

0.4

nd

0.1

Page 4

OU 01 Attachment 5

-------
ATTACHMENT KK-2. Washington State Pesticide Monitoring Program (Source: Ecology 1996)

Appendix C. (continued)
Compound

Year

Elliott Bav

Commencement
Bav

Budd Inlet

Columbia
River

t-PCBs

I975(l)

210

79

27

na



1976(2)

na

na

11a

5



1977(2)

na

na

11a

3



1978(2)

na

na

11a

3



1981<3>

na

82

tin

na



1982(3)

na

26

na

na



1986(4)

143

25

17

1 1



1987<4)

75

44

22

12



1988(4)

58

5

18

14



1995<5)

44

70

21

6

na = not analyzed
nd = not detected
* DDE only

** t-chlordane = alpha-chlordane + trans-nonachlor + heptachlor 4- heptachlor epoxide (as reported in NOAA, 1989)

(1)	Mowrer et al., 1977 [Elliott Bay site is W. Duwamish WW: Commencment Bay site is mouth of Hylebos WW.
Budd Inlet site is Priest Point Park]

(2)	Farnngton et al., 1982 [Columbia River site is North Jetty: Myithis culifornianus ]

(3)	Hopkins et al., 1985 [Commencement Bay site is mouth of City Waterway]

(4)	NOAA ,1989 [Elliott Bay site is Four-Mile Rock: Commencement Bay site is Tahlequah Pt.|

(5)	present study [Elliott Bay site is W. Duwamish WW; Commencement Bay site is head of Hylebos WW")

Note Data from references (2) and (4) converted from dry wt. to wet wt. assuming 87% moisture (Table 2)

Page 5

OU 01 Attachment 5

-------
ATTACHMENT KK-3. Summary of PCBs and mercury in fish tissue from Puget Sound (Source: DOH 2006)

Page 1	OU 01 Attachment 5

-------
ATTACHMENT KK-3. Summary of PCBs and mercury in fish tissue from Puget Sound (Source: DOH 2006)

Human Health Evaluation of
Contaminants in Puget Sound Fish

October 2006

Prepared by

The Washington State Department of Health
Division of Environmental Health
Office of Environmental Health Assessments
Olympia, Washington

Division o f Environmental Health

Page 2

OU 01 Attachment 5

-------
ATTACHMENT KK-3. Summary of PCBs and mercury in fish tissue from Puget Sound (Source: DOH 2006)

Table ES-1. Meal recommendations for rockfish from Puget Sound listed by Washington State
Department of Fish and Wildlife recreational marine areas.

Recreational
Marine Area

(see Figure FS-1)

Consumption
(iiiidance lor rockl'ish
from Puget Sound

Kxeeptions

(soo Figure FS-2)

East Juan de Fuca
Strait

No more than 1 meal/week

None

San Juan Islands

No more than 1 meal/week

None

8.1

Deception Pass,
Hope Island, and
Skagit Bay

No more than 1 meal/week

None

8.2

Port Susan and
Port Gardner

No more than 1 meal/week -
with noted exceptions

No more than 2 meals per month: Mukilteo-Everett
and Port Gardner.

Admiralty Inlet

No more than 1 meal/week

None

Seattle-Bremerton
Area

No more than 1 meal/week -
with noted exceptions

No consumption: Elliott Bay (east of imaginary
boundary from Duwamish Head to Pier 91, including
the Duwamish River) and Sinclair Inlet (west of Dyes
Inlet and Mitchell Point).

Tacoma-Vashon
Area

No more than 1 meal/week -
with noted exceptions

No more than 2 meals per month: Commencement
Bay (SE of imaginary boundary between Sperry Ocean
dock and Cliff House Restaurant).

Hood Canal

No more than 1 meal/week

None

South Puget
Sound

No more than 1 meal/week

None

NOTE: Meal size equals eight ounces of uncooked fish for an average-sized adult.

English Sole and Other Flatfish

Page 3

OU 01 Attachment 5

-------
ATTACHMENT KK-3. Summary of PCBs and mercury in fish tissue from Puget Sound (Source: DOH 2006)

Table ES-2. Meal recommendations for English sole and other flatfish from Puget Sound listed
by recreational marine areas (see Figure ES-3).

Recreational
Marine Area . ..

Figure FS-1)

Consumption (iuidaiice lor

Knglish Sole and other
Klairish from Puget Sound

Kxceptions

(see Figure FS-3)

East Juan de Fuca
Strait

No meal limit

None

San Juan Islands

No meal limit

None

8.1

Deception Pass,
Hope Island, and
Skagit Bay

No meal limit

None

8.2

Port Susan and
Port Gardner

No meal limit - with noted
exceptions

No more than 2 meals per month: Everett-
waterfront from Mukilteo ferry dock to City of
Everett. Based on extrapolation from sediment
concentrations.

Admiralty Inlet

No meal limit

None

Seattle-Bremerton
Area

No meal limit - with noted
exceptions

No consumption: Duwamish Waterway
(includes Harbor Island East and West
Waterways)

No more than 1 meal per month: Sinclair Inlet
(west of Dyes Inlet and Mitchell Point).

No more than 2 meals per month: Elliott Bay
(east of imaginary boundary from Duwamish
Head to Pier 91).

No more than 1 meal per wk: Eagle Harbor
and Port Orchard (waterway separating
Bainbridge Island and Kitsap Peninsula).

Tacoma-Vashon
Area

No meal limit - with noted
exceptions

No more than 2 meals per month: Inner
Commencement Bay (SE of imaginary boundary
between Sperry Ocean dock and Cliff House
Restaurant).

No more than 1 meal per wk: Outer
Commencement Bay (SE of imaginary boundary
between Boathouse Marina and Brown's Point).

Hood Canal

No meal limit

None

South Puget
Sound

No meal limit

None

NOTE: Meal size equals eight ounces of uncooked fish for an average sized-adult.

Puget Sound Salmon

DOH recommends the following with respect to Chinook and coho salmon in Puget Sound:

• Chinook salmon from Puget Sound may be consumed once (eight ounces) per week (or
four times per month).

Page 4

OU 01 Attachment 5

-------
ATTACHMENT KK-3. Summary of PCBs and mercury in fish tissue from Puget Sound (Source: DOH 2006)

Figure ES-2. Meal limit recommendations for rockfish from urban areas of Puget Sound. Area
designations are consistent with WDFW recreational marine areas. The general meal limit
recommendation for rockfish throughout Puget Sound is 1 meal per week.

,Tyee Manna |

Commencement
Bay

CHd Tewt£._

Area 8-1 \



s.

Whidbey
Island

Area 9

t Pier 91 1

Area 10

Legend

No consumption

1	meal per month

2	meals per month

1 meal per week ( 4 meals per month)
No Limits

Everett

'' Mukilteo I
Ferry Doc* |

Island

t*3*

6rdgej

Area 10

J*

ItlamJ

Page 5

19

OU 01 Attachment 5

-------
ATTACHMENT KK-3. Summary of PCBs and mercury in fish tissue from Puget Sound (Source: DOH 2006)

Figure ES-3. Meal limit recommendations for English sole and flatfish from urban areas of
Puget Sound. Area designations are consistent with WDFW recreational marine areas.

Area 10

Area 6-1 \

Wfoidbey
Island

Legend

No consumption

1	meal per month

2	meals per month

1 meal per week ( 4 meals per month)
No Limits

Area 8-2

Everett

\

Mukifteo
Ferry Dock |

Area 9

B&ntmctjie

Oyws info?

H&rtQr

fV

™ L %	Rrirt-n

Pgmt
.Whte

f] ^Marteefl
Fi> _Bndgej^k

,uU

Area 10

StfJCtttrf

<4*



Boatfrxise
W*nna

Cl«fl Hcvsfl
Raalauranl

Duwarrash
Head

Page 6

20

OU 01 Attachment 5

-------
ATTACHMENT KK-3. Summary of PCBs and mercury in fish tissue from Puget Sound (Source: DOH 2006)

Table 1. Puget Sound English sole (ES) and rockfish (R) sampling stations classified by urban,
near-urban, or non-urban setting.*

I rban stations

Near urban stations

Nun urban stations

Commencement Bay (Thea Foss)

ES, R

Budd Inlet

ES

Apple Cove Point

ES

Commencement Bay 2

ES, R

Bellingham Bay (outer)

ES

Birch Point

ES

Duwamish

ES

Blakely Rock

R

Carr Inlet 1

ES

Eagle Harbor

ES

Brown's Point

R

Case Inlet 1 (South
Case Inlet)

ES

Elliott Bay (Seattle Waterfront)

ES, R

Cherry Point

ES

Case Inlet 3 (North
Case Inlet)

ES

Elliott Bay 2 (Harbor Island)

ES, R

Commencement Bay 3
(Ruston)

ES

Day Island

R

Elliott Bay 4 (Myrtle Edwards)

ES, R

Commencement Bay 4
(Old Tacoma)

ES, R

Discovery Bay

ES

Fuller Shipwreck (Elliott Bay)

R

Commencement Bay 5
(Brown's Point)

ES, R

Double Bluff

R

Mukilteo-Everett

ES, R

Dalco Passage

R

Fern Cove

ES

Outer Commencement Bay

ES

Dash Point

ES

Foulweather

R

Port Gardner

ES, R

Dyes Inlet

ES

Hood Canal

ES, R

Sinclair Inlet

ES, R

Elliott Bay 5 (Alki)

ES

Hood Canal M

ES

Sinclair Inlet (Tribal)

R

Gig Harbor

R

Hood Canal S

ES





Lakota

R

McAurther Bank

ES





Liberty Bay

ES

Nisqually

ES





Port Orchard

ES

Orcas Island

ES, R





Port Townsend

ES

Outer Birch Point

ES





Sinclair Inlet 2 (Outer
Sinclair)

ES, R

Pickering Passage

ES





Sinclair Inlet 3

ES

Possession Point

ES





Sinclair Inlet 4 (Battle
Point)

ES

Port Ludlow

ES





Sinclair Inlet 5 (Blake
Island)

ES

Port Madison

ES









Point Roberts

ES









Port Susan

ES









San Juan Islands

R









Saratoga Passage

ES









Shilshole

ES









Strait of Juan de Fuca

ES









Strait of Georgia

ES









Vendovi Island

ES









Wollochet

ES

* Urban, near-urban, and non-urban stations were determined by WDFW (West et al. 2001) and updated for this
report.

Page 7

25

OU 01 Attachment 5

-------
ATTACHMENT KK-3. Summary of PCBs and mercury in fish tissue from Puget Sound (Source: DOH 2006)

Figure 2. Puget Sound sites where English sole were sampled by WDFW for the Puget Sound
Assessment and Monitoring Program.

Page 8

27

OU 01 Attachment 5

-------
ATTACHMENT KK-3. Summary of PCBs and mercury in fish tissue from Puget Sound (Source: DOH 2006)

Figure 1. Puget Sound sites where rockfish were sampled by WDFW for the Puget Sound
Assessment and Monitoring Program.

Page 9

26

OU 01 Attachment 5

-------
ATTACHMENT KK-3. Summary of PCBs and mercury in fish tissue from Puget Sound (Source: DOH 2006)

Tissue Analysis

Page 10

OU 01 Attachment 5

-------
ATTACHMENT KK-3. Summary of PCBs and mercury in fish tissue from Puget Sound (Source: DOH 2006)

Total PCBs were estimated in this report using two methods:

• Arithmetic summation of individual Aroclors (1248, 1254, and 1260), and

Risk Assessment

• The second step is to obtain contaminant data (in this case from PSAMP) or to analyze
fish samples for contaminant concentrations to estimate levels in fish tissue.

• Using this information, DOH can establish what contaminants people are exposed to and
estimate the doses a person would receive from consuming fish.

Page 11

OU 01 Attachment 5

-------
ATTACHMENT KK-3. Summary of PCBs and mercury in fish tissue from Puget Sound (Source: DOH 2006)

Table 11. Calculated meal limits for English sole at non-urban, near-urban and select urban
locations of Puget Sound.

Calculated

Average

meals per

Calculated meals

Mercury

Average PCI*

month

per month based

concent ration

concentration

based on

on additive

Location

(ppiii)

(ppb)

mercury

PCBs

endpoint

Non-urban

0.051

9.3

locations

Near-urban
locations

0.053

17.2

9.3

7.3

Elliott Bay a

0.080

69.0

2.3

2.2

Sinclair Inlet

0.074

121

1.3

Commencement
Bay b

0.069

60.9

2.6

2.5

a Comprised of Elliott Bay, Elliot Bay 2, and Elliott Bay 4 stations.

b Comprised of Commencement Bay, Commencement Bay 2, and Outer Commencement Bay stations.

English sole - based on PSAMP sediment PCB concentrations

[;mPCB] = el64*\sPCB'f35*e()U*Age

Where:

mPCB = concentration of PCBs in muscle as sum of 3 Aroclors, ng/g, wet wt.,
sPCB = concentration of PCBs in sediments as sum of 3 Aroclors, ng/g, dry wt.,

Age = fish age in years.

Although the resulting predicted concentration in fish tissue is an estimate, it is useful to
calculate meal limits for locations where sediment concentrations are known but where English

Page 12 OU 01 Attachment 5

-------
ATTACHMENT KK-3. Summary of PCBs and mercury in fish tissue from Puget Sound (Source: DOH 2006)

Table D1 (cont.). Estimated meals per month for rockfish from Puget Sound, based on
contaminant concentrations for each station and chemical.

Location

Rockfish
Species

Type

Mercury



Total PCBs (Aroclors)

Total PCBs
(Sum of 15 congeners)

Lakota

Quillback

I

4 | 0.295

3

4 | 62.8 | 3

0 | NA | NA

Recreational Management Area 12

Hood Canal

Quillback

C

8

0.183

4

2

7.7

21

0

NA

NA

Copper

C

1

0.170

5

1

6.5

25

0

NA

NA

Recreational Management Area 13

Day Island

Quillback

c

6

0.098

8

0

NA

NA

0

NA

NA

Copper

c

18

0.095

8

11

8.3

19

0

NA

NA

NOTE: Meal = eight ounces
N = sample size

Type: I = individual sample, C = composite sample
NA = Not available

Table D2. Estimated meals per month for English sole from Puget Sound, based on contaminant
concentrations for each station and chemical.

Location

Mercury

Total PCBs
(Aroclors)

Tot
(sum of ]

al PCBs
5 congeners)

Type

N

Mean
(PPm)

Meals/
month

N

Mean
(PPb)

Meals/
month

N

Mean
(PPb)

Meals/
month

Recreational Management Area 6

Discovery Bay

C

3

0.093

9

3

3.9

41

0

NA

NA

Strait of Juan
de Fuca

C

6

0.050

16

6

7.0

23

0

NA

NA

Recreational Management Area 7

Bellingham
Bay (outer)

C

9

0.031

26

9

3.8

42

0

NA

NA

Birch Point

C

6

0.034

24

6

5.1

32

0

NA

NA

Cherry Point

C

3

0.038

21

0

NA

NA

3

13.9

12

McAurther
Bank

C

3

0.043

19

3

3.2

50

0

NA

NA

Orcas Island

C

3

0.027

30

3

3.6

45

0

NA

NA

Outer Birch Pt.

C

3

0.047

17

3

3.1

52

0

NA

NA

Point Roberts

C

3

0.020

40

3

4.8

33

0

NA

NA

Strait of
Georgia

C

34

0.051

16

21

5.8

28

15

11.2

14

Vendovi Island

I and C

44

0.038

21

23

I

II

C

3.8

42

014

7.8

21

Recreational Management Area 8-1

Saratoga
Passage

C

6

0.072

11

6

20.2

8

0

NA

NA

Recreational Management Area 8-2

Mukilteo-
Everett

C

2

0.040

20

0

NA

NA

0

NA

NA

Port Gardner

C

34

0.048

17

21

17.5

9

8

22.4

7

Port Susan

C

3

0.070

11

0

NA

NA

1

5.5

29

F

tccrcational Management Area 9

Possession
Point

C

6

0.057

14

6

11.7

14

0

NA

NA

Page 13

120

OU 01 Attachment 5

-------
ATTACHMENT KK-3. Summary of PCBs and mercury in fish tissue from Puget Sound (Source: DOH 2006)

Table D2 (cont.). Estimated meals per month for English sole from Puget Sound, based on
contaminant concentrations for each station and chemical.



Memirv

Tolal P( lis
(Aroclors)

lot

(sum of

.il PC lis

5 congeners)

Location

T\ pe

N

Menu

ippim

Men K

IlkHllll

N

\ 1 e: 111
(pph)

Me;ils
IIHilllll

N

Me;m
ipph)

Me;ils
llkilllll

Port Ludlow

C

3

0.070

11

3

6.7

24

0

NA

NA

Port Townsend

C

12

0.049

16

12

9.7

17

0

NA

NA

Recreational Management Area 10

Apple Cove Pt.

C

6

0.063

13

6

9.8

16

0

NA

NA

Duwamish

C

9

0.064

13

6

168

1

3

164

1

Dyes Inlet

c

6

0.047

17

6

28.0

6

0

NA

NA

Eagle Harbor

c

12

0.095

8

6

42.6

4

6

52.3

3

Elliott Bay

C and I

63

0.079

10

29
I

21
C

64.4

2

15

75.8

2

Elliott Bay 2

C

3

0.095

8

2

26.5

6

3

85.9

2

Elliott Bay 4

C

3

0.080

10

0

NA

NA

3

21.0

8

Elliott Bay 5

C

3

0.072

11

3

16.7

10

3

22.4

7

Liberty Bay

C

6

0.046

17

6

23.3

7

0

NA

NA

Port Madison

C

3

0.046

17

3

13.3

12

0

NA

NA

Port Orchard

C

6

0.067

12

6

36.8

4

0

NA

NA

Sinclair Inlet

C and I

58

0.074

11

24
I

21
C

121

1

15

122

1

Sinclair Inlet 2

C

3

0.071

11

0

NA

NA

3

22.8

7

Sinclair Inlet 3

C

3

0.063

13

0

NA

NA

3

63.8

3

Sinclair Inlet 4

C

3

0.061

13

0

NA

NA

3

38.8

4

Sinclair Inlet 5

C

3

0.086

9

0

NA

NA

3

31.0

5

Shilshole

C

6

0.059

14

5

22.9

7

0

NA

NA

Recreational Management Area 11

Commenceme
ntBay

C and I

57

0.068

12

35
I

20
I

63.0

3

14

79.1

2

Commenceme
nt Bay 2

C

3

0.067

12

0

NA

NA

3

82.4

2

Commenceme
nt Bay 3

C

3

0.049

16

0

NA

NA

3

34.2

5

Commenceme
nt Bay 4

C

3

0.051

16

0

NA

NA

3

43.2

4

Commenceme
nt Bay 5

C

3

0.062

13

0

NA

NA

3

55.5

3

Dash Point

C

6

0.082

10

6

28.5

6

0

NA

NA

Fern Cove

C

3

0.072

11

3

19.3

8

0

NA

NA

Outer
Commenceme
nt

C

6

0.075

11

6

41.8

4

0

NA

NA

Recreational Management Area 12

Hood Canal

C

36

0.059

14

21

6.4

25

15

11.8

14

Hood Canal M

C

6

0.038

21

6

3.5

46

0

NA

NA

Hood Canal S

C

6

0.030

27

6

4.8

33

0

NA

NA

Page 14

121

OU 01 Attachment 5

-------
ATTACHMENT KK-3. Summary of PCBs and mercury in fish tissue from Puget Sound (Source: DOH 2006)

Table D2 (cont.). Estimated meals per month for English sole from Puget Sound, based on
contaminant concentrations for each station and chemical.













lotal PC lis

Total PC lis







Mercury





(Aroclors)

(sum of

5 congeners)







Moan

\1e;ils



Mo;iii

Mo;ils



Mo;iii

Mo;ils

Location

T\ po

N

(ppm)

IIIOIII ll

N

i pph i

IlkHllll

\

(pphi

IIIOIIlll

Recreational Management Area 13

Budd Inlet

C

9

0.035

23

9

8.8

18

0

NA

NA

Carr Inlet

C

6

0.052

15

6

14.0

11

0

NA

NA

Case Inlet 1

C

6

0.045

18

6

16.0

10

0

NA

NA

Case Inlet 3

C

3

0.040

20

3

8.3

19

0

NA

NA

Nisqually

C

24

0.061

13

12

21.5

7

15

24.0

7

Pickering

C

6

0.032

25

6

9.2

17

0

NA

NA

Wollochet

C

6

0.055

15

6

26.3

6

0

NA

NA

NOTE: Meal = eight ounces
N = sample size

Type: I = individual sample, C = composite sample
NA = Not available

Table D3. Estimated meals per month for Chinook salmon from Puget Sound, based on
contaminant concentrations for each station and chemical.

Location

Mercury

Total PC"lis (Aroclors)

1'vpe

N

Mean
(ppm)

Meals/
month

\

Mean
(PPh)

Meals/month

In-river Fisheries

Nooksak River

C

18

0.087

9

28

37.9

4

Skagit River

C and I

18 C

0.100

8

31
26 C

40.6

4

Duwamish River

C and I

18 C

0.102

8

341
31 C

57.2

3

Nisqually River

C and I

12 C

0.085

9

11
19 C

41.9

4

Deschutes River

C and I

12 C

0.108

7

121
22 C

60.4

3

Marine Fisheries

Central Sound

C

22

0.074

11

18

75.7

2

Apple Cove Pt.

C

12

0.062

13

12

90.8

2

Central Sound

C

4

0.070

11

0

NA

NA

Sinclair Inlet

c

6

0.099

8

6

45.5

4

South Sound

c

6

0.113

7

16

70.6

2

Budd Inlet

c

0

NA

NA

10

55.5

3

South Sound

c

6

0.113

7

6

95.7

2

NOTE: Meal = eight ounces
N = sample size

Type: I = individual sample, C = composite sample
NA = Not available

Shtdjng = Total sample size, mean, and meals/month for all marine fishery stations in Central and South Sound.

Page 15

122

OU 01 Attachment 5

-------
ATTACHMENT KK-3. Summary of PCBs and mercury in fish tissue from Puget Sound (Source: DOH 2006)

Table 3. (cont.) Summary of mercury (ppm, wet weight) and PCBs (ppb, wet weight) measured
in four species of rockfish, English sole, Chinook salmon and coho salmon from Puget Sound.



Mercury

Total
PCBs (Aroc

ors)a

Total PCBs (Aroclor
Equivalent)b

n

Range (ppm)

Mean

(ppm)

n

Range
(ppb)

Mean
(ppb)

n

Range
(ppb)

Mean (ppb)

ENGLISH SOLE

577

0.017-0.14

0.060

434

2-462

38.6

169

4-214

46.6

Urban

256

0.023-0.140

0.072

191

6-462

73.6

82

12-214

74.1

Near-urban

81

0.020-0.118

0.053

57

3-76

17.2

27

13-96

36.2

Non-urban

240

0.017-0.130

0.051

186

2-52

9.3

60

4-39

13.7

SALMON



















Chinook



















All of Puget
Sound

106

0.051-0.160

0.093

210

11-223

54.0

NA

NA

NA

In-riverc

78

0.058-0.160

0.096

176

11-223

50.2

NA

NA

NA

Marined

28

0.051-0.130

0.082

34

21-212

73.2

NA

NA

NA

Central Sound

22

0.051-0.120

0.074

18

21-170

75.6

NA

NA

NA

South Sound

6

0.092-0.130

0.113

16

24-212

70.6

NA

NA

NA

Coho



















All of Puget
Sound

225

0.008-0.110

0.039

221

5-126

31.8

224

16-106

35.5

In-riverc

183

0.008-0.110

0.038

175

5-98

31.1

139

17-82

34.6

Marined

32

0.028-0.071

0.051

46

8-126

34.4

42

21-106

42.1

Minter Creek and
Wallace River
Hatcherv

10

0.020-0.043

0.029

NA

NA

NA

43

16-106

32.1

Central Sound

26

0.028-0.069

0.049

20

8-61

18.3

10

30-59

46.8

South Sound

6

0.045-0.071

0.057

26

18-126

46.8

32

21-106

40.6

Note: Means reflect equal weighting of individual and composite samples.
a Sum of Aroclors 1248, 1254, and f260.

b Approximation of equivalent Aroclor concentration from HPLC data.

0 "tn-river" refers to nearshore areas near rivers and river mouths from which salmon most likely originated.
d "Marine" refers to offshore areas where the origins of salmon are unknown.

Estimating Exposure to Contaminants in Puget Sound Fish

Fish Consumption Rates

Numerous Puget Sound human seafood consumption surveys have been conducted.
Consumption surveys that ask how much fish is being eaten, how often, and which species are
being consumed can be used to estimate exposure rates from eating contaminated fish. DOH
considered four regional seafood consumption surveys for Puget Sound. Members of the
Suquamish Indian Tribe (Suquamish 2000) and the Tulalip and Squaxin Island Tribes (Toy et al.
1996) were interviewed in two separate studies to estimate Puget Sound Native American
consumption rates. A survey of the Asian Pacific Islander (API) community was conducted by
EPA (EPA 1999b) to estimate consumption rates. Recreational anglers from four Puget Sound
areas were surveyed in two studies by NOAA (Landolt et al. 1985, 1987).

Page 16

38

OU 01 Attachment 5

-------
ATTACHMENT KK-4. English Sole Tissue Data in Hylebos Waterway

EMAP-WA00-0041 (Hylebos Waterway) English sole Tissue Data, July 2000.

Studv ID

Location ID

Studv Location
Name

Field Activity
Start Date

Sample
Matrix

Sample Source
- English sole

Result Parameter
Name

Result Reported
Value

Result Data
Qualifier

Result
Measurement
Basis Code

Result
Value
UOM

Result Method
Code

EMAP 1999-2002

EMAP-WA00-0041

WA00-0041

7/19/2000

Tissue

Animal Tissue

Fish Total Length.
Mean of Individuals
in Composite
Sample

224





mm

WESLENGTH

EMAP 1999-2002

EMAP-WA00-0041

WA00-0041

7/19/2000

Tissue

Animal Tissue

Fish Weight, Mean

of Individuals in
Composite Sample

109





£

WESWEIGHT

EMAP 1999-2002

EMAP-WA00-0041

WA00-0041

7/19/2000

Tissue

Animal Tissue

Fish, Number in
Composite Sample

7





count

COUNT

EMAP 1999-2002

EMAP-WA00-0041

WA00-0041

7/19/2000

Tissue

Animal Tissue

PCB-008

0.6

U

WET

ng/g

SW8082

EMAP 1999-2002

EMAP-WA00-0041

WA00-0041

7/19/2000

Tissue

Animal Tissue

PCB-018

0.36

U

WET

ng/g

SW8082

EMAP 1999-2002

EMAP-WA00-0041

WA00-0041

7/19/2000

Tissue

Animal Tissue

PCB-028

9.2



WET

ng/g

SW8082

EMAP 1999-2002

EMAP-WA00-0041

WA00-0041

7/19/2000

Tissue

Animal Tissue

PCB-044

6.1



WET

ng/g

SW8082

Page 1















OU 01 Attachment 5

-------
ATTACHMENT KK-4. English Sole Tissue Data in Hylebos Waterway

EMAP 1999-2002

EMAP-WA00-0041

WA00-0041

7/19/2000

Tissue

Animal Tissue

PCB-052

XL



WET

ng/g

SW8082

EMAP 1999-2002

EMAP-WA00-0041

WA00-0041

7/19/2000



Animal Tissue

PCB-066

0.19

u

WET

ng/g

SW8082

EMAP 1999-2002

EMAP-WA00-0041

WA00-0041

7/19/2000

Tissue

Animal Tissue

PCB-077

0.86

U

WET

ng/g

SW8082

EMAP 1999-2002

EMAP-WA00-0041

WA00-0041

7/19/2000

Tissue

Animal Tissue

PCB-077/110

36



WET

ng/g

SW8082

EMAP 1999-2002

EMAP-WA00-0041

WA00-0041

7/19/2000

Tissue

Animal Tissue

PCB-101

56



WET

ng/g

SW8082

EMAP 1999-2002

EMAP-WA00-0041

WA00-0041

7/19/2000

Tissue

Animal Tissue

PCB-105

16



WET

ng/g

SW8082

EMAP 1999-2002

EMAP-WA00-0041

WA00-0041

7/19/2000

Tissue

Animal Tissue

PCB-118

42



WET

ng/g

SW8082

EMAP 1999-2002

EMAP-WA00-0041

WA00-0041

7/19/2000

Tissue

Animal Tissue

PCB-126

0.8

U

WET

ng/g

SW8082

EMAP 1999-2002

EMAP-WA00-0041

WA00-0041

7/19/2000

Tissue

Animal Tissue

PCB-128

10



WET

ng/g

SW8082

EMAP 1999-2002	EMAP-WA00-0041	WA00-0041 7/19/2000	Tissue Animal Tissue	PCB-138	60	WET	ng/g	SW8082

Page 2

OU 01 Attachment 5

-------
ATTACHMENT KK-4. English Sole Tissue Data in Hylebos Waterway

EMAP 1999-2002	EMAP-WAQQ-0041	WAQQ-0041 7/19/2000	Tissue Animal Tissue

EMAP1999-2002	EMAP-WAQQ-0041	WA00-0041 7/19/2000	Tissue Animal Tissue

EMAP 1999-2002	EMAP-WA00-0041	WA00-0041 7/19/2000	Tissue Animal Tissue

EMAP 1999-2002	EMAP-WA00-0041	WA00-0041 7/19/2000	Tissue Animal Tissue

EMAP 1999-2002	EMAP-WA00-0041	WA00-0041 7/19/2000	Tissue Animal Tissue

P 1999-2002	EMAP-WA00-0041	WA00-0041 7/19/2000	Tissue Animal Tissue

EMAP 1999-2002	EMAP-WA00-0041	WA00-0041 7/19/2000	Tissue Animal Tissue

Page 3

PCB-153

83

WET	ng/g	SW8082

PCB-180

30

WET	ng/g	SW8082

PCB-187

35

WET	ng/g	SW8082

PCB-189	14

WET	ng/g	SW8082

PCB-195

2.2

WET	ng/g	SW8082

PCB-206

WET	ng/g	SW8082

PCB-209	M

WET	ng/g	SW8082

OU 01 Attachment 5

-------
ATTACHMENT KK-4. English Sole Tissue Data in Hylebos Waterway
Attachment KK-4, continued. EMAP Station location in Hylebos Waterway, July 2000 English sole tissue data.

iO GIS Map Viewer - Windows Internet Explorer

, ~ Iff . https://fortress,wa.gov/ecv/eimgisvie,Aier/default.aspx?res=1024x3 l9&str5essionID=44137 jQO i_25appmode=eimr&porting&T ype- Hl| || State of Washington [US] j^jj X j Google

JnJxJ

= m

File Edit View Favorites Tools Help
•^Convert *¦ (^Select

Favorites ggU I ^ GIS Map Viewer

-Detail - EIM Database Sear... GIS Map Viewer

Map Viewer

:'-r ' El • ' esn ' Page - Safety - Tools • «»

Environmental Information Management

Go Back Search Ell

Fitter None Jd Tools a | O

Active:

Map Search Q Layers Q

p_j View data tor

selected locations

Count: 1

1 EMAP-WA00-0041

EIM Database Search 2011 Data Disclaimer Privacy Notice

±1

4 * | <*125% - ^

Page 4

OU 01 Attachment 5

-------
ATTACHMENT KK-5. Final Meeting Notes for 6-30-2012 Discussion on PCBs in Fish Tissue

Attachment KK-5, Godtfredsen 2012.

Godtfredsen, K., S. McGroddy, J. West, L. Kissinger, E. Hoffman, and D. Hotchkiss. 2012.
Technical Memorandum: 6/20/12 Meeting Notes: PCB Analysis in Tissue. Final text revised by
consensus on 12/5/12.

Page 1

OU 01 Attachment 5

-------
ATTACHMENT KK-5. Final Meeting Notes for 6-30-2012 Discussion on PCBs in Fish Tissue

Meeting Notes: PCB Analysis in Fish Tissue

Final text revised by consensus on 12/5/12.

Attendees: Kathy Godtfredsen, Susan McGroddy, Jim West, Lon Kissinger, Erika Hoffman, Doug
Hotchkiss

Progression of PCB Analysis in PSAMP Fish. Sam] tgram

1990 to 1997/8 - PSAMP used Aroclor analysis with GC/ECD at King County Environmental Lab (KCEL)
using manual quantitation.

1995 - Aroclors analyzed by King County laboratory using automated quantitation.

PSAMP 1997/8 to 2004 - Switched to using an HPLC/PDA "screening method" of PCB congener analysis,
which quantified 15 congeners. Sum of identified congener data + "area under the curve for unidentified
PCB congeners" was used to estimate total PCB concentration. James West notes that it was later
determined that this method underestimated Sum209Congener PCBs (see below).

1997/98 - Conducted a comparison study during the switch to congener-based methods. Ninety-three
samples were run to generate an Aroclor-to-HPLC/PDA conversion model. Using linear regression the
HPLC/PDA method for Total PCBs underestimated the sum of Aroclors (calculated as the sum of two
routinely detected Aroclors, 1254 and 1260) by 70% (i.e., HPLC-PDA totals were 30% of the Sum of
Aroclors).

1997-2002 - Used manual solvent extraction methods for HPLC/PDA.

2003/4 - Switched to Accelerated Solvent Extraction (ASE). Many pre-2003 samples were run
retrospectively using HPLC/PDA with ASE. Thirty-six samples were run by both methods to evaluate bias
and generate a correction factor. In later years, chemists suspected interferences from PBDEs, so the
screening method was dropped in favor of a more traditional GC/MS approach.

2004 to present - Switched to a 40-congener low resolution GC/MS congener analysis with ASE.

Selection of the 40 congeners was based on those most frequently detected in Puget Sound tissues.

• Congeners 126 and 169, which co-elute and have a low concentration, were not included.

• Low resolution method has a higher LOQ (500 pptr range) and fewer standards than high
resolution.

• The low resolution method is inadequate for TEQ-based human health risk assessment because
critical TEQ congeners were not analyzed. DOH used PSAMP Aroclor and HPLC/PDA total PCB
data for their human health risk assessment of salmon, rockfish, and English sole. They will use
PSAMP GC/MS LowRes data to run similar human health risk assessments for crab and shrimp in
2012/3.

• PSAMP adopted NOAA's "2xSuml8 Congeners" as one estimate of total PCB concentration, in
addition to the "Sum of 40 Congeners."

2004 - PSAMP compared total PCB estimates from congener-based monitoring methods with Hi
Resolution GC/MS "Sum 209 Congener" (HiRes) methods, assuming the latter provides the most
accurate quantitation for total PCBs. PSAMP ran 28 samples using HPLC-PDA (ASE) against GC/MS

Page 2

OU 01 Attachment 5

-------
ATTACHMENT KK-5. Final Meeting Notes for 6-30-2012 Discussion on PCBs in Fish Tissue

HighRes and 5 samples by 40-congener GC/MS LowRes against GC/MS HiRes; comparison was
conducted using a number of different species to cover a wide range of lipids.

• Sum 40 congeners by GC/MS under-predicted Sum209Congeners by 34%.

• HPLC/PDA/ASE under-predicted Sum209Congeners by 28%.

• 2xSuml8 Congeners was equivalent to Sum209Congeners (slope=0.991).

LDWG also ran sample splits of 6 PSAMP GC/MS LowRes samples of English sole fillet at Axys for HighRes
and Aroclor analysis at ARI (see Table 1 for results).

• Calculating NOAA's 2xSuml8 using PSAMP's and LDWG's GC/MS HighRes results gives good
estimate of HiRes Sum209Congeners.

• Conclusion: 2xSuml8Congeners is a good proxy for Sum209Congeners.

Other PSAMP comparisons are consistent with these results: The total PCB estimate generated by the
HPLC/PDA method (i.e., sum of 15 congeners plus unidentified congeners) under predicted the sum
2x18 congeners by approximately 27% (ASE) and 33% (NoASE).

2007 - PSAMP revisited the Aroclor question; they compared GC/MS results with Aroclor-based results
by running archived samples collected in the early 2000s by both methods simultaneously. The Aroclor
samples were run by KCEL using their current (2007) protocols and it is unclear how those protocols
differed from the 1990s (if at all). At a minimum, extraction methods were different - ASE was used in
2007 but not in previous years. No consistent relationship was found to predict one from the other
from this comparison effort.

2009 - A study with 40 samples (with a range of species) was done by LDWG in which samples were
analyzed by high res GC/MS and also by the King County lab using prior Aroclor-based methods. Erika
Hoffman indicated that the analytical methods were detailed in a March 5, 2009 report ("Chemical
Analyses of Fish, Crab, and Clam tissue samples and co-located sediment samples collected in 2007"),
and that PCB congeners were analyzed by Axys using HRGC/HRMS EPA 1886 and PCB Aroclors were
analyzed by ARI using GC/ECD EPA 8082. Highly variable results were found, lending further uncertainty
to the 1990s Aroclor results.

2011 - English sole were sampled by PSAMP near Kellogg Island and in 2007, '09, and '11 found to have
an average total PCB concentration of 286, 314, and 274 ng/g wet wt based on GC/MS
2xSuml8Congeners.

Table 1 shows the list of PCB congeners used in the three summation procedures by PSAMP.

Bottom Li 1 is in PSA sh Sampling Program

Jim strongly recommends caution in using Aroclors to estimate total PCBs from the pre-1997 Aroclor
analysis for trends.

Susie recommended including Aroclor data on Vital Sign plots, but omitting them from the trend
analysis.

Jim is working on a report that will document all the PSAMP PCB methods changes, and the implications
of these changes on evaluating long-term time trends.

Page 3

OU 01 Attachment 5

-------
ATTACHMENT KK-5. Final Meeting Notes for 6-30-2012 Discussion on PCBs in Fish Tissue

Lacking is a comparison of the 2xSuml8Congeners summation method with Sum209Congeners, for all
samples that have ever been run on the latter. That is, pull out the 18 congeners from the HiRes
analysis, sum them, multiply by two and compare with the sum of all congeners from the HiRes analysis.

The East Waterway data had a decent relationship between high res total PCBs and Aroclor-based totals
in all fish/crab tissue. Overall, concentrations were much higher in the EWW than in the LDW
(concentrations ranged from approximately 700 to 3,000 ppb ww vs. < 500 ppb in fish collected by
PSAMP near Kellogg Island). Aroclor analyses generally resulted in overestimates of total PCB
concentrations in EWW samples.

It should be noted that English sole samples were replicate "super composite samples" created by
combining all the composites together. The PCB Aroclor results were much more variable than the PCB
congener results in English sole fillets. Overall, the two methods gave comparable results.

East Waterway ]	i

7,000 t

0 1,000 2,000 3,000 4,000 5,000 6,000 7,000
Total PCBs (sum of Aroclors) (|jg/kg ww)

~ Brown rockfish (whole body)

English sole (whole body)

~ Shiner surf perch (whole body)

English sole (fillet)

Crab (hepatopancreas)

1:1 line

Page 4

OU 01 Attachment 5

-------
ATTACHMENT KK-5. Final Meeting Notes for 6-30-2012 Discussion on PCBs in Fish Tissue

Lower Duwamish Waterway Data (2007)

Six PSAMP English sole fillet (without skin) samples were shared with the LDW group in 2007. These
samples were analyzed for PCB congeners (Axys) and Aroclors (ARI). The sum of PCB Aroclors was
consistently lower than the sum of 209 PCB congeners (Table 1).

Table 1. Comparison of total PCBs as sum of 209 PCB congeners and PCB
Aroclors for six PSAMP split samples



Total PCBs (|jg/kg ww)

Sample

Sum of
209 PCB congeners

Sum of
PCB Aroclors

2xSum18
Method
(NOAA)

07DU-ESM01

315.4

128

315

07DU-ESM02

279.9

115

221

07DU-ESM03

316.0

148

324

07DU-ESM04

396.0

136

396

07DU-ESM05

307.2

121

236

07DU-ESM06

262.0

92

227

The PSAMP total PCB values calculated using the NOAA 2xSuml8 method on LoRes GC/MS data from
these samples collected in 2007 are shown above. These results are more consistent with the Sum 209
congener totals than the Sum Aroclors. Other PCB tissue data from the LDW Rl are presented below
(using Table 4-33 and Figure 4-12 as numbered from the Rl, for ease of reference). Table 4-33 provides
the total PCB data that are graphed in Figure 4-12.

Table 4-33. Total PCB concentrations (sum of PCB congeners) in composite
tissue samples collected from the LDW

2004

2005

2007

Total PCBs
(|jg/kg ww)

Total PCBs
(Hg/kg ww)

Total PCBs
(Hg/kg ww)

Tissue Type

Area1 N Min Max Mean1, n Min Max Mean1, n Min Max Mean1,

Fish. Whole Body

English sole

Shiner surfperch

T1

2

1,614 J

2,481 J (

2,048

1

2,589 J

2,589 J

2,589

2

774 J

1,165 J (

970

T2

2

2,126 J

2,712 J |

2,419



3,214 J

3,214 J

3,214

2

1,603 J

1,632 J

1,618

T3

2

1,419 J

2,457 J |

1,938

1

1,433 J

1,433 J

1,433

2

1,032 J

2,928 J |

1,980

T4

1

1,361 J

1,361 J

1,361

0



no data



0



no data



T1

2

700.1 J

876.6 J

788.4



683.1 J

683.1 J

683.1

2

504.1 J

974 J

739

T2

2

1,055 J

12,228

J I

6,642

h

1,047 J

1,047 J

1,047

2

401.6 J

648.3 J |

525.0

T3

3

1,009 J

8,010 J

4,180

b

2,048 J

2,048 J

2,048

2

1,103 J

2,462 J

1,783

T4

2

532.4 J

770 J

651

0



no data



0



no data



Page 5

OU 01 Attachment 5

-------
ATTACHMENT KK-5. Final Meeting Notes for 6-30-2012 Discussion on PCBs in Fish Tissue

2004	2005	2007

Total PCBs	Total PCBs	Total PCBs

(|jg/kg ww)	(HQ/kg ww)	(|jg/kg ww)

Tissue Type

Area'

T1

N

2

Min

532.4 J

Max

668.4 J

Mean"

600.4

n

Min Max

Mean1, n

Min

Max

Mean1,

Pacific staghorn sculpin

T2
T3
T4

2
2
2

481.6 J
1,048 J
349.6 J

496.3 J
1,907 J
504.9 J

489.0
1,478
427.3

i°|

no data

|°



no data



Starry flounder

T4

1

458 J

458 J

458

0

no data

0



no data



Fish, Fillet

























T1

2

857.5 J

1,119.2
J

988.4













English sole (with skin)

T2

T3
T4

2

2
1

1,264.6
J

641.1 J
510 J

1,269 J

1,022.9
J

510 J

1,266.8

832
510

•o|

no data

0



no data



Starry flounder (with skin)

T4

1

295.2 J

295.2 J

295.2

0

no data

0



no data



Pile perch (with skin)

T3

1

192.2 J

192.2 J

192.2

0

no data

0



no data



Striped perch
(with skin)

RM 4.0-
RM 4.1



442.3 J

442.3 J

442.3

0

no data

1°



no data



Crab, Edible Meat

























T1

1

111 J

111 J

111





1

49.45 J

49.45 J

49.45

Dungeness crab

T3

#1

149.3 J

149.3 J

149.3

0

no data

1

86.2 J

86.2 J

86.2



T4

1

148.7 J

148.7 J

148.7





0



no data





T1

2

174.7 J

186.5 J

180.6





1

112 J

112 J

112

Slender
crab

T2

2

129.7 J

180.6 J

155.2

0

no data

1

86.2 J

86.2 J

86.2



T3

h

134.3 J

134.3 J

134.3





0



no data



Crab, Hepatopancreas

























T1

0



no data







1

612.1 J

612.1 J

612.1 J

Dungeness crab

T3
T4

#1

1

3,622 J
3,618 J

3,622 J
3,618 J

3,622
3,618

101

no data

0



no data



Slender crab

T1
T2

1
1

790.1 J
1,047 J

790.1 J
1,047 J

790.1
1,047

0

no data

to



no data



Crab, Whole Body (calc'd)c

























T1

0



no data







iii

223.9
JM

223.9
JM

223.9

Dungeness crab

T3

1

1,226
JM

1,226
JM

1,226

:o|

no data











T4

1

1,224
JM

1,224
JM

1,224





0



no data



Page 6

OU 01 Attachment 5

-------
ATTACHMENT KK-5. Final Meeting Notes for 6-30-2012 Discussion on PCBs in Fish Tissue

2004

2005

2007

Tissue Type

Total PCBs
(Hg/kg ww)

Area' N Min Max Mean1, n Min Max Mean1, n Min Max Mean1,

Slender crab

Invertebrates, Whole Body

T1
T2

Benthic Invertebrates
Shellfish

LDW-
wide d

Clams, non-depurated

LDW-
wide6

! 365.5 ! 373.6
JM I JM |

i 414.06] 449.18 !
I JM I JM |

369.6

431.62

32.13 | 1,346

393.5

no data

|8 I

141.05 J

930 J

no data

|0l

no data

a Tissue sampling areas are shown on Maps 4-9 and 4-10.

b Mean concentration is the average of detected concentrations. There were no undetected results for total PCBs (as sum of
PCB congeners).

0 Data from composite hepatopancreas samples were mathematically combined with data from composite samples of edible
meat to form composite samples of edible meat plus hepatopancreas. Total PCB concentrations in whole-body (i.e., edible
meat plus hepatopancreas) crab were calculated assuming 69% (by weight) edible meat and 31% hepatopancreas, based on
the relative weights of these tissues in a 16.6-cm Dungeness crab dissected by Windward in 2004 (unpublished data).

d Benthic invertebrate and clam samples were collected throughout the LDW (Map 4-10).

J - estimated concentration n - number of samples

JM - calculated from an estimated concentration
LDW - Lower Duwamish Waterway
M - calculated concentration

PCB - polychlorinated biphenyl
RM - river mile
ww - wet weight

Page 7

OU 01 Attachment 5

-------
ATTACHMENT KK-5. Final Meeting Notes for 6-30-2012 Discussion on PCBs in Fish Tissue

Total PCBs (sum of Aroclors) (ng/kg ww)

Figure 4-12. Total PCB concentration (sum of PCB congeners) compared with
total PCB concentrations (sum of Aroclors) in fish and crab tissue
samples

Dashboard Indicator Recovery Targets

Discussed concerns with use of Meador's tissue threshold for effects in juvenile salmonids. As an
alternative, discussed presenting percentiles of TRVs for comparisons to raw data.

Given uncertainties in trend data for pre-1997 (see above), Jim will assign "yellow" indicator
(indeterminate for trend) to Elliott Bay/LDW area (PSAMP's "Duwamish" station).

PSP's Leadership Council wants Vital Sign to use scientifically sound effects thresholds as recovery
targets. Jim will pursue these but many are unavailable or contentious. Other reference values will be
included in Vital Sign to put recovery targets in context, including "background" or "screening values."
These could be "clicked on or off" by the user.

Could consider DOH thresholds (generally <10 ppb PCBs - no advisory; 10-100 ppb advisory; >100 ppb
PCBs "bad") - based on noncancer endpoints. Would need to research a bit more.

Recent advisory levels for PCBs (and other contaminants) developed by California EPA may be pertinent
here. Suggest this team review their work on Advisory Tissue Levels (ATLs) and Fish Contaminant Goals
(FCGs):

Page 8

OU 01 Attachment 5

-------
ATTACHMENT KK-5. Final Meeting Notes for 6-30-2012 Discussion on PCBs in Fish Tissue

Klasing, S. and R. Brodberg (2008). Development of fish contaminant goals and advisory tissue
levels for common contaminants in California sport fish: chlordane, DDTs, dieldrin,
methylmercury, PCBs, selenium, and toxaphene, Pesticide and Environmental Toxicology
Branch, Office of Environmental Health Hazard Assessment
California Environmental Protection Agency: 122.

www.oehha.ca.gov/fish/gtlsv/pdf/FCGsATLs27June2008.pdf

Page 9

OU 01 Attachment 5

-------
ATTACHMENT KK-5. Final Meeting Notes for 6-30-2012 Discussion on PCBs in Fish Tissue

Tallies

Table 1. List of PCB congeners used in three summation procedures by PSAMP, as compiled by Jim West 12/4/2012.



NWFSC GC/MS Low Resolution

NWFSC H PLC/PDA

NOAA 2x18 (MusselWatch)



Sum of 40 quantitated congeners

Sum of 15 identified
congeners plus area under
the curve for unidentified
PCBs

"Two times the sum of 18 congeners"
quantitated by any method



PCB017







PCB018



PCB018



PCB028



PCB028



PCB031







PCB033







PCB044



PCB044



PCB049







PCB052



PCB052



PCB066







PCB070







PCB074









PCB077





PCB082







PCB087







PCB095



PCB095



PCB099







PCB101/90

PCB101

PCB101



PCB105

PCB105

PCB105



PCB110

PCB110





PCB118

PCB118

PCB118





PCB126





PCB128

PCB128

PCB128



PCB138/163/164

PCB138

PCB138



PCB149







PCB151







PCB153/132

PCB153

PCB153



PCB156

PCB156



Page 10

OU 01 Attachment 5

-------
ATTACHMENT KK-5. Final Meeting Notes for 6-30-2012 Discussion on PCBs in Fish Tissue





PCB157





PCB158









PCB169





PCB170

PCB170/194

PCB170



PCB171







PCB177







PCB180

PCB180

PCB180



PCB183







PCB187/159/182



PCB187





PCB189





PCB191







PCB194







PCB195



PCB195



PCB199







PCB205







PCB206



PCB206



PCB208







PCB209



PCB209

TOTAL

40

15

17

Incl.

Coeluters

46

16

*
00

T—1

*Jim West (WDFW) will check the NOAA reference to clarify which of these coelutes to yield n=18.

Page 11

OU 01 Attachment 5

-------
ATTACHMENT KK-6. Historical Fish Data, Pacific Staghorn, NOAA 2003

Attachment KK-6. Historical Fish Data - Pacific Staghorn - NOAA 2003. From Ecology EIM database
(accessed 10-24-12).

Page 1

OU 01 Attachment 5

-------
ATTACHMENT KK-6. Historical Fish Data, Pacific Staghorn, NOAA 2003

GIS Map Viewer - Windows Internet Explorer

.JsJxJ

fl : https;//for tress, wa,gov/eo/.'eirTigisviewer/default, 3SDX?res= 1024x819&strSessonID=1013Q62222_ll&appmode=e)mreporting3LType=St J

File Edit View Favorites Tools Help
^Convert ' C?Select

; Favorites

GIS Map Viewer

i i

" 0 ' ED SSS " Page - Safety - Tools» '

ment of

I Map Viewer

1
[

y

Environmental Information Management J

Go Back Search EIM

EIM Database Search 2011 Data Disclaimer Privacy Notice	vl

il	I

"I® Internet | Protected Mode: On

Filter | None zi

p View data lor

selected locations

Count: 2
+.yr

1	NOAACBRM.l

2	IMOAACBRM.3

Page 2

OU 01 Attachment 5

-------
ATTACHMENT KK-6. Historical Fish Data, Pacific Staghorn, NOAA 2003

Studv ID

Location ID

Studv Location Name

Field Activitv

SamDle

SamDle Source-

Result

Result

Result

Result







Start Date

Matrix

Pacific staehorn

Parameter

Resorted

Measurement

Value













Name

Value

Basis Code

UOM

NOAACBRM

NOAACBRM.1

Middle Waterway

6/9/2003

Tissue

Animal Tissue

PCB

100

WET

ng/g

NOAACBRM

NOAACBRM.1

Middle Waterway

6/9/2003

Tissue

Animal Tissue

PCB

45

WET

n g/g

NOAACBRM

NOAACBRM.3

Olympic View

6/9/2003

Tissue

Animal Tissue

PCB

110

WET

ng/g

NOAACBRM

NOAACBRM.3

Olympic View

6/9/2003

Tissue

Animal Tissue

PCB

130

WET

ng/g

NOAACBRM

NOAACBRM.1

Middle Waterway

6/9/2003

Tissue

Animal Tissue

PCB

43

WET

ng/g

NOAACBRM

NOAACBRM.3

Olympic View

6/9/2003

Tissue

Animal Tissue

PCB

59

WET

ng/g

NOAACBRM

NOAACBRM.3

Olympic View

7/9/2003

Tissue

Animal Tissue

PCB

100

WET

ng/g

NOAACBRM

NOAACBRM.1

Middle Waterway

8/9/2003

Tissue

Animal Tissue

PCB

140

WET

ng/g

Page 3

OU 01 Attachment 5

-------
ATTACHMENT KK-7. PSAMP English sole station locations and data.

Location of PSAMP Baseline Station in Thea Foss Waterway where English sole were collected
in April/ May in 2005, 2007, 2009, and 2011.

Browns Point

~ j

Ruston

Old Tacoma

N.E.

- Commencement Bay

Thea Foss
Waterway

'¦•a



U

O Baseline Stations
~ Focus Stations

Commencement Bay, Tacoma,
Washington

Source: http://wdfw.wa.gov/conservation/research/proiects/marine toxics/graphics/cb-sole-map.ipg

Page 1

OU 01 Attachment 5

-------
ATTACHMENT KK-7. PSAMP English sole station locations and data.

SamplelD

Species

Year

StationID

LatNum

LongNum

Matrix

Comp
ositeN

nMale

nFem

nUnk

MFUnkRatio

Mean
Composite
Length
(Fork
Length,
mm)

Mean
Composite Age
(years)

GravimetricLipids
{%)

SumPCBs

2x17
(ng/gwet)

SumPCBs40
Congeners
(ng/gwet)

Mean and
Range

05CB-ESM01

ENGLISH

2005

Thea Foss

47.2594559

-122.4361766

muscle

20

14

6



14:6:0

268.5

5.5

0.394124535

84.82

66

75 +/- 8

05CB-ESM02

ENGLISH

2005

Thea Foss

47.2594559

-122.4361766

muscle

20

14

6



14:6:0

260.55

5.8

0.427886379

87.54

69

66to83

05CB-ESM03

ENGLISH

2005

Thea Foss

47.2594559

-122.4361766

muscle

20

12

8



12:8:0

274

6.35

0.311222339

90.86

69



05CB-ESM04

ENGLISH

2005

Thea Foss

47.2594559

-122.4361766

muscle

20

6

4

10

6:4:10

258.25

5.3

0.427550028

110.22

85



05CB-ESM05

ENGLISH

2005

Thea Foss

47.2594559

-122.4361766

muscle

20

15

5



15:5:0

253.65

5.75

0.397348976

100.38

77



05CB-ESM06

ENGLISH

2005

Thea Foss

47.2594559

-122.4361766

muscle

19

12

2

5

12:2:5

249.10526

6.052631579

0.455935109

104.3

83



07CB-ESM01

ENGLISH

2007

Thea Foss

47.2594559

-122.4361766

muscle

20

13

7



13:7:0

265.15

6.93

0.223731809

69.18

53

40 +/- 9

07CB-ESM02

ENGLISH

2007

Thea Foss

47.2594559

-122.4361766

muscle

20

7

13



7:13:0

269.25

6.1

0.200551533

49.58

38

28to53

07CB-ESM03

ENGLISH

2007

Thea Foss

47.2594559

-122.4361766

muscle

20

9

11



9:11:0

264.95

6.47

0.235373033

58.24

45



07CB-ESM04

ENGLISH

2007

Thea Foss

47.2594559

-122.4361766

muscle

20

11

9



11:9:0

242.85

5.8

0.266469727

41.04

32



07CB-ESM05

ENGLISH

2007

Thea Foss

47.2594559

-122.4361766

muscle

20

9

11



9:11:0

251.25

5.7

0.164638482

39.6

28



07CB-ESM06

ENGLISH

2007

Thea Foss

47.2594559

-122.4361766

muscle

20

9

11



9:11:0

254.2

6.6

0.261432205

54.78

43



09CB-ESM01

ENGLISH

2009

Thea Foss

47.2594559

-122.4361766

muscle

20

10

10



10:10:0

275.4

6.5

0.177982135

91.52

67

85 +/- 26

09CB-ESM02

ENGLISH

2009

Thea Foss

47.2594559

-122.4361766

muscle

20

12

8



12:8:0

266.45

6.25

0.210885491

174.32

130

62to130

09CB-ESM03

ENGLISH

2009

Thea Foss

47.2594559

-122.4361766

muscle

20

14

6



14:6:0

271.85

7.45

0.127508613

98.68

73



09CB-ESM04

ENGLISH

2009

Thea Foss

47.2594559

-122.4361766

muscle

20

16

4



16:4:0

255.8

6.2

0.146260352

103.88

76



09CB-ESM05

ENGLISH

2009

Thea Foss

47.2594559

-122.4361766

muscle

20

12

8



12:8:0

249.3

5.5

0.18694131

134.6

99



09CB-ESM06

ENGLISH

2009

Thea Foss

47.2594559

-122.4361766

muscle

20

11

9



11:9:0

257.6

6.05

0.1365926

83.78

62



11CB-ESM01

ENGLISH

2011

Thea Foss

47.2594559

-122.4361766

muscle

20

10

8

2

10:8:2

265



0.270899147

95

71

71to92

11CB-ESM02

ENGLISH

2011

Thea Foss

47.2594559

-122.4361766

muscle

20

10

10

0

10:10:0

290.2





120

92



Page 2

OU 01 Attachment 5

-------
ATTACHMENT KK-8. Non-Urban Puget Sound Tissue Dataset

£ower /7uwamish f^aterway {7 roup

Port of Seattle / City of Seattle / King County / The Boeing Company

Appendix B

Updated Beach Play Risk Estimates,
Species-Specific RBTC Calculations, and the

Puget Sound Tissue Dataset

Final Feasibility Study

Lower Duwamish Waterway
Seattle, Washington

FOR SUBMITTAL TO:

The U.S. Environmental Protection Agency
Region 10

Seattle, IV A

The Washington State Department of Ecology
Northwest Regional Office

Bellevue, WA

October 31,2012

Prepared by: AZCOM

710 Second Avenue, Suite 1000 ~ Seattle, Washington ~ 98104

Windward

VV liiy{nvironmenta|LLC

200 W Mercer St # 401 ~ Seattle, Washington ~ 98119

Page 1

OU 01 Attachment 5

-------
ATTACHMENT KK-8. Non-Urban Puget Sound Tissue Dataset

Appendix B - Updated Beach Play Risk Estimates,
Species-Specific RBTC Calculations, and the Puget Sound Tissue Dataset

To calculate the clam RBTC, these values are substituted into Equation 3, as
shown in Equation 5.

C

= RBTC RBTC overall x Averageclam 42 x 140 ^

Averageingestionweighted 394	Equation 5

This approach assumes that relative contaminant concentrations among the species
remain the same even when conditions change. This proportionality calculation is then
repeated for the other tissue types that comprise the diet. Different species-to-species
relationships may be calculated if multiple empirical datasets or model outputs are
available, which in turn would result in a range of RBTCs (rather than a single number).
This concept is further explored in Section B.3.2.

B.3.2 Species-Specific RBTCs for Risk Drivers

Following the methodology described in Section B.3.1, species-specific RBTCs were
calculated for the risk drivers identified for the LDW: total PCBs, inorganic arsenic, and
cPAHs (Tables B-5 through B-9). Species-specific RBTCs could not be derived for
dioxins/furans because no site-specific empirical data were available to calculate the
ratios that describe concentration relationships among the species. Data and methods
used to establish the species-specific RBTCs for each risk driver are summarized below.

Species-specific RBTCs for total PCBs were developed based on three sources of species-
to-species relationship information: 1) the LDW HHRA empirical dataset (as in the
example in Section B.3.1), 2) the LDW 2007 empirical dataset, and 3) the calibrated
FWM. Because the calibrated FWM predicts concentrations for each species in the
scenario-specific diets, it can also be used to estimate the concentration relationships
among the different species. Because the relationships were similar, but not exactly the
same based on the three sources of information, a range of species-specific RBTCs were
developed for each RME seafood consumption scenario/risk level combination for total
PCBs, as presented in Tables B-5 through B-7.

It was not possible to calculate a range of species-specific RBTCs for inorganic arsenic or
cPAHs because the 2007 tissue samples were not analyzed for these contaminants for all
market basket species and because no FWM exists for these risk drivers. Therefore,
species-specific RBTCs for inorganic arsenic and cPAHs are presented as single values.

B.4 Non-Urban Puget Sound Tissue Dataset

To help provide context for tissue RBTCs, a tissue dataset of samples collected from
non-urban areas away from known contaminated sites in Puget Sound was compiled
for each of the four risk drivers (i.e., total PCBs, arsenic, cPAHs, and dioxins/furans).

Section B.4.1 describes the criteria used to develop the non-urban Puget Sound tissue
dataset and provides detailed tables and figures showing the data included in this

£ower ^uwamlsh f^atarway £yroup

fert'Of Seattle/my efSimMiZtOitir Cetmljtf me BoefBgCeimtmmy	Final Feasibility StUffy

Page 2	ou 01 Attachment 5

-------
ATTACHMENT KK-8. Non-Urban Puget Sound Tissue Dataset

Appendix B - Updated Beach Play Risk Estimates,
Species-Specific RBTC Calculations, and the Puget Sound Tissue Dataset

dataset. Section B.4.2 presents human health risk estimates calculated based on the non-
urban Puget Sound tissue dataset.

B.4.1 Dataset Development

The non-urban Puget Sound tissue dataset consists of data from various studies. For
total PCBs and arsenic, the tissue data from some of these studies were presented in the
LDW RI; this RI dataset served as a starting point for these two risk drivers. In addition,
data for all four risk drivers were obtained from Ecology's Environmental Information
Management (EIM) database. It is important to note that the non-urban Puget Sound
dataset has been compiled from various sources, and the datasets from these sources
were generally used as reported without further data quality reviews. In addition, the
sampling and analytical methods used to produce these datasets varied from study to
study. Thus, although these data provide a general indication of the concentrations of
these risk drivers in tissues collected throughout Puget Sound, they should not be
regarded as a single dataset generated using a consistent methodology that is
representative of Puget Sound.

Once the preliminary data had been compiled, criteria for using the data in the non-
urban Puget Sound tissue dataset were determined in consultation with EPA and
Ecology. The following list summarizes the criteria for including data in this dataset:

~	Species: Only those species representative of the consumption categories
evaluated in the LDW HHRA (i.e., benthic fish, pelagic fish, crabs, clams, and
mussels) were included in the dataset. Available data for other species, including
shrimp, oysters, and other fish species (e.g., salmon and rockfish1) were
excluded.

~	Proximity to urban areas: In consultation with EPA and Ecology, sampling
locations near urban areas were excluded from the non-urban Puget Sound
tissue dataset. Examples of excluded areas include: Commencement Bay
(Tacoma), Elliott Bay (Seattle), Budd Inlet (Olympia), Port Gardner (Everett),
Sinclair Inlet (Bremerton), Port Angeles Harbor, and Bellingham Bay.

~	Proximity to known contaminated sources: In consultation with EPA and
Ecology, sampling locations near known contaminant sources were excluded
based on consideration of the type, distance, and magnitude of any known
sources identified in the Integrated Site Information System (ISIS) and EIM

1 Rockfish were not included in the non-urban Puget Sound dataset as a surrogate pelagic species for
two reasons: 1) rockfish were not included in the LDW market basket because "adult rockfish are
likely to constitute a very small component of a seafood consumption scenario because existing data
suggest that adult rockfish abundance is low in the LDW" (Windward 2004), and 2) their long life
spans may contribute to higher contaminant concentrations than in other pelagic fish with shorter life
spans.

£ower ^uwamlsh f^atarway £yroup

fert'Of Seattle/my efSimMiZtOitir Cetmljtf me BoefBgCeimtmmy	Final Feasibility StUffy

Page 3

OU 01 Attachment 5

-------
ATTACHMENT KK-8. Non-Urban Puget Sound Tissue Dataset

Appendix B - Updated Beach Play Risk Estimates,
Species-Specific RBTC Calculations, and the Puget Sound Tissue Dataset

databases. Examples of sampling locations excluded based on proximity to a
known source include the areas of Fidalgo Bay/March Point (near Anacortes),
Point Wells (near Edmonds), Port Washington Narrows (near Bremerton), and
Keyport (near Poulsbo).

~	Inorganic arsenic data quality: For inorganic arsenic, only those data collected as
part of the LDW RI/FS specifically for the purpose of evaluating Puget Sound
tissue concentrations were used in this dataset. This RI/FS dataset was
sufficiently large to meet the goals associated with the non-urban Puget Sound
dataset and had already undergone extensive review and validation, whereas the
analytical methods and the data quality of the relatively small number of
additional available samples analyzed for inorganic arsenic were less well
known.

The resulting non-urban Puget Sound tissue dataset contains different numbers of
samples for the various risk drivers and tissue types, depending on data availability.
Acceptable data are summarized in Tables B-10 through B-13; sampling locations are
shown on Figures B-5 through B-12. In summary, the following numbers of samples
were available for each risk driver (after filtering based on criteria listed above):

~	Total PCBs: 344 tissue samples, including 242 fish samples, 17 crab edible-meat
samples, 15 crab whole-body samples,2 and 70 clam samples;

~	Inorganic arsenic: 81 tissue samples, including 33 fish samples, 12 crab edible-
meat samples, 12 crab whole-body samples, and 24 clam samples;

~	cPAHs: 28 samples, including 1 fish sample, 8 crab edible-meat samples, 7 crab
whole-body samples, 1 mussel sample, and 11 clam samples;

~	Dioxins/furans: 106 samples, including 11 fish samples, 27 crab edible-meat
samples, 25 crab whole-body samples, and 43 clam samples.

Fish sample counts included both benthic fish and pelagic fish (although relatively few
pelagic fish data were available), crab sample counts were divided by tissue type (i.e.,
edible-meat and whole-body samples), and clam sample counts included various clam
species.

B.4.2 Risk Estimates Based on the Non-Urban Puget Sound Tissue Dataset

This section provides risk estimates calculated using the non-urban Puget Sound tissue
dataset. In consultation with EPA, it was agreed that a market basket approach would
be used to more closely approximate the approach taken in the LDW HHRA. However,
because the available non-urban Puget Sound data did not perfectly match all of the

2 Crab whole-body samples for all risk drivers were calculated based on concentrations in edible meat
and hepatopancreas samples, as described in Tables B-10 through B-13.

£ower ^uwamlsh f^atarway £yroup

fert'Of Seattle/my efSimMiZtOitir Cetmljtf me BoefBgCeimtmmy	Final Feasibility StUffy

Page 4

OU 01 Attachment 5

-------
ATTACHMENT KK-8. Non-Urban Puget Sound Tissue Dataset

Appendix B - Updated Beach Play Risk Estimates,
Species-Specific RBTC Calculations, and the Puget Sound Tissue Dataset

seafood consumption categories used in the LDW HHRA, a simplified approach was
used. The following five consumption categories were used to calculate risks based on
the Puget Sound tissue dataset: clams, mussels, crab edible meat, crab whole-body, and
fish (pelagic and benthic fish combined) (Table B-4).

In the LDW HHRA, concentrations of the four risk drivers in seafood were represented
by an upper confidence limit (UCL). This approach was not selected for the non-urban
Puget Sound risk estimates because the compiled dataset represents various studies,
sample sizes, and methods. Instead, risk estimates for the four risk drivers were
calculated based on the minimum, mean, and maximum values for each consumption
category (Table B-14). These values were used to calculate the ingestion-weighted
concentrations that were presented in Figures 3-3 through 3-6 in Section 3 of the FS
(see Section B.3.1 for details on how these values were calculated).

Excess cancer risk estimates (both for the individual risk drivers and as total risk
estimates across all four risk drivers) are shown in Figures B-13 through B-15 and in
Table B-15 for the three RME scenarios. Total excess cancer risks ranged from 1 x 10 5
to 6 x 10 5 using minimum exposure values, from 5 x 10 5 to 3 x 1CH using mean
exposure values, and from 2 x 1CH to 9 x 1CH using maximum exposure values. Total
excess cancer risks were greater than the MTCA threshold of 1 x 10 5 for all scenarios
and exposure values with one exception: the total excess cancer risk for the Child Tribal
RME scenario using the minimum exposure values was 1 x 10 5. Additionally, risk
estimates for the individual risk drivers were compared with MTCA's 1 x 106 excess
cancer risk threshold. For inorganic arsenic and dioxin/furan TEQ, excess cancer risks
were greater than this threshold regardless of the statistic used (i.e., when minimum,
mean, or maximum values were used; Table B-15). For total PCBs and cPAHs, excess
cancer risks were greater than this threshold for all scenarios when maximum values
were used and for some scenarios (i.e., the Adult Tribal RME and/ or Adult API RME
scenarios; see Table B-15) when either the minimum or mean values were used.

As shown in Figures B-13 through B-15, the majority of the total excess cancer risk for
each of the RME scenarios was attributable to inorganic arsenic and dioxins/furans.
The risks associated with inorganic arsenic in the non-urban Puget Sound dataset were
attributable primarily to clams (as was the case in the LDW HHRA). Risks associated
with dioxins/furans were attributable primarily to clams for risks based on the mean
and maximum concentrations but were attributable primarily to fish for risks based on
the minimum concentrations. Risks associated with total PCBs and cPAHs were lower,
together contributing 5% or less to the total excess cancer risk.

For both total PCBs and inorganic arsenic, non-cancer HQs were less than 1 when using
the minimum and mean exposure values. When the maximum exposure values were
used, HQs for the three RME scenarios ranged from 0.6 to 3 (Table B-15). The only HQs
greater than 1 were those calculated using the maximum exposure values for the Child
Tribal RME scenario (the total PCB HQ was equal to 2, and the inorganic arsenic HQ

£ower ^uwamish (Waterway fioup f*$&\

Port of Seattle / City of Seattle /King County / The Boeing Company Final Feasibility Study 1

Page 5 ou 01 Attachment 5

-------
ATTACHMENT KK-8. Non-Urban Puget Sound Tissue Dataset

Appendix B - Updated Beach Play Risk Estimates,
Species-Specific RBTC Calculations, and the Puget Sound Tissue Dataset

was equal to 3). The proportional contributions of the various seafood consumption
categories to the HQs for total PCBs and inorganic arsenic were similar to those to the
excess cancer risks (Figures B-13 through B-15). Thus, clams were the primary
contributor to the inorganic arsenic HQs, while fish were the primary contributor to the
total PCB HQ.

Figures B-16 through B-19 present a comparison of excess cancer risks and non-cancer
HQs estimated for the non-urban Puget Sound tissue dataset and those estimated for
the LDW HHRA tissue dataset for both total PCBs and inorganic arsenic. For both the
non-urban Puget Sound and LDW tissue datasets, the risk estimates shown in these
figures were calculated using mean exposure values. The excess cancer risk estimates
and non-cancer HQs calculated for total PCBs based on the LDW data were
approximately 120 to 200 times higher than those calculated based on the non-urban
Puget Sound dataset. For inorganic arsenic, excess cancer risks and non-cancer HQs
calculated based on the LDW dataset were also higher than those based on the non-
urban Puget Sound dataset; although, unlike PCBs, LDW excess cancer risks and non-
cancer HQs were only approximately 5 times higher than those in non-urban Puget
Sound locations. The majority of risk for inorganic arsenic (in both these datasets) is
attributable to clam consumption. Similar figures were not created for cPAHs because
of low detection frequencies in the non-urban Puget Sound tissue dataset. Similar
figures were not created for dioxins/furans because insufficient tissue data were
available from the LDW to calculate a market basket risk estimate.

B.5 References

Ecology 2000. Results of a screening analysis for metals and organic compounds in shellfish
from Padilla Bay and vicinity. Publication No. 00-03-008. Environmental
Assessment Program, Washington State Department of Ecology, Olympia, WA.
May 2000.

Ecology 2009. Port Angeles Harbor Sediment Characterization Study, Port Angeles, WA:

Sediment Investigation Report. Draft. Toxics Cleanup Program, Washington State
Department of Ecology, Lacey, WA. October 2009.

Era-Miller B. 2006. South Puget Sound verification of303(d) listings for chemical

contaminants in fish and shellfish tissue. Publication No. 06-03-026. Environmental
Assessment Program, Washington State Department of Ecology, Olympia, WA.
July 2006.

King County 1995. Water Quality Assessment. Water Pollution Control Division, King
County Department of Natural Resources, Seattle, WA. October 1995.

King County 2000. Water Quality Status Report for Marine Waters, 1998. King County
Department of Natural Resources, Seattle, WA. July 2000.

£ower ^uwamlsh f^atarway £yroup

fart'of Seattle fmyefSimMiZ tOvCetmljt/The Beefing Cvmfmmy Final Feasibility StUffy

Page 6 ou 01 Attachment 5

-------
ATTACHMENT KK-8. Non-Urban Puget Sound Tissue Dataset

Appendix B - Updated Beach Play Risk Estimates,
Species-Specific RBTC Calculations, and the Puget Sound Tissue Dataset

King County 2001. Water Quality Status Report for Marine Waters, 1999 and 2000. King
County Department of Natural Resources, Seattle, WA. September 2001.

King County 2002. Water Quality Status Report for Marine Waters, 2001. King County
Department of Natural Resources, Seattle, WA. November 2002.

King County 2005. Water Quality Status Report for Marine Waters, 2002 and 2003. King
County Department of Natural Resources and Parks, Seattle, WA. August 2005.

King County 2006. Water Quality Status Report for Marine Waters, 2004. King County
Department of Natural Resources and Parks, Seattle, WA. August 2006.

King County 2009. Water Quality Status Report for Marine Waters, 2005-2007. King

County Department of Natural Resources and Parks, Seattle, WA. April 2009.

Malcolm Pirnie. 2007. Phase 2 Addendum Remedial Investigation for the Marine Environment
Near the Former Rayonier Mill Site, Port Angeles, Washington. Prepared for
Rayonier, Jacksonville, Florida. Malcolm Pirnie, Seattle, WA. Agency Review
Draft, February 2007.

Parametrix 2003. Shellfish tissue sampling report and human health risk assessment,
former Pope & Talbot, Inc. Mill Site, Port Gamble Bay, Washington. Parametrix,
Bremerton, WA. October 2003.

Puget Sound Estuary Program (PSEP) 1991. Dioxin andfuran Concentrations in Puget

Sound crabs. EPA 910/9-91-040. Prepared for the Puget Sound Estuary Program,
U.S. Environmental Protection Agency, Region 10, Office of Coastal Waters. PTI
Environmental Services, Inc., Bellevue, WA. September 1991.

SAIC 2008. Dioxin/juran concentrations at the non-dispersive open-water dredged material
disposal sites in Puget Sound. Prepared for Washington State Department of
Natural Resources. Prepared by Science Applications International Corporation,
Bothell, WA. July 2008.

Van den Berg, M., L.S. Birnbaum, M. Denison, M. De Vito, W. Farland, M. Feeley,

H. Fiedler, H. Hakansson, A. Hanberg, L. Haws, M. Rose, S. Safe, D. Schrenk,
C. Tohyama, A. Tritscher, J. Tuomisto, M. Tysklind, N. Walker, and R.E. Peterson
2006. The 2005 World Health Organization reevaluation of human and
mammalian toxic equivalency factors for dioxins and dioxin-like compounds.
Tox Sci 93(2):223-241. 2006.

West, J.E., S.M. O'Neill, G. Lippert, S. Quinnell 2001. Toxic contaminants in marine and

anadromous fishes from Puget Sound, Washington. Results of the Puget Sound ambient
monitoring program fish component 1989-1999. Washington Department of Fish and
Wildlife, Olympia, WA. August 2001.

£ower ^uwamlsh f^atarway £yroup

fart'of Seattle fmyefSimMiZ tOvCetmljt/The Beefing Cvmfmmy	Final Feasibility StUffy

Page 7	ou 01 Attachment 5

-------
ATTACHMENT KK-8. Non-Urban Puget Sound Tissue Dataset

Appendix B - Updated Beach Play Risk Estimates,
Species-Specific RBTC Calculations, and the Puget Sound Tissue Dataset

Windward Environmental, LLC 2004. Lower Duwamish Waterway Remedial

Investigation. Technical memorandum: Rockfish in the Lower Duwamish Waterway.
Windward Environmental LLC, Seattle, WA. 2004.

Windward 2005a. Lower Duwamish Waterway Remedial Investigation. Data report:
Chemical analyses ofbenthic invertebrate and clam tissue samples and co-located
sediment samples. Prepared for Lower Duwamish Waterway Group. Windward
Environmental LLC, Seattle, WA. May 20, 2005.

Windward 2005b. Lower Duwamish Waterway Remedial Investigation. Data report: Fish
and crab tissue collection and chemical analyses. Prepared for Lower Duwamish
Waterway Group. Windward Environmental LLC, Seattle, WA. July 27, 2005.

Windward 2006. Lower Duwamish Waterway Remedial Investigation. Data report:

Arsenic concentrations in clam tissue samples and co-located sediment samples collected
from background areas in 2005. Prepared for Lower Duwamish Waterway Group.
Windward Environmental LLC, Seattle, WA. April, 3, 2006.

Windward 2007. Lower Duwamish Waterway Remedial Investigation. Baseline Human
Health Risk Assessment. Final. Prepared for Lower Duwamish Waterway Group.
Windward Environmental LLC, Seattle, WA. November 12, 2007.

Windward 2009. Lower Duwamish Waterway Remedial Investigation. Remedial

Investigation Report, Appendix B, Baseline Human Health Risk Assessment. Errata:
adjustment to Tulalip Tribes seafood consumption rates and the impact on risk
estimates. Prepared for Lower Duwamish Waterway Group. Windward
Environmental LLC, Seattle, WA. July 17, 2009.

Windward 2010a. Lower Duwamish Waterway Remedial Investigation. Remedial
Investigation Report. Final. Prepared for Lower Duwamish Waterway Group.
Windward Environmental LLC, Seattle, WA. July 9, 2010.

Windward 2010b. Lower Duwamish Waterway Remedial Investigation. Technical

Memorandum 2009/2010 Surface Sediment Sampling Results for Dioxins and Furans
and Other Chemicals. Prepared for Lower Duwamish Waterway Group.

Windward Environmental LLC, Seattle, WA. July 19, 2010.

£ower ^uwamlsh f^atarway £yroup

fart'of Seattle fmyefSimMiZ tOvCetmljt/The Beefing Cvmfmmy	Final Feasibility StUffy

Page 8	ou 01 Attachment 5

-------
ATTACHMENT KK-8. Non-Urban Puget Sound Tissue Dataset

Appendix B - Updated Beach Play, Risk Estimates,
Species-Specific RBTC Calculations, and the Puget Sound Tissue Dataset

Table B-10 Total PCB Concentrations in Fish and Shellfish Collected from Non-Urban Puget Sound Locations Outside of Known
Contaminated Sites

Species

Tissue Type

Sampling Location

Sampling
Year(s)

Detection
Frequency

Individuals per
Composite
(Average)

Total PCB Concentration3
(|jg/kg ww)

Source

Meanb

Minimum

Maximum

Clams

Butter clam

soft parts

Various locations0

1994-2005

0/42

NS

nc

2.5 U

6.5 U

King County 1995,
2000, 2001,2002,
2005, 2006, 2009

Butter clam

soft parts

Padilla/Fidalgo Bay

1999

0/1

50

nc

2.5 U

2.5 U

Ecology 2000

Littleneck clam

soft parts

Padilla/Fidalgo Bay

1999

0/1

50

nc

2.5 U

2.5 U

Ecology 2000

Littleneck clam

soft parts

Salsbury Point

2003

0/2

NS (10-20)

nc

2.5 U

2.6 U

Parametrix 2003

Geoduck

edible meat

Freshwater Bayd

2006

8/8

1

0.64

0.24

1.43

Malcolm Pirnie 2007e

gut ball

5/5

1

1.35

0.92

2.10

Horse clam

edible meat

Dungeness Bayd

2006

8/8

1

0.12

0.09

0.14

Malcolm Pirnie 2007e

gut ball

5/5

1

1.26

0.95

1.49

Horse clam

edible meat

Freshwater Bayd

2006

8/8

1

0.14

0.10

0.23

Malcolm Pirnie 2007e

gut ball

5/5

1

1.66

1.35

2.14

Crabs

Dungeness crab

edible meat

Padilla/Fidalgo Bay

1999

2/2

5

1.3

1.2 J

1.4 J

Ecology 2000

Dungeness crab

edible meat

Dungeness Bayd

2006

7/7

1

1.02

0.46

1.92

Malcolm Pirnie 2007e

hepatopancreas

7/7

1

25.0

13.1

49.5

calculated whole-body'

7/7

1

8.44

4.39

16.0

Dungeness crab

edible meat

Freshwater Bay0

2006

8/8

1

0.62

0.43

0.99

Malcolm Pirnie 2007e

hepatopancreas

8/8

1

17.8

8.80

32.3

calculated whole-body'

8/8

1

5.96

3.03

10.7

^Qwar cAuwamlsh J^atarway {jrroup

Porforb^ttfe / Cfty of Seattle / Ming County / The Boeing Company

Final Feasibility Study

OU 01 Attagbgfent 5

-------
ATTACHMENT KK-8. Non-Urban Puget Sound Tissue Dataset

Appendix B - Updated Beach Play, Risk Estimates,
Species-Specific RBTC Calculations, and the Puget Sound Tissue Dataset

Table B-10 Total PCB Concentrations in Fish and Shellfish Collected from Non-Urban Puget Sound Locations Outside of Known
Contaminated Sites (continued)







Sampling
Year(s)

Detection

Individuals per
Composite
(Average)

Total PCB Concentration3
(|jg/kg ww)





Species

Tissue Type

Sampling Location

Frequency

Meanb

Minimum

Maximum



Source

Benthic fish

English sole

fillet

PSAMP - non urbane

1989- 1999

117/189

15.2

11.6

1.3

50.8

West et al. 2001

English sole

fillet

PSAMP - near urbane

1989- 1999

36/42

13.6

15.9

2.0

75.4

West et al. 2001

English sole

fillet

Case Inlet/Dana Passage

2005

3/3

4.7

8.5

5.6 J

13.2 J

Era-M

Her 2006

English sole

fillet

Pickering Passage

2005

0/2

5

nc

5.5 U

5.6 U

Era-M

Her 2006

English sole

fillet

South Puget Sound

2005

2/2

20

6.5

6.1 J

6.8 J

Era-M

Her 2006

Rock sole

fillet

Carr Inlet

2005

0/1

5

nc

5.5 U

5.5 U

Era-M

Her 2006

Rock sole

fillet

Case Inlet/Dana Passage

2005

0/1

5

nc

5.5 U

5.5 U

Era-M

Her 2006

Rock sole

fillet

Hale Passage

2005

0/2

5

nc

5.1 U

5.5 U

Era-M

Her 2006

Note: Rows highlighted in light green indicate new total PCB tissue concentrations in fish and shellfish collected from Puget Sound locations outside of known contaminated sites, not previously reported in the
Rl (Windward 2010a).

a.	For PCB Aroclors, the total PCB concentration represents the sum of detected concentrations of up to nine individual PCB Aroclors for a given sample. For samples in which none of the individual Aroclors
were detected, the maximum RL for an individual PCB Aroclor in that sample is used as the concentration. For PCB congeners, the total PCB concentration represents the sum of the detected PCB
congener concentrations for a given sample.

b.	Mean concentrations were calculated using one-half of the RL for non-detect values. A mean value was not calculated when there were no detected values.

c.	Locations include Edmonds, Carkeek Park, Golden Gardens, Alki Point, Vashon Island, and Normandy Park. Data for clams collected by King County were compiled from seven King County reports
(1995, 2000, 2001, 2002, 2005, 2006, 2009).

d.	Dungeness Bay and Freshwater Bay were the reference sites used in the Rayonier Mill Rl near Port Angeles, Washington (Malcom Pirnie 2007).

e.	The total PCB concentrations in this study were analyzed as PCB congeners.

f.	Data from composite hepatopancreas samples were mathematically combined with data from composite samples of edible meat to form composite samples of edible meat plus hepatopancreas. Total PCB
concentrations in whole-body (i.e., edible meat plus hepatopancreas) crab were calculated assuming 69% (by weight) edible meat and 31 % hepatopancreas, based on the relative weights of these tissues
in a 16.6-cm Dungeness crab dissected by Windward in 2004 (unpublished data).

g.	PSAMP data are from various non-urban and near-urban sites around Puget Sound (Figure B-5).

cm = centimeters; J = estimated concentration; |jg/kg = micrograms per kilogram; nc = not calculated (no detected values); NS = not specified; PCB = polychlorinated biphenyl; PSAMP = Puget Sound

Ambient Monitoring Program; Rl = remedial investigation; RL = reporting limit; U = not detected; ww = wet weight

Lower /Juwamish M/aterway /Troup

PortPpSStthPcfty of Seattle /King County/ The Boeing Company	Final Feasibility Study 1J	3

-------
I Drayton Harbor

'Birch Bay

Bellingham Bay

Bellingham

Samish Bay

PadiUa Bay

'Island
County J

Dungeness
jfT Bay

'ort Gambl

Kitsap
County

iremerton

King

County

mmencement Bay

acoma

Pierce
County

rhifrstor

Appendix B - Updated Beach Play Risk Estimates,
ATTACHMENT KK-8. Non-Urban Puget Sound T\ssu&&M§&$Pcific RBTC Calculations, and the Puget Sound Tissue Dataset

Figure B-5. Non-Urban Puget Sound Sampling
Locations for Fish Tissue Analyzed for PCBs

Fish Tissue Sampling Locations
O English sole (West et al. 2001)
~ English sole (Era-Miller 2006)
¦ Rock sole (Era-Miller 2006)

i |^at«rway G

KIMf Cmunry i llMlf Co

Winded

Vancouver Island

0	10	20

f\J	Miles

0 10 20

i Kilometers

Snohomish
County

Grays Harbor
County

Jefferson
County

o

Port Angeles

J Port Gardner
fm

Everett

Clallam
County

Mason
County

Oakland

Page 11	OU 01 Attachment 5 B-42

-------
Appendix B - Updated Beach Play Risk Estimates,

-------
Appendix B - Updated Beach Play Risk Estimates,

-------
ATTACHMENT KK-8. Non-Urban Puget Sound Tissue Dataset

The CB/NT FYR includes fish and crab tissue data as originally summarized in Table B-10
"Total PCB Concentrations in Fish and Shellfish Collected from Non-Urban Puget Sound
Locations Outside of Known Contaminated Sites" of the Feasibility Study (FS) for the Lower
Duwamish Waterway Superfund Site (AECOM 2012). The FS includes the following text
associated with Table B-10:

"The data in this excel file came from a variety of sources, none of which are the
laboratories which originally generated the data. While we have made every attempt to
faithfully reproduce the data from those sources, we have NOT gone back to the original
laboratory sources and QCed the accuracy of the data using Form Is or other electronic
sources as this would be a rather substantial effort. Any questions regarding this data set
and it's compilation should be directed to Erika Hoffman (EPA Region 10) at
hoffman. erika(a),epa. gov "

Page 14

OU 01 Attachment 5

-------
ATTACHMENT KK-9. DOH Puget Sound Fish Consumption Advice

S^ i Was/irngfon Stale Department of

W Health

Division of Environmental Health
Office of Environmental
Health Assessments

October 2006

PugetSound

Fish Consumption Advice

Advice for People Who Eat Salmon, Rockfish, and
Flatfish from Puget Sound

Mary Selecky

Secretary of
Health

Why is there a fish advisory for
PugetSound?

Over the past decade, the Puget
Sound Assessment and Monitoring
Program has tested for contaminants
in several Puget Sound fish (Chinook
and coho salmon, English sole, and
four species of rockfish). Some types
offish were found to have higher lev-
els of contaminants than others.

The Washington State Department of
Health (DOH) has identified two con-
taminants that pose a potential health
concern for people who eat certain
species of Puget Sound fish:

•	PCBs (Polychlorinated biphenyls)

•	Mercury (Methylmercury)

DOH is providing consumption advice
for particular species offish in Puget
Sound based on levels of one or both
of these contaminants. We recom-
mend that people, especially women
who might become pregnant or who
are pregnant, nursing mothers, and
young children, minimize exposure to
these contaminants by following ad-
vice in this healthy fish eating guide.

What are the health benefits of
fish?

Fish is high in protein and is an excel-
lent source of omega-3 fatty acids,
which are not found naturally in our
bodies. Omega-3 fatty acids are essen-
tial during pregnancy for the healthy
development of a child's brain, retina,
and nerve tissue. Omega-3 fatty acids
help prevent heart disease and stroke
by reducing blood pressure, inflamma-
tion, and blood clotting.

Other foods like beef, poultry, and
pork also have some contaminants.
Removing fish from your diet will not
eliminate your exposure, but will elimi-
nate the many health benefits that you
get from eating fish. So, keep eating
fish!

What are PCBs and mercury and
how do they affect health?

PCBs - PCBs are a group of chemicals
that were once used widely in prod-
ucts such as coolants and lubricants
for transformers. In 1977, PCBs were
banned because of their potential to
affect health and persistence in the en-
vironment. Children exposed to PCBs
in the womb may have learning and
behavior problems later in life. PCBs
can also impact the immune system.

"It's good to know that fish
in Puget Sound, especially
our salmon, remain a healthy
choice for the dinner table.
While we provide clear infor-
mation on the many choices of
fish that are low in contamina-
tion, let's also be clear about
the need to keep toxics out of
Puget Sound."

Mercury - Mercury occurs naturally
in the environment. It also comes
from industrial air pollution and im-
proper disposal of thermostats, elec-
trical switches, and fluorescent bulbs.
Mercury is linked to learning and
behavior problems in kids. Like PCBs,
exposure to mercury in the womb
can cause learning and behavior
problems later in life.

How do PCBs and mercury get
into Puget Sound fish?

PCBs and mercury enter rivers and
streams through air or direct re-
lease, then settle into sediments.
Some fish eat prey associated with
sediments. Aquatic organisms do
not eliminate these chemicals easily.
These contaminants can move up the
food chain into predatory fish, then
passed to humans who eat fish.

Puget Sound Fish Eating Guide	www.doh.wa.gov/fish	Page 1

-------
ATTACHMENT KK-9. DOH Puget Sound Fish Consumption Advice

A Healthy Eating Guide
for Salmon, Rockfish, and
Flatfish from Puget Sound

Advice for anyone concerned about
contaminants in fish, especially women
who might become pregnant, women who
are pregnant, nursing mothers, and
young children.

Puget Sound Fish Consumption Guidance

Fish is a vital part of a healthy diet. Do not stop
eating fish. Most foods have some contaminants
in them, not just Puget Sound fish. The following
advice will limit your exposure to contaminants and
maximize the many health benefits from eating fish.

The two main ways to reduce your exposure to con- -
taminants in fish are through wise choices and good
fish preparation. Fish preparation recommendations
can reduce, by up to 50 percent, PCBs and other
contaminants that collect in the fat of fish. Mercury
is stored in the muscle of fish and cannot be reduced
by cleaning this way.

If there are "no restrictions" for the fish you like to eat
in these tables, follow the American Heart Association
recommendations and enjoy at least 2 heart healthy
meals per week.

PugetSound
Recreational
Marine Areas

Blaine

v &

¦ \
Bellingham

rfi. ' '

_ #%,
V :s*v y	"sBW. » •-».



7 ,



Vemon

/

Port Angeles

\ , f /... •>

H~ I < ^ A1 i \ VVx

&

Everett

o

"	T.-'-

of/-

12j' >• ¦ j.

- <2l	Seattle

Bremerton

/

& o"	/ If > VI"

: 'I V }-} ,

- £ ,3. \ J J. -iv/W'' '¦ % -3*
'/'vV Tacoma
< V' a

-vOlympia.



How to Use the Following Tables

Fish consumption guidance is organized by Wash-
ington State Department of Fish and Wildlife's
(WDFW) marine areas. To use the following tables,
locate the "Recreational Marine Area" where you
catch fish. Follow the consumption advice for that
area. Note, one meal is eight ounces offish un-
cooked and no restrictions means you can eat 2 to
3 meals per week. If you eat the amount recom-
mended for the week, be sure to choose other fish
that are lower in contaminants for any other meals
that week. Some good choices are canned light
tuna, cod, flounder, coastal salmon, and trout. For
additional choices visit www.doh.wa.gov/fish.

DOH Fish Preparation Recommendations

When cleaning fish,
remove the skin, fat, and
internal organs before
cooking.

Cut away the
along the side ot the fish Trim off the'belly fat

Grill, bake, or broil fish so
that the fat drips off while
cooking.

Cut away the fat
along

Consume younger, smaller
fish (within legal limits).

Puget Sound Fish Eating Guide

www.doh.wa.gov/fish

OU 01 Attachment 5

Page 2

-------
Puget Sound
Salmon

ATTACHMENT KK-9. DOH Puget Sound Fish Consumption Advice

Salmon from Puget Sound have low levels
of contaminants and are a healthy food. The
American Heart Association recommends
that people eat at least two fish meals per
week for a healthy heart,

Salmon are a good choice when choosing
fish from Puget Sound. There are no meal
restrictions for coho, chum, pink, and sock-
eye salmon which means you can eat 2 to 3
meals per week. DOH recommends eating
Puget Sound Chinook once per week.

Puget Sound Salmon*

All Puget Sound Marine Areas

Marine Area

Salmon Species

Consumption Advice

6 thru 13

Chinook

No more than 1 meal per week

6 thru 13

Chinook (Blackmouth)

No more than 2 meals per month

6 thru 13

Coho

No restrictions

6 thru 13

Chum, Pink, Sockeye**

No restrictions

* High-end consumers (more than 2 meals per week) should follow DOH's fish prepara-
tion recommendations.

** Chum, pink, and sockeye salmon were not sampled as part of PSAMP. Data from
other sources show that these species tend to have low PCB ievels.

Resident Chinook (blackmouth) appear to
have higher levels of contaminants, so eat
only two meals per month. Most blackmouth
remain in Puget Sound rather than migrate
to the ocean, so they accumulate more con-
taminants.

Puget Sound
Rockfish

Puget Sound Rockfish

Rockfish consumption advice is based on
contaminant levels in brown, quillback, and
copper rockfish from Puget Sound. In addition
to contaminant concerns, non-tribal harvest of
yelloweye and canary rockfish is prohibited for
conservation purposes.

Marine Area/ Location

Rockfish Species

Consumption Advice

Exceptions

6 thru 13

All Puget Sound Marine Areas

Yelloweye Rockfish*

No consumption

None

6 thru 13

All Puget Sound Marine Areas

Canary Rockfish*

No consumption

None

6

East Juan de Fuca Strait

Rockfish

No more than 1 meal per week

None

7

San Juan Islands

Rockfish

No more than 1 meal per week

None

8.1

Deception Pass, Hope Island & Skagit Bay

Rockfish

No more than 1 meal per week

None

8.2

Port Susan/ Port Gardner

Rockfish

No more than 1 meal per week

Yes



Mukilteo-Everett/ Port Gardner

Rockfish

No more than 2 meals per month



9

Admiralty Inlet

Rockfish

No more than 1 meal per week

None

10

Seattle-Bremerton

Rockfish

No more than 1 meal per week

Yes



Elliott Bay

Rockfish

No consumption





Sinclair Inlet

Rockfish

No consumption



11

Tacoma-Vashon

Rockfish

No more than 1 meal per week

None

12

Hood Canal

Rockfish

No more than 1 meal per week

None

13

South Puget Sound (South of theTacoma Narrows)

Rockfish

No more than 1 meal per week

None

Non-tribal harvest of yelloweye and canary rockfish is prohibited for conservation purposes.

Puget Sound Fish Eating Guide

www.doh.wa.gov/fish

OU 01 Attachment 5

Page 3

-------
Puget Sound Fish Consumption Advice

The following advice applies to consumption of Puget
Sound flatfish including English sole, starry flounder,
f	and rock sole. No restrictions means you can eat 2 to 3

meals per week

Puget Sound English Sole & Other Flatfish

*

Marine Area/ Location

Consumption Advice

Exceptions

6

East Juan de Fuca Strait

No restrictions

None

7

San Juan Islands

No restrictions

None

8.1

Deception Pass, Hope Island & Skagit Bay

No restrictions

None

8.2

Port Susan/ Port Gardner

No restrictions

Yes



Mukilteo Ferry Dock to City of Everett

No more than 2 meals per month



9

Admiralty Inlet

No restrictions

None

10

Seattle-Bremerton

No restrictions

Yes



Duwamish Waterway

No consumption





Elliott Bay

No more than 2 meals per month





Eagle Harbor

No more than 1 meal per week





Port Orchard Passage

No more than 1 meal per week





Sinclair Inlet

No more than 1 meal per month



11

Tacoma-Vashon

No restrictions

Yes



Inner Commencement Bay

No more than 2 meals per month





Outer Commencement Bay

No more than 1 meal per week



12

Hood Canal

No restrictions

None

13

South Puget Sound (South of the Tacoma Narrows)

No restrictions

None

* Recommendations for consuming other bottomfish such as lingcod, are not included in the above advice.

For More Information About:

Fish Advisories in Washington State
Contact: Washington State Department of Health
Fish Consumption Advisory Program
To I Free: 1.877.485.7316
www.d oh .wa .gov/fi sh

The Health of Puget Sound

Contact: Puget Sound Partnership
Toll Free: 1.800.54.Sound

www.psp.wa.gov

Puget Sound Ambient Monitoring Program
Fish Component

Contact: Washington State Department of Fish & Wildlife
Ph: 360.902.2200
www.wdfw.wa.gov/fish/psamp

Fishing Regulations in Puget Sound

Contact: Washington State Department of Fish & Wildlife

Ph: 360.902.2700
www.wdfw.wa.gov/fishing

"It is important to continue to eat fish,
be smart, and choose fish wisely."

Maxine Hayes
State Health Officer

- « (VWiingtoi Staff Department of

6 Healt

Graphics and Photo Credits:

Fish graphic courtesy of Windsor Nature Discovery (Toll-Free
1.800.833.6388), Puget Sound image courtesty of Don Lennartson,
and Angler with Chinook courtesty of Dom Reale.

This document is available in other formats for persons with dis-
abilities. TDD LINE: 1-800-833-6388.

October 2006 DOH Publication #334-098

Puget Sound Fish Eating Guide

www.doh.wa.gov/fish

OU 01 Attachment 5

Page 4

-------
ATTACHMENT KK-10. Washington State Sport Fishing Rules

¦ £>, {VMU£, 'r

;
viKjjfew

zjliytyyuriis

OU 01 Attachment 5

-------
ATTACHMENT KK-10. Washington State Sport Fishing Rules

Eflgg)	j

mj Les Davis Fishing Pier: Waters within 100 yards of the Les Davis Fishing Pier, CLOSED to fishing for food fish and to the harvest of
SHELLFISH except when fishing from the pier.

(2) Des Moines Fishing Pier: Waters within 100 yards of the Des Moines Public Fishing Pier, CLOSED to fishing for food fish and to the harvest of
SHELLFISH except when fishing from the pier.

@ City of Des Moines Park Conservation Area: CLOSED to all harvest.

@ South 239th Street Park Conservation Area: CLOSED to all harvest.

© Colvos Passage Marine Preserve: Area enclosed by a line starting at extreme low water 300' SW of the southern boundary of Sunrise
County Park, Pierce Co. (latitude 47°20.9'N) due east 300', then southwesterly paralleling the shoreline for 500', then west to the extreme low
water line, then northeasterly along extreme low water line to point of origin, CLOSED to all harvest, except SALMON trolling allowed.

Commencement Bay Closure: Waters east of a line bearing 215° true (195°30' magnetic) from the Cliff House Restaurant on north shore
(approximate position 47°17'51"N, 122°25'54"W) through Sperry Ocean Dock (approximate position 47°16'26"N, 122°27'22"W) -
Apr. 1-Apr. 30, and June 1 -July 31: CLOSED to fishing for SALMON. Aug. 1-Mar. 31 and May 1-May 31: same rules as Marine Area 11 - ENTIRE
AREA. See Department of Health (DOH) Fish Consumption Advisory on page 20.

(7) Saltwater State Park Marine Preserve: Those waters, bedlands, and tidelands of Saltwater State Park within a line projected from the

w northernmost marker at the DNR high tide line through 122°19'39.02"W, 47°22'25.14"N; then to 122°19'44.14"W, 47
-------
ATTACHMENT KK-10. Washington State Sport Fishing Rules

(From the north tip of Vashon Island to the Northernmost Tacoma Narrows Bridge)

''species

SEASON

ADDITIONAL RULES ^

SALMON-ENTIRE AREA

June 1-Sept. 30

CHINOOK - min. size 22". Other SALMON species - no min. size. Daily limit 2
(combined). Release wild CHINOOK. See Commencement Bay Closure on
previous page.



Oct. 1 -Oct. 31

CHINOOK - min. size 22". Other SALMON species - no min. size. Daily limit 2
(combined).



Nov. 1-Dec. 31

CHINOOK - min. size 22". Other SALMON species - no min. size. Daily limit 2
(combined). Only 1 CHINOOK may be retained.



Feb. 1-Apr, 30

CHINOOK - min. size 22". Other SALMON species - no min. size. Daily limit 2.
Release wild CHINOOK. See Commencement Bay closure on previous page.

Dash Point Dock, Les Davis Pier,
Des Moines Pier, Redondo Pier,
Point Defiance Boathouse Dock

Year-round

CHINOOK - min. size 22". Other SALMON species - no min. size. Daily limit 2
(combined). Only 1 CHINOOK may be retained.

TROUT

Year-round

Catch-and-release except up to 2 hatchery STEELHEAD may be retained.

STURGEON

Year-round

Catch-and-release.



June 1-June 30
Sept. 1 -Oct. 15

Min. size 38" fork length. Max. size 54" fork length. Daily limit 1. Release GREEN
STURGEON.

MACKEREL

Year-round

No min. size. No daily limit.

HERRING, SMELT, ANCHOVY,
SARDINE and SAND LANCE

Year-round

No min. size. Daily limit 10 lbs., all species combined. All SMELT caught must be kept
and count toward the daily limit except CLOSED to Columbia River SMELT (eulachon).
For SMELT: Jig gear may be used 7 days a week. Dipnets may be used 8:00 a.m.
Fridays through 8:00 a.m. Wednesdays."

PACIFIC HALIBUT

CLOSED



BOTTOMFISH

Year-round season. Daily limit is a total of 15 BOTTOMFISH (see definition page 10) regardless of species, subject
to individual limits and seasons shown below. Fishing for BOTTOMFISH prohibited in waters deeper than 120 feet.

LINGCOD

May 1-June 15
May 21-June 15

Hook and line season. Min. size 26". Max. size 36". Daily limit 1.
Spearfishing season. Max. size 36". Daily limit 1.

SURFPERCH

Year-round

No min. size. Dailv limit 10. Except SHINER PERCH daily limit 15: not included in
BOTTOMFISH limit.

ROCKFISH

CLOSED



PACIFIC COD, POLLOCK, HAKE,
WOLF-EEL, SIXGILL SHARK

CLOSED

SIXGILL SHARK may not be removed from the water.

CABEZON

May 1 -Nov. 30

No min. size. Daily limit 2.

OTHER FOOD FISH

Year-round

No min. size. Daily limit 2 of each species.

ALL OTHER FISH

Year-round

CLOSED

J

Reporting lost or abandoned nets or pots

Still Fishing After All These Years

Lost and abandoned fishing gear continues to fish, impacting marine animals and destroying their
habitat, entangling divers, and damaging propellers and rudders of boats.

What's being done?

Federal, state, tribal, and local governments, NGOs, and grassroots organizations and individuals are
collaborating to protect and restore Washington marine resources by locating and removing harmful
derelict fishing gear.

How can you help?

Record as much information as you can when you find derelict gear, including;

• General location

Photo provided by the Northwest Straits Initiative.

•	Date of sighting

•	Type of gear

•	Approximate water depth

You can report this information to:

¦	Latitude (example 48.34333)

¦	Longitude (example -123.00333)

Washington

There are no penalties associated with reporting lost fishing gear.

The Derelict Fishing Gear Removal Project is a no-fault program. The goals are
simply to remove lost and abandoned gear, to help restore Puget Sound, to improve
public safety, and to assist species recovery.

Nets are	Never attempt to remove them. Divers, stay a safe distance away

FfSH and
WILDLIFE

Northwest Straits

marine conservation initiative

(Toll Free) 855-542-3935 or go to 360-428-1084 or go to

http://wdfw.wa.gov/fishing/cl9 ffP Att^VVW(
-------
ATTACHMENT KK-10. Washington State Sport Fishing Rules

Qeawee

fSifltoflto

3 Steps to Safe and Legal Shellfish Harvest - It's your responsibility!

1

• Know the Rules (You could get a ticket)

Is the harvesting season open? Read the rules for seasons, size, and bag limits. Always check the toll free WDFW
Emergency Shellfish Rule Change Hotline (866) 880-5431. Current harvesting season information can always be found by
using the clickable map on the WDFW website at http://wdfw.wa.aov/fishina/shellfish/beaches.

•	• Pollution Closures (You could get sick)

Does the beach meet standards for healthy eating? Some closures are shown on the map on page 127. For more
pollution closures visit the Washington Department of Health website at www.doh.wa.aov/shellfishsafetv.htm. call
(360) 236-3330, the Shellfish Safety toll-free Hotline at (800) 562-5632, or the local county health department.

•	• Marine Biotoxin Closures and Vibrio Warnings (You could get sick or die)

Is there an emergency closure due to Shellfish Poisoning (PSP/ASP/DSP) or Vibrio bacteria? Check the DOH website
at www.doh.wa.aov/shellfishsafetv.htm. call (360) 236-3330, or the Shellfish Safety toll-free Hotline at (800) 562-5632.

NOTE: Emergency rules may occur throughout the year and will supersede the rules contained in this pamphlet. Changes can be found by
calling the Shellfish Rule Change toll-free Hotline at (866) 880-5431, contacting statewide customer service, or by visiting the WDFW website.

Licenses

A Combination or a Shellfish/Seaweed License
is required for all shellfish (except CRAWFISH)
and SEAWEED harvest. A catch record card, and
endorsement is required to fish for DUNGENESS
CRAB in Puget Sound. (See License
Requirements, page 6).

Designated Harvesters

Persons with a disability must have a designated
harvester card issued by WDFW if using another
harvester to assist them with their catch. The
person harvesting the catch on behalf of the
licensee with a disability must be in possession
of the designated harvester card while assisting
the person with a disability. Both the digger and
the person with a disability must be licensed.
The licensee is also required to be in the direct
line of sight of the designated harvester who is
harvesting shellfish for them. If this is not possible,
the licensee is required to be within % mile of the
designated harvester who is harvesting shellfish
for them.

Practices

Water color does not indicate SHELLFISH
safety.

Rinse your catch in salt (not fresh) water
before leaving the beach, quickly cool your
catch on ice or in a refrigerator, and cook as
soon as possible.

Wash all SEAWEED before eating.

Cook shellfish thoroughly before eating.
Cooking, rinsing, or freezing DOES NOT
destroy all pollutants. CRAB can also
concentrate pollutants in their internal
organs (crab butter). Clean CRAB before
cooking. Eat only the meat.



Page 4

Eating contaminated shellfish or seaweed
can cause serious illness or death. The only
way to be safe is to "Know Before You Dig."
Check the Department of Health (DOH) website
www.doh.wa.aov/ehp/sf/default-sf.htm. or call
the local health department. For shellfish safety
closures call the Shellfish Safety Hotline at (800)
562-5632.

Dont harvest in areas that are polluted. It
can make you sick. Pollution can come from
many sources like sewage drain pipes, failing
septic systems, farm practices, wildlife, and pet
waste. Use sani-cans, vault toilets and other
approved facilities. Properly dispose of human
and pet waste if no facilites are available.

Dont harvest in areas with marine biotoxins
(PSP/ASP/DSP) or Vibrio warnings. You
could get sick or die.

PARALYTIC SHELLFISH POISONING (PSP) &
AMNESIC SHELLFISH POISONING (ASP):

•	Can make you sick or cause death

•	Can't be destroyed by cooking or freezing

•	Are produced by algae that usually can't be
seen

•	Do not turn water red like the old name
suggests

NEW: DIARRHETIC SHELLFISH POISONING
(DSP):

•	Can make you sick

•	Can't be destroyed by cooking or freezing

•	Is produced by algae that can't be seen

VIBRIO BACTERIA: In the summer, sea water
often has high levels of naturally occuring
bacteria. Unlike biotoxins, these bacteria can
be killed by cooking. To avoid getting sick,
DOH advises that you COOK ALL SHELLFISH
thoroughly.

For more information on PSP, ASP, DSP and
Vibrio bacteria, visit the DOH website, call the
main office at (360) 236-3330, or contact the
local county health department.

Possession Limit

One daily limit in fresh form. Additional
shellfish may be possessed in frozen or
processed form.

For all Shellfish Species, see Marine Area
maps (pages 99-123) for closures pertaining
to the following areas:

AREA 7: San Juan Islands Marine Preserve.
AREA 9: Edmonds Public Fishing Pier, Brackett's
Landing Shoreline Sanctuary, Keystone
Conservation Area, and Admiralty Head Marine
Preserve.

AREA 10: Elliott Bay Public Fishing Pier, Orchard
Rocks Conservation Area, Carkeek Park, Golden
Gardens, Discovery Park, Richey Viewpoint,
Emma Schmitz Memorial, Lincoln Park, and
Eagle Harbor.

AREA 11: Des Moines Fishing Pier, Les Davis
Fishing Pier, Colvos Passage Marine Preserve,
City of Des Moines Park, and South 239th Street
Park, Saltwater State Park Marine Preserve.
AREA 12: Sund Rock Conservation Area,
Waketickeh Creek Conservation Area, and
Octopus Hole Conservation Area.

AREA 13: Saltans Point Conservation Area,
Titlow Beach Marine Preserve, and Z's Reef
Marine Preserve.

Tideland Ownership

Most Puget Sound, Hood Canal, Grays Harbor,
and Wllapa Bay beaches are privately owned.
SHELLFISH and SEAWEED may not be taken
from private beaches without the owner's or
lessee's permission. Private tideland owners
and lessees, and members of their immediate
family (grandparents, parents, spouse, siblings,
children, and grandchildren) are exempt from
personal use daily limits when taking CLAMS,
OYSTERS, and MUSSELS harvested for their
own personal use from their own tidelands.

Daily limits apply for all other shellfish, all
other people, and all other beaches. Everyone
harvesting shellfish in excess of the daily limit
from private beaches for presumed commercial
purposes needs a shellfish certification from the
Department of ^ 1^^.30.010(8)).

124

-------
ATTACHMENT KK-10. Washington State Sport Fishing Rules



Two different state agencies are responsible for two different types of recreational shellfish harvest closures. The Washington Department
of Fish and Wildlife (WDFW) is responsible for conservation closures or season adjustments, which are listed in the Public Beach List (below).

These closures are designed to protect and conserve intertidal shellfish populations. The Washington Department of Health (DOH) is responsible for
human health-related closures in response to potentially life-threatening environmental conditions, which result from PSP/ASP/DSP, Vibrio bacteria or
pollution, as described in the Shellfish Safety section on page 124. Some, but not all of these beaches are also closed by WDFW. Permanent WDFW/
DOH closures and periodic DOH harvest advisories are shown on page 127.

r DOH SEASON

WDFW SEASON

HARVEST STATUS

REASON



Open

Open

SAFE & LEGAL

Open

Closed

ILLEGAL

Conservation closure or season adjustment



Closed

Open

NOT SAFE

Potentially life-threatening environmental conditions



V Closed

Closed

NOT SAFE & ILLEGAL



J

Not all beaches have been evaluated by DOH, so if you have any concerns call the local health department or DOH at (360) 236-3330 or (800) 562-
5632. In addition, some beaches may be posted with warning signs - look for signs as you access the beach.

ALWAYS CHECK BOTH THE CURRENT WDFW SEASON AND THE DOH HEALTH CLOSURE STATUS BEFORE HARVESTING ANY PUBLIC BEACH.

Beaches that do not appear on the Public Beach List (below) or on the Health Restrictions map on page 127 may be open to harvest
year-round. For beach locations check the WDFW website at http://wdfw.wa.aov/fishina/shellfish/beaches . The website includes interactive beach
maps providing information about access, available species, harvest tips, driving directions, facility descriptions and links to the DOH Shellfish Safety
webpages. Also, check the Marine Preserves and Conservation Closures on page 124 before planning your trip.

• Between Jan. 1-Apr. 30 you MUST check the website	, Shellfish

Rule Change Hotline (866) 880-5431 or contact the WDFW customer service desk (360) 902-2700 to verify seasons. Emergency rules will
supersede the rules contained in this pamphlet.

RAZOR CLAM seasons occur only after clam samples have been tested by Washington Department of Health (DOH) and are found to be
safe for human consumption.

c

BEACH NAME

CLAM/MUSSEL
SEASON

OYSTER
SEASON

N

ADDITIONAL RULES

Ala Spit

May 1-May 31

May 1-May 31

Limited natural production of OYSTERS.

Belfair State Park

Year-round

Year-round

Open only in area defined by boundary markers and posted signs.

Cama Beach State Park

CLOSED

CLOSED



Camano Island State Park

CLOSED

CLOSED



Dosewallips State Park

Mar. 1 -Oct. 31

Year-round

Open only in area defined by boundary markers and posted signs.

Duckabush

Year-round

Year-round

All state-owned tidelands on the west shore of Hood Canal from Quatsap Point to
the south end of the Duckabush River flats.

Dungeness Spit and National
Wldlife Refuge Tidelands

May 15-Sept. 30

May 15-Sept. 30

Limited natural production of OYSTERS.

Eagle Creek

July 1 -July 31

Year-round



Fort Flagler State Park

May 15-Sept. 30

May 15-Sept. 30

Including that portion of the spit west of the Park boundary (Rat Island). Limited
natural production of OYSTERS.

Frye Cove County Park

Jan. 1-May 15

Jan. 1-May 15



Garrison Bay/British Camp

All tidelands of Guss Island, and all state and federally owned tidelands at British Camp (San Juan County) between
the National Park Service dinghy dock and the southern park boundary, are closed to CLAM harvest year-round.
Tidelands north of the dinghy dock to Bell Point are open year-round.

Hope Island State Park

May 1-May 31

May 1-May 31

Located in South Puget Sound.

lllahee State Park

Apr. 1 -July 31

Apr. 1 -July 31

Limited natural production of CLAMS.

Kayak Point County Park

CLOSED

CLOSED



Kitsap Memorial State Park

CLOSED

CLOSED



Kopachuck State Park

June 1 -July 31

Mar. 1 -July 31



Mystery Bay State Park

Oct. 1 -Apr. 30

Oct. 1 -Apr. 30

Health closure May 1-Sept. 30. See page 127.

Nahcotta Tidelands

CLOSED

Year-round

Open only in the area defined by boundary markers and posted signs.

Oak Bay County Park

May 1 -July 31

May 1 -July 31

Limited natural production of OYSTERS.

Oyster Reserves of North Bay
(Case Inlet)

Year-round

Year-round



Oyster Reserves of Oakland

^ BaV P3gP «

Year-round

Year-round

EXCEPT area defined by boundary markers and signs is closed year-round to
CLAM and OYSTER harvest. ou Q1 Attachment 5 >

Continued on next page	125

-------
ATTACHMENT KK-10. Washington State Sport Fishing Rules



f

BEACH NAME

CLAM/MUSSEL
SEASON

OYSTER
SEASON

¦\

ADDITIONAL RULES

Oyster Reserves of Totten
and Eld Inlets

CLOSED

CLOSED



Oyster Reserves of Wllapa
Bay

CLOSED

CLOSED

EXCEPT Diamond Point on the northwest side of Long Island between reserve
monuments 39-41, and Pinnacle Rock on the southwest side of the Long Island
between reserve monuments 58-59, are open year-round to CLAM and OYSTER
harvest.

Pacific Ocean beaches

Nov. 1-Mar. 31

Nov. 1-Mar. 31

Closed Apr. 1 -Oct. 31 (unless listed otherwise) because of PSP (except RAZOR
CLAMS).

Penrose Point State Park

Mar. 1-May 15

Mar. 1-May 15



Pitt Island

CLOSED

CLOSED



Point Whitney Lagoon

Apr. 1 -Apr. 30

Year-round



Point Whitney Tidelands

Mar. 1-Mar. 31

Jan. 1-June 30

Excluding Point Whitney Lagoon.

Port Townsend Ship Canal/
Portage Canal

Jan. 1 -July 31

Jan. 1 -July 31

See Marine Area 9 map, page 114. Limited natural production of OYSTERS.

Potlatch DNR Tidelands

Apr. 1-June 30

Apr. 1-June 30



Potlatch State Park

Apr. 1-June 30

Apr. 1-June 30



Purdy Spit County Park

CLOSED

CLOSED

Southern shore of the spit, from the boat ramp east to the bridge, is closed.

Quilcene Bay WDFW
Tidelands

Apr. 1-Dec. 31

Apr. 1-Dec. 31

All state-owned tidelands in Quilcene Bay north of a line drawn from the Quilcene
Boat Haven to Fisherman's Point are closed, except those state-owned tidelands
on the west side of the bay, north of the Quilcene Boat Haven, are open
Apr. 1 - Dec. 31. Open from official sunrise to official sunset. CLAM min. size 1

Scenic Beach State Park

CLOSED

CLOSED



Sequim Bay State Park

May 1-June 30

Year-round



Shine Tidelands State Park

Jan. 1-May 15

Jan. 1-May 15

Limited natural production of OYSTERS.

South Indian Island County
Park

May 15-Aug. 31

May 15-Aug. 31

And adjacent tidelands. Limited natural production of OYSTERS.

Spencer Spit State Park

Mar. 1 -July 31

Mar. 1 -July 31

Limited natural production of OYSTERS.

Triton Cove Tidelands

June 1-Aug. 31

Year-round

% mile north of Triton Cove State Park.

Twanoh State Park

Aug. 1-Sept. 30

Year-round



West Dewatto (DNR 44A)

Aug. 1-Sept. 30

Year-round



Wllapa Bay

Year-round

Year-round

Bonus limit: 24 COCKLES in addition to the regular CLAM limit. See Oyster
Reserves, state-owned, and Nahcotta Tidelands.

WINAS-Maylor Point - East

National security concerns control access. Contact John Phillips, Naval Air Station, (360) 257-8873 or
(360) 257-1009, for information on access requirements.

Wolfe Property State Park

V

Jan. 1-May 15

Jan. 1-May 15

From 7 Sisters Rd. north to the lagoon channel adjacent to the spit connecting
Hood Head to the mainland. North and east of the lagoon channel is private
property.



WDFWs shellfish program has planted several public beaches with OYSTERS, CLAMS, and GEODUCKS. Some beaches have increased
harvest opportunity as a result of WDFWs enhancement activities. If a beach is open for CLAMS, MUSSELS, or OYSTERS, harvest is encouraged
on these beaches.

Birch Bay State Park - Oysters
Blake Island State Park - Geoducks
DNR 24 - Oysters

DNR 44A West Dewatto - Clams/Oysters
Frye Cove County Park - Clams/Oysters
lllahee State Park - Oysters
Kopachuck State Park - Oysters

Mystery Bay State Park - Oysters
Oak Bay County Park - Clams
Penrose State Park - Clams/Oysters
Point Whitney Lagoon - Clams
Point Whitney Tidelands - Clams
Potlatch State Park - Oysters
Quilcene Bay WDFW Tidelands - Oysters

Sequim Bay State Park - Clams/Oysters

Shine Tidelands State Park - Clams/Geoducks

South Indian Island County Park - Clams

Triton Cove Tidelands - Clams

Twanoh State Park - Clams

West Penn Cove - Oysters

Wolfe Property State Park - Clams/Oysters

Varnish Clams have the ability to retain biotoxins at
higher levels and longer than other clams.

Always check the biotoxin hotline before harvesting.
1-800-562-5632 or
Page 6 www.doh.wa.gov/shellfishsafety.htm

&

Varnish clam

Nuttallia obscurata

Up to 2%", with shiny brown coating

on the outside, purple on the inside
ofs^ 01 Attachment 5

126

-------
ATTACHMENT KK-10. Washington State Sport Fishing Rules



i

f	\

Before harvesting shellfish check the Department of Health toll-free Shellfish Safety hotline, (800) 562-5632, or (360) 236-

3330 in the Olympia area, or on the Internet, www.doh.wa.aov/ehp/sf/default-sf.htm If you need further assistance, contact
the county health department. County health department phone numbers are published in the government pages of local
telephone directories.

These areas and all beaches in the following list are
CLOSED year-round by the Department of Fish and
Wildlife (WDFW) and Department of Health (DOH):

•	On the Strait of Juan de Fuca - Port Angeles Harbor and Port
Angeles Coast Guard.

•	All beaches within the (cross-hatched) areas.

•	All beaches around ferry docks.

•	All beaches below indicated by this symbol on the map: ©

1	Semiahmoo County Park	21 North Beach County Park

2	Semiahmoo	22 South Point Wilson

3	Reid Harbor - South Beach	23 North Point Hudson

4	Post Point	24 Suquamish (Old Man House) and

5	Chuckanut Bay (Mud Bay)	Old Man House State Park

6	Samish Beach	25 Bangor

7	Bay View State Park	26 Silverdale Waterfront Park

8	Skagit Wldlife Area	27 Fort Ward State Park

9	DNR-144 (Sleeper)	28 Manchester State Park

10	DNR-142	29 Little Clam Bay

11	Oak Harbor City Park	30 Dockton County Park

12	Monroe Landing	31 DNR-79

13	Coupeville	32 McNeil Island/Gertrude Island

14	Harrington Beach	33 South Oro Bay

15	West Pass Access	34 Taylor Bay

16	Northeast Cultus Bay	35 Woodard Bay

17	Dave Mackie County Park	36 Walker County Park

18	Freeland County Park	37 Hoodsport

19	Graveyard Spit	38 Pleasant Harbor State Park

20	Pitship Point

The Department of Health (DOH) has harvest advisories
on the following beaches, as indicated by this symbol: Q

An advisory is placed on beaches that MAY be subject to periodic
contamination from pollution sources or MAY intersect polluted areas.
Check the DOH website for details, or contact the county health
department prior to harvesting these beaches.

A.	Larrabee State Park (north end)

B.	WINAS Crescent Harbor

C.	WINAS-Maylor Point - E (north end)

D.	Blowers Bluff

E.	WINAS-Maylor Pt - W (inside Oak Harbor)

F.	East San de Fuca

G.	San de Fuca

H.	West Penn Cove (N Penn Cove)

I.	Madrona (Penn Cove)

J.	Long Point

K.	Dungeness National Wldlife Refuge

L.	Cline Spit

M.	DNR-411A

N.	Mystery Bay State Park

O.	Scatchet Head

P.	Point White

Q.	Blake Island State Park (east side)

R.	DNR-34

S.	Jarrell Cove

T.	North Chapman Cove, Northeast Chapman Cove, and Southeast

Chapman Cove

U.	Oakland Bay

V.	North Hoodsport Hatchery

W.	Twanoh State Park

X.	Belfair State Park

Y.	Dosewallips State Park

Z.	Brownsville

OU 01 Attachment 5

127

-------
ATTACHMENT KK-10. Washington State Sport Fishing Rules

6

• »	Sjatf Ojwrfntffll tf		

0Health Shellfish Safety Information

You are here: DOH Home » EH Home » OSWP » Biotoxin

Search I Employees

Only the	of beaches are shown on these maps.

For	visit Washington State Department of Fish and Wildlife.

Marine Biotoxin Closure Zones

lilt Closed for clams, geoduck, scallops, mussels, oysters,
snails and other invertebrates.

Marine Biotoxin status updated, 10/31/2012 3:39:03 PM

Public Beaches

Closed

Area closed due to pollution.

Tide Predictions

Not all beaches are mapped,

call your local health department/district

http://www.doh.wa.aov/lhimap/lhimap.htm
or (360)236-3330

Click on a Beach for detailed info.

I

Du

Dash^P oil

Browns Point
Browns P oint

mis

-a-tSi am

Commencement Bay

T aeom a



Inside Pierce Cou

O	I j_L_—f-7T	,

10/31/2012 3:3^:06 PM

Jrty

Start Over

Emergency Closures Due to
Marine Biotoxins - Text Version

County Beach List
Recreational Program
Fact Sheets

Citation:

http://ww4.doh.wa.gov/scripts/esrimap.dH?name=BIOVIEW&Left=1054000&Bottom=620016&Right=1180000&T
op=791984&Step=2&click.x=255&click.y= 174

Page 8

OU 01 Attachment 5

-------
ATTTACHMENT KK-11. 2012 Guide to SAFE Shellfish Harvesting

2012 Guide to SAFE Shellfish Harvesting
in Pierce County - Mussels, Clams, and Oysters
(Washington DOH and TPCHD)

Source: http://www.tpchd.org/files/library/065d4e306417d533.pdf

Page 1

OU 01 Attachment 5

-------
rf*./v v-

¦nfA > .

01 Attachment 5
ytkjVv .*,• '

ATTTACHMENT KK-11 2012 Guide to SAFE Shellfish Harvesting

Additional Contact Information

Shellfish: A Natural Resource

Healthy People in Healthy Communities

www.tpchd.org

r *

2012 Guide to SAFE
Shellfish Harvesting In
Pierce County

Mussels
Clams

Oysters

Health and Safety Concerns

Many Pierce County beaches are safe for shellfish
harvesting and shellfish are usually safe to eat.
Shellfish from some beaches are not safe to eat
due to pollution and natural poisons (biotoxins),
bacteria, viruses or chemicals in the water that
can be dangerous. Shellfish feed by filtering
water and can accumulate contaminants. Pay
attention to where and when you gather shellfish
and know where the danger areas are located.
It is important to check both the Washington
Department of Fish & Wildlife website and
Washington State Department of Health website
for the latest closures.

Shellfish may have biotoxins, chemicals,
bacteria and viruses that are not visible.
--Saltwater biotoxins include Paralytic Shellfish
Poison (PSP), Amnesic Shellfish Poison (ASP)
and Diarrhetic Shellfish Poisoning (DSP).
-Eating shellfish with high concentrations of
biotoxins can kill you.

Cooking does not destroy the PSP, ASP or DSP
toxin.

Washing and cooking shellfish will not remove
chemicals or biotoxins, but may kill bacteria
and viruses.

Harvested shellfish spoil quickly. Keep iced or
refrigerated. Cook 4-6 minutes prior to eating.

Call 911 right away if you notice any of these

symptoms after eating shellfish:

-numb tongue or lips

-tingling in the toes of fingertips

-loss of muscular control

-difficulty breathing, nausea, vomiting,

abdominal pain and diarrhea

Page 2

Tacoma-Pierce County Health Department

(253) 798-3767
www.tpchd.org/shellfish

Diarrhetic Shellfish and Paralytic Shellfish
Poisoning Hotline

(800) 562-5632

www.doh.wa.gov/ehp/sf/biotoxin.htm
www.doh.wa.gov/shellfishsafety.htm

Washington Department of Fish & Wildlife

Open beaches, emergency closures due to

conservation concerns and rule changes

information

(866) 880-5431, press 2

Recreational license information

(360) 902-2464

wdfw.wa.gov/fishing/shellfish.html

Washington Department of Health

For beach closures due to health concerns

(360) 236-3330

www.doh.wa.gov/ehp/sf/

To report possible shellfish related illness

send an email to:

sf.illness@doh.wa.gov

Washington State Parks Boating Programs

(360) 902-8555
parks.wa.gov/boating

f ^ Washington State Department of

ft Health

Division of Environmental Health
Office ofSfieftfish and Water Protection

Tacoma - Pierce County

•' \ Health Department

W Healthy People in Healthy Communities

-------
ATTTACHMENT KK-11. 2012 Guide to SAFE Shellfish Harvesting

General Rules

/

Recreational Shellfish Harvesting Beaches

Classifications by Washington Department of Health and Washington Department of Fish & Wildlife

A Shellfish License is required to harvest on a public
beach. Licenses are available at many sporting goods
stores.

Wear the license so it can be seen while
digging.

There are limits to the number and kind of
shellfish you can gather.

--check with Washington Department of Fish
& Wildlife for the latest information about
rules and fishing licenses.

Be safe around and on the water.

--wear life jackets at all times.

-Puget Sound water can be colder than you
think and you can lose your ability to swim in
as little as ten minutes in cold water.

Many Pierce County beaches are privately
owned.

-do not remove shellfish from private
beaches without permission from the owner,
-remain within public beach boundaries
when harvesting.

Call (253) 798-3767 or visit www.tpchd.
org/shellfish (Recreational Shellfish Beach
Closures) to check if the beach is open and
safe for shellfish harvesting.

A beach may be closed at any time to prevent
over-harvesting. For updated conservation
closures, please call (866) 880-5431.

Unclassified Beaches

Use extreme caution when harvesting shellfish from
these areas where water is not tested.

•	Fox Island Bridge

•	Sunrise Beach County Park

•	The Narrows

Page 3

Open Beaches

Cutts Island: Boat access only, clams and oysters
open all year.

Joemma Beach State Park: Clams and oysters,
open all year.

Kopachuck State Park: Clams, June 1-July 31 and
oysters, March 1-July 31.

Penrose Point State Park: Clams and oysters,
March 1-May 15.

Vaughn Bay Sandspit (DNR-18): Boat access only,
clams and oysters, open all year.

Windy Bluff: Boat access only, clams and oysters,
open all year.

Wyckoff Shoal (DNR-39): Boat access only, clams
and oysters, open all year.

Closed Beaches

•	Brown's Point Lighthouse Park: Health restrictions

•	Dash Point County Park: Health restrictions

•	Fort Lewis (Solo Point): Health restrictions due to
proximity to sewage outfall.

•	North Fort Lewis: Health restrictions due to
proximity to sewage oufall.

•	Purdy Sandspit County Park: Conservation closure

•	South Gordon Point (Salter's Point): Health
restrictions due to proximity to sewage outfall.

•	Taylor Bay: Health restrictions due to proximity to
sewage outfall.

OU 01 Attachment 5

Sandspit County Park,

Unclassified

¦VVindy Bluff ,
¦Vaughn Bay Sandspit

:ounty4^rk

¦Cutts Island State Pan^
¦Kopachuck State Park

rOwn's Point Lighthouse Park

AFoxlsIa n d J3 r jdg<

J ¦Penrose State Park"vp

Narro'

Tacoma

¦Wyckoff Shoal

p^|oemma Beach State Park

McNeil
Island

•Taylor Bay

•South Gordon Point (Salter's Pojfit)
^North Fort Lewis

/ Anderson
Island

(•Fort Lewis (Sojo^'oint)

Beach Status

• Closed
¦ Open

Dash Point County Park

-------
ATTACHMENT KK-12. Lower Duwamish Waterway congener and total PCB tissue comparison

Attachment KK-12
Lower Duwamish Waterway congener and total PCB tissue comparison

Page 1

OU 01 Attachment 5

-------
ATTACHMENT KK-12. Lower Duwamish Waterway congener and total PCB tissue comparison

Table 4-4. Coplanar PCB congener concentrations in fish and crab composite samples, including both wet weight and lipid-normalized total PCB concentrations (PCB congener sum)

Coplanar PCB Congener Concentrations (ng/kg ww)

Total PCB
Concentration'1

Lipid

Lipid-Normalized total
PCB Concentration

Sample ID

PCB-077

PCB-081

PCB-105

PCB-114

PCB-118

PCB-123

PCB-126

PCB-156

PCB-157

PCB-167

PCB-169

PCB-189

(|jg/kg ww)

(%)

(mg/kg lipid)

English sole - whole body































LDW-07-T1 -M-ES-WB-comp3

291

29.1

12,800

855

44,800

702

77.7

8,130 C

C156

4,470

4.46

635

1,165 J

6.85

17.01

LDW-07-T1 -M-ES-WB-comp5

181

18.0

9,610

727

31,100

480

41.7

5,000 C

C156

2,010

2.18

408

774 J

3.83

20.2

LDW-07-T2-A-ES-WB-comp2

533

48.0

19,900

1,570

75,400

1,230

113

11,600 C

C156

5,320

5.66

625

1,632 J

9.00

18.13

LDW-07-T2-A-ES-WB-comp4

) 420

37.4

21,800

1,270

68,800

1,200

110

11,300 C

C156

4,910

5.50

762

1,603 J

8.07

19.86

A/-07-T3-M-ES-WB-comp4

1,030

87.3

37,400 J

2,700

136,000

2,090

184

20,500 C

C156

8,870

7.95

1,270 :

2,928 J

10.9

26.86 I

LDW-07-T3-M-ES-WB-comp6

255

20.4

9,030

708

38,900

537

50.7

6,820 C

C156

3,300

3.44

553

1,032 J

4.40

23.45

Shiner surfperch - whole body































LDW-07-T1-B-SS-WB-comp1

I 588

48.7

14,500

1,110

45,600

720

96.1

9,750 C

C156

4,140

4.16

835

974 J

2.20

44.3 )

LDW-07-T1-C-SS-WB-comp1

449

41.9

7,830

548

24,600

465

59.1

5,840 C

C156

2,570

1.75

376

504.1 J

4.94

10.2

LDW-07-T2-B-SS-WB-comp1

314

26.8

5,050

371

18,200

342

45.2

4,180 C

C156

1,890

2.19 J

304

401.6 J

4.40

9.127

LDW-07-T2-E-SS-WB-comp1

431

31.1

10,500

810

35,400

590

61.5

6,820 C

C156

2,960

2.26

500

648.3 J

4.46

14.54

LDW-07-T3-E-SS-WB-comp1

I 230

20.0

6,770

538

25,200

406

62.9

8,420 C

C156

4,330

4.88

1,140

1,103 J

3.43

32.16 !

LDW-07-T3-F-SS-WB-comp1

501

39.1

17,000

1,360

53,900

889

91.2

14,100 C

C156

5,860

5.11

1,980 :

2,462 J

4.94

49.84 I

Dungeness crab - edible meat





























|

A/-07-T1 -M-DC-EM-comp1

! 85.0

5.40 U

835

56.9

2,350

40.9

7.39 U

357 C

C156

150

3.98 U

23.3

49.45 J

0.440

11.24 !

LDW-07-T3-M-DC-EM-comp3

I 78.3

5.21 U

1,190

82.0

3,760

47.1

9.89 UJ

583 C

C156

226

5.31 U

38.2

86.2 J

0.531

i 16.23 i

Dungeness crab - hepatopancreas































LDW-07-T1-M-DC-HP-comp1

) 688

41.4

9,470

606

26,800

494

72.4

4,740 C

C156

1,980

4.67

372

612.1 J

3.72

1 16.45 <

Slender crab - edible meat































LDW-07-T1 -M-SC-EM-comp2

137

8.20

1,830

119

5,540

98.4

10.1

1,000 C

C156

423

6.56 U

51.2

112 J

0.428

26.17 |

LDW-07-T2-M-SC-EM-comp1

j 129

7.14

1,620

111

4,530

71.8

8.68

662 C

C156

267

4.49 U

33.4

86.2 J

0.592

14.56 (

a Total PCBs are calculated as the sum of all 209 individual PCB congeners. The method for calculating total PCBs is presented in Appendix D.

b Lipid-normalized concentrations (in units of mg/kg lipid) represent the wet-weight total PCB concentration (calculated as the sum or all 209 individual PCB congeners in units of mg/kg ww) divided by the decimal fraction corresponding to the percent
lipid (e.g., 2.0% lipid = 0.02).

C - concentration represents a co-elution

C156 - PCB-156 and PCB-157 co-elute; the combined concentration is presented as the concentration of PCB-156

ID - identification

J - estimated concentration

PCB - polychlorinated biphenyl

U - not detected at the reporting limit shown

ww-wet weight

£ower /Juwamish l^^iterway ^roup

PPage;

2007 Fish/Crab/Clam Data Report
FINAL	March 5, 2009

Page 41

p&4r8l %eatt,e ' City of Seattle / King County / The Boeing Company	Qu Q1 attachment 5

-------
OU 20, 22,19 Attachment 1 - List of Documents Reviewed

-------
OUs 20, 22, and 19 Attachment 1 - List of Documents Reviewed

Asarco Consulting, Inc. (Asarco). 2004. Final Design Report for Sediment Dredging: Marine Sediments
and Groundwater. Commencement Bay Nearshore/Tideflats Superfund Site. Asarco
Sediments/Groundwater Operable Unit 06. Town ofRuston and City ofTacoma, Washington. June 2004.

CH2M Hill. 2010a. Technical Memorandum. Asarco Yacht Basin Remedial Design Evaluation. February
4, 2010.

CH2M Hill. 2010b. Technical Memorandum. Tacoma Yacht Basin Sediment Disposal - Onsite and Off site
Cost Comparison. December 7, 2010.

CH2M Hill. 2010c. Technical Memorandum. Tacoma Yacht Basin Sediment Disposal -Hybrid Cost
Estimate. December 17, 2010.

CH2M Hill. 2013a. Technical Memorandum. Asarco Slag Peninsula - Habitat Basin Repair Study. June
24,2013.

CH2M Hill. 2013b. Technical Memorandum. ASARCO Slag Peninsula Armoring Remedial Design -
Preliminary Design Analysis. June 24, 2013.

Ecology. Undated. "Arsenic in Soil Database." Viewed on 4/10/14 at:

https://fortress.wa.gov/ecy/areispublic/Default.aspx

U.S. Environmental Protection Agency (EPA). 1993. EPA Superfund Record of Decision:

Commencement Bay, Near Shore/Tide Flats. EPA ID: WAD980726368. OU 22. Pierce County, WA.
EPA/ROD/R10-93/062. June 16, 1993. Available at:

http://cumulis.epa.gov/superrods/index.cfm?fuseaction=main. search

EPA. 1995. EPA Superfund Record ofDecision: Commencement Bay, Near Shore/Tide Flats. EPAID:
WAD980726368. OU20. Pierce County, WA. EPA/ROD/R10-95/122. March 24, 1995. Available at:

http://cumulis.epa.gov/superrods/index.cfm?fuseaction=main. search

EPA. 2000. EPA Superfund Record of Decision: Commencement Bay, Near Shore/Tide Flats. EPA ID:
WAD980726368. OU 19. Pierce County, WA. EPA/ROD/R10-00/051. July 14, 2000. Available at:

http://cumulis.epa.gov/superrods/index.cfm?fuseaction=main. search

EPA. 2006a. Final Statement of Work for Remedial Design and Remedial Action. Commencement Bay
Nearshore/Tideflats Superfund Site. Operable Unit 02 - Asarco Tacoma Smelter Facility and Slag
Peninsula and Operable Unit 06 - Marine Sediments and Groundwater. Ruston and Tacoma,

Washington. July 11, 2006. Available under Key Technical Documents at:

http://yosemite.epa.gov/rl0/CLEANUP.NSF/0e2495c305581dab8825777a007dd9be/c73cl06fdl87elb6882569150064ad86IOpe
nDocument

EPA. 2006b. "Environmental Fact Sheet. ASARCO Superfund Site, Ruston/Tacoma, Washington."

March 2006. Viewed on 4/9/14 at:

http://yosemite.epa.gov/R10/CLEANUP.NSF/9f3c21896330b4898825687b007a0f33/c73cl06fdl87elb6882569150064ad86/$FIL
E/Asarco %20fs%203-l 3-06.pdf

EPA. 2009. Five-Year Review Report. Third Five-Year Review Report for Commencement Bay
Nearshore/Tideflats Superfund Site, Tacoma, Washington. Prepared by U.S. Environmental Protection
Agency (EPA), Region 10. December 23, 2009.

1

-------
OUs 20, 22, and 19 Attachment 1 - List of Documents Reviewed

EPA. 201 la. "Superfund Program Implements the Recovery Act. Commencement Bay/Ruston-North
Tacoma." Last updated December 15, 2011. Viewed on 4/28/14 at:

http://www.epa.gov/superfund/eparecovery/commencement_bay.html

EPA. 201 lb. Evaluation of the Remediation Goal for Arsenic at the Ruston/North Tacoma Study Area
Operable Unit, Commencement Bay Nearshore/Tideflats Superfund Site. January 27, 2011.

EPA. 2013. Remedial Action Completion Report. Ruston/North Tacoma Residential Remediation.
Commencement Bay Nearshore/Tideflats Superfund Site. Ruston/North Tacoma Study Area. 2013.

EPA. 2014. "Asarco Smelter - Ruston." Last updated May 8, 2014. Study Area Zones map available
under "Photos and Maps" at:

http://yosemite.epa.gov/R10/CLEANUP.NSF/0e2495c305581dab8825777a007dd9be/c73cl06fdl87elb6882569150064ad86IOpe
nDocument

Griffiths. 2014. Email communication on 4/29/14 from Evan Griffiths (CH2M Hill) to Veronica Henzi
(USACE). Subject: Re: TM on Slag Peninsula Armoring.

Hydrometrics. 2012. Submission of Fall 2012 Riprap Cap Placement Construction RFP and 2012
Biological Assessment Report in relation to Fall 2012 Remedial Action Work Plan - Riprap Cap
Placement Project. Operable Unit No. 6. Point Ruston (Tacoma Smelter Site) [sic]. Prepared for Point
Ruston LLC. September 27, 2012.

Hydrometrics. 2013a. Volume I. Operation, Maintenance and Monitoring Plan for Smelter Site Cap, Slag
Peninsula Cap, Shoreline Armoring and Utilities. Prepared for Point Ruston LLC. Revised May 2013.

Hydrometrics. 2013b. Point Ruston. Development and Occupancy Plan. Prepared for Point Ruston LLC.
Revised February 2013.

Hydrometrics 2013c. Point Ruston. Construction Management Plan. Phase 2 Remedial Action.
Commencement Bay Nearshore/Tideflats Superfund Site. Operable Unit 02 - Tacoma Smelter Facility
and Slag Peninsula. Operable Unit 06 - Marine Sediments and Groundwater. Ruston and Tacoma,
Washington. Prepared for Point Ruston LLC. October 2013.

Hydrometrics. 2013d. Point Ruston, LLC. Final Construction Report. Sediment Cap Phase. Prepared for
Point Ruston LLC. March 2013.

Hydrometrics. 2013e. Point Ruston Temporary Impermeable Cap and Site Wide Storm Water
Construction Management Plan. Commencement Bay Nearshore/Tideflats Superfund Site. Operable Unit
02 - Tacoma Smelter Facility and Slag Peninsula. Operable Unit 06 - Marine Sediments and
Groundwater. Ruston and Tacoma, Washington. Prepared for Point Ruston LLC. March 2013.

Parametrix. 2011. ASARCO Tacoma Smelter Site. Tacoma, Washington. Pier and Piling Removal.
Construction Completion Report. Prepared for Washington State Department of Natural Resources. June
2011.

Pierce County. 2014. "PublicGIS." Viewed on 4/15/14 at: http://matterhorn3.co.pierce.wa.us/publicgis/

Point Ruston, LLC. 2014. "Point Ruston." Viewed on 4/24/14 at: http .//www.pointruston. com/

Rochlin. 2014. Phone communication on 4/24/14 between Veronica Henzi (USACE) and Kevin Rochlin
(EPA). Subject: Outstanding issues from the 2009 FYR.

2

-------
OUs 20, 22, and 19 Attachment 1 - List of Documents Reviewed

United States Bankruptcy Court for the Southern District of Texas, Corpus Christi Division (USBC).
2009a. Amended Settlement Agreement Regarding Miscellaneous Federal and State Environmental Sites.
Case 05-21207. Document 10540. Filed in TXSB on March 13, 2009. Available at:

http://www2.epa.gov/enforcement/consent-decree-5-settlement-agreements-associated-2009-asarco-bankruptcy

USBC. 2009b. Amended Settlement Agreement and Consent Decree Regarding Residual Environmental
Claims for the Coeur d'Alene, Idaho, Omaha, Nebraska, and Tacoma, Washington Environmental Sites.
Case 05-21207. Document 10541. Filed in TXSB on March 13, 2009. Available at:

http://www2.epa.gov/enforcement/consent-decree-5-settlement-agreements-associated-2009-asarco-bankruptcy

United States District Court for the Western District of Washington (USDC). 2006. Second Amendment to
Asarco Tacoma Smelter Consent Decree in the matter of United States v. ASARCO Incorporated, relating
to the Asarco Tacoma Smelter Site, Operable Units 02 and 06 of the Commencement Bay Nearshore
Tideflats Superfund Site. Civil Action No C91-5528 B. June 29, 2006. Available at:

http://yosemite.epa.gov/rl0/CLEANUP.NSF/6ea33b02338c3a5e882567ca005d382f/c73cl06fdl87elb6882569150064ad86/$FIL
EZASARCO-2nd.pdf

3

-------
OU 20, 22,19 Attachment 2 - Site Inspection Checklist for OU 20 and OU 22

-------
OU 20, 22,19 Attachment 2 - Site Inspection Checklist for OU 20 and OU 22

Five-Year Review Site inspection Checklist

I. SITE INFORMATION

Site name: Asarco Smelter/Point Ruston

Date of inspection: 5/9/14

Location: Ruston/Tacoma WA

EPA ID:

Agency, office, or company leading the five-year
review: Air monitoring, dust control.

Weather/temperature Cloudy/55 degn

Remedy Includes: (Check all that apply)
©Landfill cover/containment
©Access controls
©Institutional controls
O Groundwater pump and treatment
[MlSurface water collection and treatment
~Other:

Air monitoring, dust control.

~ Monitored natural attenuation

~Groundwater containment
~Vertical barrier walls

Attachments: ~ Inspection team roster attached

~ Site map attached

II. INTERVIEWS (Check all that apply)

1. O&M site manager N/A

Name	Title

Interviewed ~ at site ~ at office ~ by phone Phone no. 	

Problems, suggestions; ~ Report attached	

Date

2. O&M staff N/A

Name	Title

Interviewed ~ at site flat office ~ by phone Phone no. 	

Problems, suggestions; ~ Report attached	

Date

1

-------
OU 20, 22,19 Attachment 2 - Site Inspection Checklist for OU 20 and OU 22

3.

Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response
office, police department, office of public health or environmental health, zoning office, recorder of
deeds, or other city and county offices, etc.) Fill in all that apply.

Agency
Contact

Name Title Date Phone no.

Problems; suggestions; [~~| Report attached

Agency
Contact

Name Title Date Phone no.

Problems; suggestions; [~~| Report attached

Agency
Contact

Name Title Date Phone no.

Problems; suggestions; [~~| Report attached

Agency
Contact

Name Title Date Phone no.

Problems; suggestions; [~~| Report attached

4.

Other interviews (optional) ~ Report attached.



III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

1.

O&M Documents

B O&M manual [fi] Readily available [fi] Up to date ~ N/A
H As-built drawings ©Readily available © Up to date ~ N/A
© Maintenance logs © Readily available © Up to date ~ N/A

Remarks

2.

Site-Specific Health and Safety Plan © Readily available © Up to date ~ N/A
© Contingency plan/emergency response plan ~ Readily available ~ Up to date ~ N/A
Remarks Health and safety training requirements and schedules are recorded on site id badges.

2

-------
OU 20, 22,19 Attachment 2 - Site Inspection Checklist for OU 20 and OU 22

3.

(MM and OSHA Training Records

~ Readily available

~ Up to date

Hn/a



Remarks qercla permit exemption, permits not required. Effluent records are provided in

monthly progress reports. Real time air monitoring records are provided weekly to the

4.

Permits and Service Agreements

~	Air discharge permit

~	Effluent discharge

~	Waste disposal, POTW
IB] Other permits

~	Readily available

~	Readily available

~	Readily available
["I Readily available

~	Up to date
~Up to date

~	Up to date

~	Up to date

~ N/A

¦	N/A

1 N/A

¦	N/A



Remarks CERCLA permit exemption, permits not required. Effluent records are provided in

monthly progress reports. Real time air monitoring records are provided weekly to the

cr o a . <"> ¦ < ¦* <"> i- . "ci r <		 £3

5.

Gas Generation Records
Remarks

H] Readily available

~ Up to date

¦ N/A

6.

Settlenient Monument Records
Remarks

~ Readily available

~ Up to date

H N/A

7.

Groundwater Monitoring Records
Remarks

~ Readily available

~ Up to date

~n/a

8.

Leachate Extraction Records

~ Readily available

~ Up to date

~ n/a



Remarks Leachate records from the onsite landfill are provided





9.

Discharge Compliance Records

~	Air

~	Water (effluent)

Remarks

H] Readily available
~ Readily available

~ Up to date
O Up to date

¦ N/A

~ n/a

10.

Daily Access/Security Logs
Remarks

[H]Rcadilv available

~ Up to date

~ N/A

3

-------
OU 20, 22,19 Attachment 2 - Site Inspection Checklist for OU 20 and OU 22

IV. O&M COSTS

1. O&M Organization

~	State in-housc
B PRP in-hou.se
~Federal Facility iu-housc

~	Other

~	Contractor for State
B Contractor for PRP

~	Contractor for Federal Facility

2.

O&M Cost Records
~ Readily available ~ Up to date
Original O&M cost estimate	

~ Funding mechanism/agreement in place

		~ Breakdown attached

Total annual cost by year for review period if available

From



To





~Breakdown attached



Date



Date

Total cost



From



To





~ Breakdown attached



Date



Date

Total cost



From



To





~ Breakdown attached



Date



Date

Total cost



From



To





~ Breakdown attached



Date



Date

Total cost



From



To





~ Breakdown attached



Date



Date

Total cost



3. Unanticipated or Unusually High O&M Costs During Review Period

Describe costs and reasons:

No O&M Costs provided. The number of joints on phase 1 of the project between different cap
materials is going to result in high maintenance costs.

V. ACCESS AND INSTITUTIONAL CONTROLS ¦ Applicable ~ N/A

A. Fencing

1. Fencing damaged	~ Location sliown on site map ~Gates secured ~ N/A

Remarks exclusion zones as well as non occupied site entrances are fenced.

B. Other Access Restrictions

1. Signs and other security measures	~ Location sliown on site map ~ N/A

Remarks ^ exC|USjon Zones are signed.

4

-------
OU 20, 22,19 Attachment 2 - Site Inspection Checklist for OU 20 and OU 22

c.

Institutional Controls (ICs)





1.

Implementation and enforcement

Site conditions imply ICs not properly implemented

Site conditions imply ICs not being fully enforced

Type of monitoring (e.#., self-reporting, drive by)

El Yes O No
~ Yes ~ No

¦ N/A
H N/A



Frequency







Responsible party/agency







Contact







Name Title

Date Phone no.



Reporting is up-to-date

Reports arc verified by the lead agency

~	Yes ~ No

~	Yes ~ No

H N/A
¦ N/A



Specific requirements in deed or decision documents have been met [¦] Yes Q No
Violations have been reported d Yes O No
Other problems or suggestions: ~ Report attached

~ n/a

H N/A

2.

Adequacy [¦] ICs arc adequate

Remarks

~ ICs arc inadequate

~ N/A

D.

General





1.

Vandalism/trespassing ~ Location shown on site map

Remarks 24 hour site security. Vandalism has occurred,
have been repaired.

~ No vandalism evident
Issues reported to EPA.

Any problems

2.

Land use changes on site [¦] N/A
Remarks





3.

Land use changes off site [¦] N/A
Remarks





VI. GENERAL SITE CONDITIONS

A.

Roads H] Applicable ~ N/A





1.

Roads damaged ~ Location shown on site map
Remarks

H] Roads adequate

~ N/A

5

-------
OU 20, 22,19 Attachment 2 - Site Inspection Checklist for OU 20 and OU 22

B.

Other Site Conditions





Remarks





VII. LANDFILL COVERS ¦ Applicable

~ N/A

A.

Landfill Surface





1.

Settlement (Low spots) ~ Location shown on site map
A real extent Depth

B Settlement not evident



Remarks





2.

Cracks
Lengths

~ Location shown on site map
Widths Depths

| Cracking not evident



Remarks





3.

Erosion
A real extent

~ Location shown on site map
Depth

[¦] Erosion not evident



Remarks





4.

Holes

A real extent

~ Location shown on site map
Depth

H] Holes not evident



Remarks





5.

Vegetative Cover

H Grass [fi] Cover properly established



Remarks

~ No signs of stress ~ Trees/Shrubs (indicate size and locations on a diagram)

6.

Alternative Cover (armored rock, concrete, etc.)

Remarks

¦ N/A

7.

Bulges
A real extent

~ Location shown on site map

Height

H] Bulges not evident



Remarks





6

-------
OU 20, 22,19 Attachment 2 - Site Inspection Checklist for OU 20 and OU 22

8.

Wet Areas/Water Damage

~	Wet areas

~	Ponding
El Seeps

~	Soft subgrade
Remarks

HWet areas/water damage not evident
n Location shown on site map A real extent
["I Location shown on site map A real extent
n Location shown on site map A real extent
r~|Location shown on site map A real extent

9.

Slope Instability
A real extent
Remarks

~ Slides

~ Location shown on site map [fi] No evidence of slope instability

B.

Benches

¦ N/A

~ Applicable



(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope
in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined
channel.)

1.

Flows Bypass Bench
Remarks



~ Location shown on site map [fi] N/A or okay

2.

Bench Breached
Remarks



~ Location shown on site map | N/A or okay

3.

Bench Overtopped
Remarks



~ Location shown on site map | N/A or okay

C.

Letdown Channels ~ Applicable [¦] N/A

(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)

1.

Settlement

A real extent

~ Location shown on site map [fi] No evidence of settlement
Depth



Remarks





2.

Material Degradation ~ Location shown on site map [fi]No evidence of degradation
Material type Area! extent



Remarks





3.

Erosion
A real extent

~ Location shown on site map [¦] No evidence of erosion

Depth



Remarks





7

-------
OU 20, 22,19 Attachment 2 - Site Inspection Checklist for OU 20 and OU 22

4.

Undercutting ~ Location shown on site map [¦] No evidence of undercutting
A real extent Depth



Remarks





5.

Obstructions Type IB] No obstructions [~~| Location shown on site map
A real extent Si/c



Remarks





6.

Excessive Vegetative Growth Type

H] No evidence of excessive growth

~ Vegetation in channels docs not obstruct flow

["I Location shown on site map A real extent

Remarks



D.

Cover Penetrations ~ Applicable [¦] N/A



1.

Gas Vents ~ N/A ~ Active ~ Passive ~ Properly secured/locked ~ Functioning
~ Routinely sampled ~ Good condition ~ Evidence of leakage at penetration

Remarks

2.

Gas Monitoring Probes

~	Properly secured/locked ~ Functioning

~	Evidence of leakage at penetration

Remarks

~	Routinely sampled

~	Needs Maintenance

~ Good condition

¦ N/A

3.

Monitoring Wells (within surface area of landfill)

B Properly secured/locked H] Functioning
~ Evidence of leakage at penetration

Remarks

~	Routinely sampled

~	Needs Maintenance

~	Good condition

~	N/A

4.

Leachate Extraction Wells

~ Properly secured/locked ~ Functioning
O Evidence of leakage at penetration

Remarks

~	Routinely sampled

~	Needs Maintenance

~ Good condition
¦ N/A

5.

Settlement Monuments ~ Located

Remarks

~ Routinely surveyed

Hn/a

8

-------
OU 20, 22,19 Attachment 2 - Site Inspection Checklist for OU 20 and OU 22

E.

Gas Collection and Treatment

~ Applicable [fi]N/A



1.

Gas Treatment Facilities

~	Flaring ~ Thermal destruction ~ Collection for reuse

~	Good condition ~ Needs Maintenance

Remarks

2.

Gas Collection Wells, Manifolds and Piping
~ Good condition ~ Needs Maintenance

Remarks



3.

Gas Monitoring Facilities (e.g
~ Good condition

Remarks

gas monitoring of adjacent homes or buildings)
~ Needs Maintenance ~ N/A

F.

Cover Drainage Layer

~ Applicable

H N/A

1.

Outlet Pipes Inspected
Remarks

~ Functioning

~ n/a

2.

Outlet Rock Inspected
Remarks

~ Functioning

~ N/A

G.

Detention/Sedimentation Ponds

~ Applicable

¦ N/A

1.

Siltation ~ N/A

A real extent

~ Siltation not evident
Depth





Remarks





2.

Erosion A real extent

Depth

n Erosion not evident



Remarks





3.

Outlet Works ~ Functioning ~ N/A

Remarks



4.

Dam ~ Functioning ~ N/A

Remarks



9

-------
OU 20, 22,19 Attachment 2 - Site Inspection Checklist for OU 20 and OU 22

EL Retaining Walls

[¦] Applicable ~ N/A



1.

Deformations
Horizontal displacement

~ Location shown on site map [¦] Deformation not evident
Vertical displacement



Rotational displacement
Remarks





2.

Degradation
Remarks

~ Location shown on site map

0 Degradation not evident

I. Perimeter Ditches/Off-Site Discharge 0 Applicable

~ N/A

1.

Siltation

A real extent
Remarks

O Location shown on site map
Depth

| Siltation not evident

2.

Vegetative Growth

A real extent
Remarks

~	Location shown on site map 0 N/A

~	Vegetation does not impede flow

Type

3.

Erosion
A real extent
Remarks

~ Location shown on site map
Depth

H] Erosion not evident

4.

Discharge Structure
Remarks

0 Functioning ~ N/A





VIII. VERTICAL BARRIER WALLS

0 Applicable 0 N/A

1.

Settlement

A real extent
Remarks

~ Location shown on site map
Depth

~ Settlement not evident

2.

Performance Monitoring Type of monitoring
~ Performance not monitored ~ Evidence of breaching
Frequency Head differential



Remarks





IX. GROUNDWATER/SURFACE WATER REMEDIES ~ Applicable 0N/A

A. Groundwater Extraction Wells, Pumps, and Pipelines

~ Applicable ~ N/A

1.

Pumps, Wellhead Plumbing, and Electrical

~ Good condition ~ All required wells properly operating ~ Needs Maintenance ~ N/A
Remarks

10

-------
OU 20, 22,19 Attachment 2 - Site Inspection Checklist for OU 20 and OU 22

2.

Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances

~ Good condition ~ Needs Maintenance

Remarks

3.

Spare Parts and Equipment

~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided

Remarks

B. Surface Water Collection Structures, Pumps, and Pipelines ~ Applicable ~ N/A

1.

Collection Structures, Pumps, and Electrical

H Good condition ~ Needs Maintenance
Remarks

2.

Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances

0 Good condition ~ Needs Maintenance

Remarks

3.

Spare Parts and Equipment

~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided

Remarks

C.

Treatnient System ~ Applicable [fi] N/A

1.

Treatnient Train (Check components that apply)

~	Metals removal ~ Oil/water separation ~ Bioremediation

~	Air stripping ~ Carbon adsorbers
n Filters

n Additive chelation agent, flocculent)
n Others

O Good condition ~ Needs Maintenance

~	Sampling ports properly marked and functional

~	Sampling/maintenance log displayed and up to date

~	Equipment properly identified

["I Quantity of groundwater treated annuallv
[•H Quantity of surface water treated annuallv

Remarks

2.

Electrical Enclosures and Panels (properly rated and functional)
0N/A g Good condition 0 Needs Maintenance

Remarks

11

-------
OU 20, 22,19 Attachment 2 - Site Inspection Checklist for OU 20 and OU 22

3.

Tanks, Vaults, Storage Vessels

~N/A [¦] Good condition ~ Proper secondary containment ~ Needs Maintenance

Remarks

4.

Discharge Structure and Appurtenances
~ N/A [fi] Good condition ~ Needs Maintenance

Remarks

5.

Treatment BuiWing(s)

H N/A ~ Good condition (esp. roof and doorways) ~ Needs repair
~ Chemicals and equipment properly stored

Remarks

6.

Monitoring Wells (pump and treatment remedy)

B Properly secured/locked ~ Functioning ~ Routinely sampled ~Good condition
~ All required wells located ~ Needs Maintenance ~ N/A

Remarks

D. Monitoring Data

1.

Monitoring Data

~ Is routinely submitted on time ~ Is of acceptable quality

2.

Monitoring data suggests:

~ Groundwater plume is effectively contained ~ Contaminant concentrations are declining

D.

Monitored Natural Attenuation

1.

Monitoring Wells (natural attenuation remedy)

~ Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition
~All required wells located ONeeds Maintenance ON/A
Remarks

X. OTHER REMEDIES

If there arc remedies applied at the site which arc not covered above, attach an inspection sheet describing
the physical nature and condition of any facility associated with the remedy. An example would be soil
vapor extraction.

12

-------
OU 20, 22,19 Attachment 2 - Site Inspection Checklist for OU 20 and OU 22

XI. OVERALL OBSERVATIONS

Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume,
minimize infiltration and gas emission, etc.).

Remedy being implemented as described in the ROD and design documents. Site is occupied. Air monitoring shows dust controls are effective in preventing spread of
contamination.

B. Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protcctivcness of the remedy.

Very little O&M ongoing as site is still under construction.

C. Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs, that suggest that the protcctivcness of the remedy may be
compromised in the future.

The potential O&M of the numerous joints on site may lead to redesign of the cap in the future.

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.

N/A

13

-------
OU 3 Attachment 1 - List of Documents Reviewed

-------
OU 3 Attachment 1 - List of Documents Reviewed

City of Tacoma (and PSE). 2012-2017 Permit No. TAC-031-2011. Permit renewed 5/1/12. Issued to
Dalton, Olmsted & Fuglevand, Inc.

Dalton, Olmsted & Fuglevand, Inc. (DOF). 2002. Revised Water Quality Monitoring Program, Tacoma
Historical Coal Gasification Site. January 4, 2002.

Dalton. 2014. Email communication on 6/27/14 from Matt Dalton (DOF) to Veronica Henzi (USACE).
Subject: RE: Requesting information for Tacoma Tar Pits Five-Year Review report.

DOF. 2003. Groundwater Remediation System, Operation and Maintenance Plan, Tacoma Historical
Coal Gasification Site. Prepared for Puget Sound Energy, Inc. February 2003.

DOF. 2009a. Quarterly Report. April 1, 2009 to June 30, 2009. Permit No. 001-636-456. Tacoma
Historical Coal Gasification Site. July 14, 2009.

DOF. 2009b. Quarterly Report. July 1, 2009 to September 30, 2009. Permit No. 001-636-456. Tacoma
Historical Coal Gasification Site. October 12, 2009.

DOF. 2010a. Quarterly Report. October 1, 2009 to December 31, 2009. Permit No. 001-636-456.
Tacoma Historical Coal Gasification Site. January 14, 2010.

DOF. 2010b. Quarterly Report. January 1, 2010 to March 31, 2010. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. April 13, 2010.

DOF. 2010c. Quarterly Report. April 1, 2010 to June 30, 2010. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. July 30, 2010.

DOF. 2010d. Quarterly Report. July 1, 2010 to September 30, 2010. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. October 14, 2010.

DOF. 2010e. Water Quality Monitoring Report. March and June 2009 Sampling Events. Tacoma
Historical Coal Gasification Site. May 14, 2010.

DOF. 201 Of. Water Quality Monitoring Report. September and December 2009 Sampling Events.
Tacoma Historical Coal Gasification Site. December 21, 2010.

DOF. 2011a. Technical Memorandum. Asphalt Permeability Testing Work Plan, Detention Basins
THCGS. September 9, 2011.

DOF. 2011b. Quarterly Report. October 1, 2010 to December 31, 2010. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. January 12, 2011.

DOF. 2011c. Quarterly Report. January 1, 2011 to March 31, 2011. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. April 10, 2011.

DOF. 201 Id. Quarterly Report. April 1, 2011 to June 30, 2011. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. July 14, 2011.

DOF. 201 le. Quarterly Report. July 1, 2011 to September 30, 2011. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. October 10, 2011.

1

-------
OU 3 Attachment 1 - List of Documents Reviewed

DOF. 201 If. Water Quality Monitoring Report. March and June 2010 Sampling Events. Tacoma
Historical Coal Gasification Site. January 10, 2011.

DOF. 2012a. Technical Memorandum. Results of Trench Line Sampling, Tacoma Historical Coal
Gasification Site (Tacoma Tar Pits), Tacoma, Washington. Dec 9, 2012.

DOF. 2012b. Technical Memorandum. Results of Asphalt Permeability Testing, Detention Basins,

THCGS. May 8, 2012.

DOF. 2012c. Quarterly Report. October 1, 2011 to December 31, 2011. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. January 6, 2012.

DOF. 2012d. Quarterly Report. January 1, 2012 to March 31, 2012. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. April 12, 2012.

DOF. 2012e. Quarterly Report. April 1, 2012 to June 30, 2012. Permit No. TAC-031-2011. Tacoma
Historical Coal Gasification Site. July 13, 2012.

DOF. 2012f. Quarterly Report. July 1, 2012 to September 30, 2012. Permit No. TAC-031-2011. Tacoma
Historical Coal Gasification Site. October 12, 2012.

DOF. 2012g. Water Quality Monitoring Report. September and December 2010 Sampling Events.

Tacoma Historical Coal Gasification Site. January 9, 2012.

DOF. 2012h. Water Quality Monitoring Report. March and June 2011 Sampling Events. Tacoma
Historical Coal Gasification Site. August 7, 2012.

DOF. 2012i. Water Quality Monitoring Report. September and December 2011 Sampling Events. Tacoma
Historical Coal Gasification Site. August 13, 2012.

DOF. 2012j. Inspection and Maintenance Report. January 2010 to December 2011. Tacoma Historical
Coal Gasification Site. Prepared for PSE by DOF, Inc. May 2012.

DOF. 2013a. Technical Memorandum. New Monitoring Well Installations, Tacoma Historical Coal
Gasification Site, Tacoma, Washington. December 23, 2013.

DOF. 2013b. Quarterly Report. October 1, 2012 to December 31, 2012. Permit No. TAC-031-2011.
Tacoma Historical Coal Gasification Site. January 8, 2013.

DOF. 2013c. Quarterly Report. January 1, 2013 to March 31, 2013. Permit No. TAC-031-2011. Tacoma
Historical Coal Gasification Site. April 10, 2013.

DOF. 2013d. Quarterly Report. April 1, 2013 to June 30, 2013. Permit No. TAC-031-2011. Tacoma
Historical Coal Gasification Site. July 12, 2013.

DOF. 2013e. Quarterly Report. July 1, 2013 to September 30, 2013. Permit No. TAC-031-2011. Tacoma
Historical Coal Gasification Site. October 7, 2013.

DOF. 2013f. Water Quality Monitoring Report. March and June 2012 Sampling Events. Tacoma
Historical Coal Gasification Site. December 21, 2013.

2

-------
OU 3 Attachment 1 - List of Documents Reviewed

DOF. 2013g. Water Quality Monitoring Report. September and December 2012 Sampling Events.

Tacoma Historical Coal Gasification Site. December 27, 2013.

DOF. 2014a. Water Quality Monitoring Report. March and June 2013 Sampling Events. Tacoma
Historical Coal Gasification Site. March 28, 2014.

DOF. 2014b. Water Quality Monitoring Report. September and December 2013 Sampling Events.

Tacoma Historical Coal Gasification Site. March 31, 2014.

DOF. 2014c. Inspection and Maintenance Report. January 2012 to December 2013. Tacoma Historical
Coal Gasification Site. Prepared for PSE by DOF, Inc. January 2014.

DOF. 2014d. Quarterly Report. October 1, 2013 to December 31, 2013. Permit No. TAC-031-2011.
Tacoma Historical Coal Gasification Site. January 13, 2014.

U.S. Environmental Protection Agency (EPA). 1987. Record of Decision for Commencement Bay, Near
Shore/Tide Flats OU 23 (Tacoma Tar Pits), Pierce County, WA. December 30, 1987.

Ebasco. 1995. Inspection and Maintenance Manual, Tacoma Historical Coal Gasification Site. Prepared
for Washington Natural Gas Company. August 1995.

EPA. 1991. Explanation of Significant Differences for Commencement Bay, Near Shore/Tide Flats OU 23
(Tacoma Tar Pits), Pierce County, WA. November 1, 1991.

EPA. 1995. Explanation of Significant Differences for the Tacoma Tar Pits Operable Unit. May 9, 1995.

EPA. 2009. Five-Year Review Report. Third Five-Year Review Report for Commencement Bay
Nearshore/Tideflats Superfund Site, Tacoma, Washington. Prepared by U.S. Environmental Protection
Agency, Region 10. December 23, 2009.

EPA. 2012a. Letter dated November 13, 2012 from Tamara Langton (EPA) to Matt Dalton (DOF)
regarding EPA Comments on the Asphalt Permeability Testing Results and the Trench Line Sampling
Results, Tacoma Historical Coal Gasification Site (Tacoma Tar Pits).

3

-------
OU 3 Attachment 2 - 2014 Technical Memorandum on Water Quality and I&M

-------
OU 3 Attachment 2-2014 Technical Memorandum on Water Quality and Inspections and Maintenance

MEMORANDUM FOR RECORD

SUBJECT: Water Quality and Inspection and Maintenance Technical Memorandum for Tacoma Tar Pits
Site (OU 3), CBNT Superfund Site, Tacoma, WA, Fourth Five-Year Review

PREPARED BY: Veronica Henzi, Environmental Engineer, Seattle District, U.S. Army Corps of
Engineers

PREPARED FOR: Tamara Langton, EPA Region 10 Remedial Project Manager for Tacoma Tar Pits Site
(OU 3)

Date: September 4, 2014

1. Introduction and Purpose

This technical memorandum summarizes two sets of activities: water quality monitoring (WQM) for the
onsite groundwater extraction and treatment (GWET) system and the monitoring wells, and inspection
and maintenance (I&M) activities for the remedial components installed in 1995. Those components
include a capped engineered waste pile, storm water detention basins, and features (e.g. paving) at the
Simons Metals LLC recycling facility operating area.

1.1. Water Quality Monitoring for the GWET System and Wells

The primary objective of WQM has been to provide data to assess compliance with the performance
criteria presented in the Record of Decision (ROD; EPA 1987) for lead, PCBs, PAHs, and benzene in
surface water and groundwater. The groundwater monitoring has been completed in a number of phases
as summarized below:

•	Pre-remediation monitoring - March 1991 to December 1994

•	Post-remediation monitoring without groundwater containment - January 1995 to January 2002

•	Post-remediation monitoring with groundwater containment - March 2002 to present

Post-remediation data collected after 1994 indicated that the criteria established in the ROD for lead,
PCBs, and PAHs are being met at the site boundary in surface water and groundwater, and that the
benzene criterion has been achieved in surface water and in groundwater within the fill and deep aquifers.
However, at the end of 2013, benzene continues to exceed the ROD criterion (53fj.g/L) in the Sand
Aquifer along portions of the site boundary. The results are described in more detail below.

The purpose of the groundwater hydraulic containment system is to intercept and treat groundwater along
portions of the site boundary that contain benzene concentrations above the ROD criterion. The
containment system consists of four extraction wells. Extraction wells A and B provide water from the
"North Branch" of the system and wells C and TW-1 provide water from the "East Branch" of the system.
Groundwater from these wells is pumped to a central treatment plant where it is treated by air-stripping.
The stripped vapors are collected using vapor-phase carbon. Treated groundwater is discharged to the
City of Tacoma sanitary sewer in accordance with the requirements of Industrial Wastewater Discharge
Permit No. TAC-031-2011 (prior permit numbers were 001-636-456 and 500043736). The permit
discharge limit for benzene is 500 (ig/L, and the system can treat up to 20,000 gallons per day. The

1

-------
OU 3 Attachment 2-2014 Technical Memorandum on Water Quality and Inspections and Maintenance

current discharge permit TAC-031-2011 issued by the City of Tacoma was renewed on 5/1/12 and expires
4/30/17; it will need to be renewed during the next FYR cycle.

WQM Data Review and Analysis

The list of documents reviewed can be found at the end of this memo and are repeated in OU 3
Attachment 1 - List of Documents Reviewed. Reports reviewed included water quality monitoring reports
and discharge reports with quarterly data from March 2009 to December 2013. These reports were
prepared by Dalton, Olmsted, and Fuglevand, Inc. (DOF) on behalf of Puget Sound Energy (PSE). Other
documents reviewed included the 2012 Technical Memorandum for Results of Trench Line Sampling
(DOF 2012a) and the 2013 Technical Memorandum for New Monitoring Well Installations (DOF 2013a).

Analysis of GWETSystem

Overall, review of the water quality and discharge reports indicates that the GWET system is functioning
as intended, and that the benzene plume in the Sand Aquifer (the aquifer of concern) is generally being
contained by the extraction and treatment system (DOF 2014a; DOF 2014b). Over the review period
(2009-2013), the system operated on average 93% of the time (as calculated by this reviewer). The only
significant down-time occurred in mid-January 2010, when the programmable logic controller (PLC)
failed. For that period (January-March 2010), the system only operated 66% of the time. After extensive
trouble-shooting, the PLC unit and defective modules were replaced and the system was restarted in
February 2010. The calculated average flow rate over the review period was 9.2 gallons per minute
(gpm), with the flow rate trending downward. Until June 2010, flows were approximately 10-13 gpm.
After June 2010, flows were less than 10 gpm, varying from 6.5 to 9.3 gpm. No discussion was provided
by DOF for the decrease; however, on September 28, 2010, a new Signet 2551 Magmeter (flow meter)
was installed at the request of the City of Tacoma, which may have contributed to the change in flow
readings.

Since the containment system began operation (2002), benzene influent concentrations have generally
declined in concentration from greater than 4,000 (ig/L to approximately between 750 and 2,000 (ig/L. In
2013, flow measurements and water quality testing of influent samples indicated substantially lower flow
rates and higher benzene concentrations from the East Branch wells as compared to the North Branch
wells. These differences are consistent with the system operational history and hydrogeologic conditions.
Regarding influent concentrations from the East Branch wells, the data from 2009 to 2013 show a
decreasing trend (see Figure 1 at the end of this document) for the entire period from 2002-2013, with
concentrations ranging from approximately 3,300 (ig/L to 1,500 (ig/L. Regarding influent concentrations
from the North Branch wells, the data from 2009 to 2013 show a slight increasing trend (see also Figure
1), with concentrations ranging from approximately 480 (ig/L to 610 (ig/L. Four extraction wells are used
for the GWET system (see Figure 2): wells A and B in the North Branch area, and wells C and TW-1 in
the East Branch area.

The individual benzene effluent concentrations from the GWET system for all quarters (during the 2009-
2013 period) except for the quarter ending September 2013, were less than 1.6 (ig/L, which is less than
the ROD criterion of 53 (ig/L and significantly less than the permit discharge criterion of 500 (ig/L. Only
on August 22, 2013, did the benzene effluent concentration (64 (ig/L) exceed the ROD criterion.

However, this value was still well below the permit criterion of 500 (ig/L. Over this entire FYR period,

2

-------
OU 3 Attachment 2-2014 Technical Memorandum on Water Quality and Inspections and Maintenance

the average benzene effluent concentration was calculated by this reviewer to be 5.2 j^ig/L: omitting the
exceedance, the value drops to <1 (.ig/L.

FYR recommendation: DOF should include a figure that summarizes effluent benzene concentrations to
help assess effluent trends. Currently, only influent concentrations are provided.

Summary of Monitoring Well Location Information

For the recent monitoring program, the program consisted of 22 wells until May 2013, when two
additional wells were installed (DOF-35M and DOF-36M). The purpose of the news wells was to assess
whether benzene was migrating downgradient along the existing buried sewer line. The two new wells
were incorporated into the monitoring program starting in June 2013. See text below on "Rationale for
New Wells / Trench Line Sampling" for additional information.

In addition to these 24 wells, two other locations are sampled. The first is a surface water location
designated "SW," and the second is the Hygrade well located outside the fencing of the Northwest
Detention Center. The SW site is located within the Burlington Northern ditch located on the south side
of the Tacoma Tar Pits site, and is approximately 65 feet upstream of where flow from the ditch enters a
buried culvert. This ditch receives surface water runoff from the detention basins and surrounding areas,
and groundwater discharge from the Fill Aquifer. The SW location is sampled semi-annually in March
and September, but was not sampled in September 2013 because the ditch was dry.

The second location is the "exterior" Hygrade well located outside the Northwest Detention Center
fencing. The exterior Hygrade well is an artesian well located approximately 20 feet to the west of
Hygrade Well No. 2. This exterior well is currently sampled once every two years. Hygrade Well No. 2 is
also an artesian well and located inside the security fencing. It is currently not being sampled, presumably
due to accessibility issues. The exterior Hygrade well was sampled in September 2010 and September
2012, and is scheduled for September 2014.

See Figure 2 for locations of the monitoring wells, extraction wells, the SW sampling site, and the
Hygrade Well No. 2 for reference. It should be noted that the exterior Hygrade well currently being
sampled is NOT shown on the figure; its location has to be inferred from the location of Hygrade Well
No. 2. In addition, many other possible sampling locations (there are 44 total locations) have been
eliminated from the monitoring program over the years.

FYR recommendation: The location of the exterior Hygrade well should be added to the DOF reports
since it is part of the sampling scheme.

Rationale for New Wells / Trench Line Sampling

EPA expressed concern in 2012 that benzene may be migrating through the backfill along the pipe trench,
to the Puyallup River (i.e., moving northeast), at concentrations greater than the ROD performance
criterion. Post-remediation monitoring of groundwater conditions at the Tacoma Tar Pits has indicated
that benzene concentrations along a portion of the eastern/southeastern site boundary within the Sand
Aquifer exceed the performance criterion (53 (ig/L) specified in the ROD. Two buried sewer lines run
along the eastern site boundary.

DOF evaluated the sewer lines in 2012 and documented their results in their Results of Trench Line
Sampling Technical Memorandum (DOF 2012a). Details are summarized as follows. The sewer lines
include two parallel 48-inch diameter lines that are buried approximately 15 to 20 feet below ground

3

-------
OU 3 Attachment 2-2014 Technical Memorandum on Water Quality and Inspections and Maintenance

surface. One line was constructed in 1960 and the other in 1976. The type of backfill used to fill the pipe
trenches was not reported. Monitoring well TTP-2M is a site boundary monitoring well located west of
the sewer lines (and just inside of the Tacoma Tar Pits Site boundary) within the area of interest (See
Figure 3).

The 2012 groundwater contours indicated that the groundwater flow from TTP-2M was toward the
southwest, away from the Puyallup River. Figure 4 shows the benzene concentration pattern for the site
based on groundwater samples collected on June 27 and 28, 2012, in relation to the area of interest
associated with the sampling effort in 2012. The higher benzene concentration area was located southwest
of TTP-2M. While benzene concentrations have fluctuated in samples from TTP-2M, benzene
concentrations historically have always been substantially lower at TTP-2M than those in samples from
wells located to the southwest within the higher benzene concentration area. Concentrations in samples
from Sand Aquifer well TTP-2M were below the ROD criterion of 53 (ig/L (at 13 (ig/L as of June 27,
2012).

As part of the trench line sampling efforts, twelve push-probe samples were collected on June 19 and 20,
2012. The probe locations (PI, P2, P3, P4) can be seen on Figure 3. The analytical results ranged between
0.037 and 260 (ig/L and are summarized below.

Location	Depth (feet BGS)	Highest Benzene Concentration (jug/L)

PI	26 to 29	15

P2	26 to 29	260

P3	19 to 22	1.5

P4	26 to 29	0.2

Figures 3 and 4 show the horizontal benzene concentration pattern along the buried sewer lines. Figure 5
shows the vertical benzene profile for probes PI, P2, and P3 (and well TTP-2M). The highest benzene
concentrations were detected in the three samples collected at different depths from location P2 (110 to
260 (ig/L). while lower concentrations were detected on either side of probe P2. Concentrations were 13
to 15 (ig/L to the southwest in samples from well TTP-2M and probe PI, and 0.2 to 1.5 (ig/L to the
northeast in samples from probes P3 and P4. The 260 (ig/L was collected at the deepest sample depth for
probe P2, at 29 feet bgs.

Based on the geologic logs, the probes appeared to have been drilled into the edges of the pipeline trench.
The benzene concentration patterns suggested that some benzene has migrated within the pipeline trench
backfill. The highest-concentration sample from probe P4 (0.2 (ig/L) was lower than the highest-
concentration sample from probe P3 (1.5 (ig/L): P3 is located closer to the pipelines. These values for
probes P3 and P4 were well below the ROD criterion of 53 (ig/L.

Detected concentrations at probe P2 (110 to 260 j^ig/L) were within the range of the past higher
concentrations detected in most samples from well TTP-2M (100 to 300 j^ig/L). The data suggest that the
higher benzene concentrations periodically observed at location TTP-2M and more recently detected at
probe P2 are caused by fluctuation of the benzene plume footprint. If this is the case, it should be noted
that the recent push-probe testing program was completed at a time when the shift had apparently moved
the plume to the northeast.

4

-------
OU 3 Attachment 2-2014 Technical Memorandum on Water Quality and Inspections and Maintenance

While the groundwater flow is generally to the southwest in the pipe trench area, there is a possibility that
a localized groundwater divide may be present in the vicinity of and/or to the northeast of TTP-2M. The
position of such a feature could shift, which would also cause the plume to shift.

To further evaluate the migration of benzene along the sewer line trench and identify the possible cause of
the observed benzene fluctuations, DOF recommended that two additional Sand Aquifer wells (Well A
and Well B) be drilled and incorporated into the long-term monitoring program. These wells are now
known as DOF-35M and DOF-36M. Well A (now DOF-36M) would be located near P3. Data from Well
A (DOF-36M) would be used to assess local groundwater flow gradients and assess benzene
concentrations near the northeast corner of the site boundary, within the pipeline trench backfill. Well B
(now DOF-35M) would be located near P2. Data from DOF-35M would also be used to assess local
groundwater flow gradients and benzene concentrations on the northeast side of the East Branch lobe of
the benzene plume.

The two new monitoring wells were installed on May 13, 2013. DOF prepared a technical memorandum
(DOF 2013a) that documented the installation of new monitoring wells known as TTP-35M and TTP-
36M in that memorandum. These wells are currently identified as DOF-35M and DOF-36M in the
monitoring and discharge reports. The well locations are shown on Figure 2. Elevations were established
relative to the top of casing (TOC) of existing Well TTP-2M. The purpose of the two new wells is to
collect data to further assess possible benzene migration along two buried municipal sewer lines that are
located along the southeastern site boundary. Monitoring of these new wells would be at the same
frequency as for TTP-2M (i.e., quarterly).

Analysis of Monitoring Well Data

See Figure 6 for the current plume data as of December 2013, where benzene concentrations continue to
exceed the ROD criterion of 53 (ig/L. See Figure 7 for groundwater contours and estimated flow
directions in the Sand Aquifer as of December 2013. The current monitoring wells are grouped into 10
East Branch wells (TTP-3M Area) and 14 North Branch wells (TTP-18M Area).

The East Branch area is located along the southeastern site boundary and generally lies between wells
TTP-12M and DOF-36M. The specific East Branch wells are as follows:

•	Within remediation area (upgradient of site boundary): DOF-26M

•	Near site boundary: TTP-2M, TTP-3M, DOF-24M, DOF-25M, DOF-34M, DOF-35M (starting
June 2013), DOF-36M (starting June 2013)

•	Downgradient of site boundary: DOF-19M, DOF-20M (semi-annual wells)

The wells near the site boundary and downgradient of the site boundary, with the exception of DOF-35M
and DOF-36M (which are too new for trend analysis), were evaluated using the Mann-Kendall
nonparametric test for trend to evaluate benzene trends at or near the East Branch site boundary. The
results are provided below in Table 1 and Figure 8.

Table 1. Mann-Kendall Test for Benzene Trends in East Branch Wells (2009-2013)	

Well

Benzene Concentrations above
ROD Criterion (53 ji«/L)?

Benzene Concentration Trend

Confidence in Trend

(%)

TTP-2M

None since June 2009

Decreasing

>99.9

TTP-3M

All

No Trend

63.8

5

-------
OU 3 Attachment 2-2014 Technical Memorandum on Water Quality and Inspections and Maintenance

Well

Benzene Concentrations above
ROD Criterion (53 ^g/L)?

Benzene Concentration Trend

Confidence in Trend

(%)

DOF-19M

None

Probably Decreasing

94.6

DOF-20M

None

No Trend

70

DOF-24M

All

No Trend

63.8

DOF-25M

All

Increasing

95.4

DOF-3 4M

All

Probably Decreasing

91.3

For the newly installed well DOF-35M, which was incorporated into the monitoring program in June
2013, the June, September, and December benzene concentrations were 81, 12, and 86 (ig/L, respectively.
Two of these three values exceed the ROD benzene criterion. For the other newly installed well, DOF-
36M, there were no detections (detection limit of 0.10 j^ig/L) in June, September, or December 2013.

Thus, the East Branch site boundary wells that exceed the ROD criterion are TTP-3M, DOF-24M, DOF-
25M, DOF-34M, and DOF-35M. DOF-35M is closest to the sewer lines and located just within the site
boundary. DOF-25M, located further away from the sewer lines, has increasing benzene concentrations
above ROD criterion.

The North Branch area is located on the north part of the site and generally lies between wells AGI-
14M(R) and AGI-5M. The specific North Branch wells are as follows:

•	Upgradient of remediation area (and covered waste pile): TTP-16M(R), TTP-17M(R)

•	Within remediation area (upgradient of site boundary): DOF-22M, DOF-23M, DOF-29M, DOF-
30M

•	Near site boundary: AGI-14M(R), DOF-33M, TTP-18M, DOF-31M, AGI-5M

•	Downgradient of site boundary: DOF-27M, DOF-28M, MW-03

These wells are on a mix of quarterly, semi-annual, and annual sampling. The benzene concentrations
vary considerably, but the higher concentrations (above the ROD criterion) are present in two lobes
generally centered on wells DOF-33M and TTP-18M/DOF-31M, respectively. The wells near the site
boundary and downgradient of the site boundary were evaluated using the Mann-Kendall nonparametric
test for trend to evaluate benzene trends at or near the North Branch site boundary. The results are
provided below in Table 2 and Figure 9.

Table 2. Mann-Kendall Test for Benzene Trends in North Branch Wells (2009-2013)

Well

Benzene Concentrations above ROD

Benzene Concentration

Confidence in Trend



Criterion (53 jig/L)?

Trend

(%)

TTP-18M

All since December 2011

Increasing

>99.9

DOF-27M

None

No Trend

78.4

DOF-28M

One instance (68 |ig/L) in March 2013 (1)

No Trend(1)

60.3

DOF-31M

All since March 2011

Increasing

99.7

DOF-3 3M

All except once instance (0.1 |ig/L) in
December 2013 (2)

Probably Decreasing(2)

93.2

MW-03

None

Stable

89.2

1	- The exceedance was thought by DOF to be a lab error (DOF 2014a); if the exceedance is removed from the dataset, the
trend becomes "stable" with 58% confidence.

2	- The value of 0.1 (ig/L appears inconsistent with all prior values, which have ranged since March 2009 from 650 (ig/L to
1400 |ig/L. If 0.1 (ig/L is removed from the dataset, the trend becomes "stable" with 82.5% confidence.

6

-------
OU 3 Attachment 2-2014 Technical Memorandum on Water Quality and Inspections and Maintenance

As indicated in Table 2, the wells with increasing benzene concentrations above the ROD criterion are
TTP-18M and DOF-31M. DOF-33M also has benzene concentrations significantly above the ROD
criterion. These wells are located just outside the North Branch area site boundary (see Figure 2, upper
portion). However, benzene has generally not been detected in wells DOF-27M, DOF-28M, and MW-03,
which are located downgradient of wells TTP-18M, DOF-31M, and DOF-33M. The Puyallup River is
located downgradient from all of the aforementioned wells.

The SW location is supposed to be sampled in March and September, but the ditch is frequently dry in
September. The available sampling data indicate that benzene concentrations have been <1.0 (ig/L for this
fourth FYR period. The SW samples did not exceed the ROD criteria for other sampled COCs as well.
Regarding the exterior Hygrade well, the 2010 and 2012 benzene concentrations were <1.0 (ig/L. The
Hygrade well samples did not exceed the ROD criteria for other sampled COCs as well.

1.2. Water Quality Summary & Recommendations

In general, the benzene concentrations in the monitoring wells at the Tacoma Tar Pits site vary
considerably, but the shape of the benzene plume (areas with concentrations greater than 53 (ig/L and
greater than 1,000 (ig/L) as of December 2013 appears generally similar to the shape of plume in
December 2009 (see Figure 6 and Figure 10). With respect to effluent discharges from the GWET system
as described above, there has been only one exceedance of the ROD criterion during this FYR period, on
August 22, 2013 (64 j^ig/L). However, this value was still well below the permit criterion of 500 (ig/L.

With respect to the new East Branch site boundary wells installed in 2013 (DOF-35M, DOF-36M) near
the sewer lines, only DOF-35M has had benzene concentrations that slightly exceed the ROD criterion.
Data from future sampling events will help assess trends from these new wells and provide a more
complete picture of possible benzene migration beyond the boundary. Other East Branch site boundary
wells have mixed results for benzene concentrations and trends (see Table 1): TTP-3M, DOF-24M, DOF-
25M, and DOF-34M exceed the ROD criterion, and DOF-25M has increasing benzene concentrations
above the ROD criterion.

With respect to the North Branch site boundary wells, wells TTP-18M and DOF-31M are located just
outside the boundary and have had increasing benzene concentrations above the ROD criterion since
2011. DOF-33M also has benzene concentrations significantly above the ROD criterion and is located
outside the boundary. Other North Branch site boundary wells have mixed results for benzene
concentrations and trends (see Table 2). While groundwater (see Figure 7) as of December 2013 is
estimated to flow toward extraction wells A and B (and hence the site interior), the benzene
concentrations in wells TTP-18M, DOF-31M, and DOF-33M are of concern since these wells exceed the
ROD criterion and are located outside the site boundary.

The PRP's contractor, DOF, indicates that the containment system is functioning as intended, and that the
benzene plume in the Sand Aquifer is being contained by the pump and treat system. However, it appears
based on this data analysis and review, that benzene concentrations in some East Branch boundary wells
(DOF-25M, DOF-35M) and some North Branch off-site boundary wells (TTP-18M, DOF-31M) are
exceeding the ROD criterion at increasing values. The following recommendations are suggested for the
water quality data:

• DOF should include a figure that summarizes effluent benzene concentrations to help assess
effluent trends. Currently, only influent concentrations are provided.

7

-------
OU 3 Attachment 2-2014 Technical Memorandum on Water Quality and Inspections and Maintenance

•	DOF should add the location of the exterior Hygrade well to the DOF reports since it is part of
the sampling scheme.

•	DOF should monitor East Branch and North Branch site boundary wells closely, since the trends
indicate that the benzene ROD criterion is being exceeded at increasing values.

2. Inspection and Maintenance Activities

The primary objective of inspection and maintenance (I&M) activities is to ensure that the remedial
components installed in 1995 are still functioning as intended. In general, the site consists of a capped
engineered waste pile, storm water detention basins, and the Simons Metals LLC recycling operating
area. The need for I&M of the cover and drainage facilities at the Tacoma Tar Pits site is largely directed
toward identifying and repairing damage caused by severe weather. Generally, it is anticipated that the
greatest potential for damage would occur during the wetter (late fall to early spring) portions of the year
as compared to the drier portions of the year. Site inspections are generally made in the fall.

2.1. I&M Data Review and Analysis

The list of documents reviewed can be found at the end of this memo and are repeated in OU 3
Attachment 1 - List of Documents Reviewed. Documents reviewed included the 2010-2011 Inspection
and Maintenance Monitoring Report (DOF 2012j), the 2012-2013 Inspection and Maintenance
Monitoring Report (DOF 2014c), and the 2012 Technical Memorandum for Results of Asphalt
Permeability Testing (DOF 2012b).

I&M Inspection Dates

Site inspections were made on the following dates:

•	September 22, 2010 (general inspection)

•	October 4, 2010 (general inspection)

•	October 28, 2010 (finish general inspection)

•	December 15, 2010 (after heavy rain)

•	September 22, 2011 (general inspection)

•	October 27, 2011 (finish general inspection)

•	October 4, 2012 (general inspection)

•	November 1, 2012 (inspection after heavy rain)

•	August 14, 2013 (asphalt basin cleaning/observation)

•	August 20, 2013 (pre-mowing inspection/basin observation)

•	August 21,2013 (basin crack sealing)

•	October 21, 2013 (post-mowing/general inspection)

Other inspections occur as part of quarterly groundwater monitoring activities and as part of O&M of
GWET system.

Summary of Site Observations for Areas Covered

8

-------
OU 3 Attachment 2-2014 Technical Memorandum on Water Quality and Inspections and Maintenance

Areas covered by the 1995 I&M plan and the current conditions of those areas have been summarized in
Table 3 below. Photos of the areas and repairs made can be seen in the 2012-2013 Inspection and
Maintenance Monitoring Report (DOF 2014c), the most current report.

Table 3. Tacoma Tar Pits Areas Subject to I&M, and Current Condition

Facility covered by I&M plan

Current condition

Covered stabilized waste pile, which
is stabilized waste material covered by
geosynthetic fabrics, compacted soil,
and a vegetative layer

The site was mowed in 2010, 2011, 2012 and 2013 and no substantial
settlement or erosion was noted. Some minor soil scraping and rutting
were observed, similar to past years. Past soil scraping and rutting have
not been observed to adversely affect the soil cover, and the grass cover
quickly re-establishes after mowing. Brush was removed from the rocked
drainage channels on the stabilized waste pile.

The waste pile access road had developed a few holes along the ecology
block wall, and these were repaired.

Stabilized waste materials covered by
low permeability asphalt - former
construction water treatment area
located between the covered stabilized
waste pile and Detention Basin No. 1
(DB#1)

In 2013 the asphalt-covered area between DB#1 and the covered waste
pile was observed to be in good condition. Simons uses the area for truck
and trailer parking. The treatment plant currently lies within the eastern
portion of this area and is surrounded with a chain-link fence that
minimizes the possibility of inadvertent damage from vehicle traffic.

Concrete and asphalt covers (paving)
in the Simons operating area

Little change was evident from previous inspections, and the operating
area drainage system continues to operate as designed. Some asphalt
gouging, concrete raveling along joints, and concrete
cracking/gouging were observed in 2013. The observed "wear and tear"
damage to the paving was expected, and, in the opinion of DOF, did not
significantly affect the capping function of the paving. DOF
conversations with Simon's staff indicated that the metal recycling
operating area continues to drain well during periods of heavy
precipitation.

Box culverts, lined ditch, and DB#1
that drain the stabilized waste pile

The box culverts and drainage ways leading to and from the detention
basins continue to operate as designed. Some sediment/soil/debris has
accumulated in the bottom of some portions of the culverts without
restricting flow to the detention basins. Drainage ways into detention
basin DB#1 remain clear.

Some cracked asphalt was identified in the detention basins, primarily
DB#1. Asphalt cores were collected for permeability testing in 2011 and
confirmed that the cracks did not extend through the full asphalt
thickness. Repairs were also made - see additional text below.

Catch basins and DB#2, which are
storm drainage facilities for the
Simons operating area. The catch
basins, and for the most part DB#2,
are maintained by Simons.

Simons cleaned the catch basins annually (last in 2013); storm water was
discharged to the BN ditch through a control structure under an industrial
stormwater discharge permit with Ecology. Flow from DB#2 is restricted
to 1.0 cfs. Storm water is treated to remove oils and metals prior to
discharge.

The Burlington Northern (BN) ditch
that drains both detention basins

Vegetation continues to grow in the BN ditch, particularly at the east end
where discharge occurs to a buried culvert. Observations during heavy
precipitation indicate the vegetation does not cause water to back-up in
the ditch, and it likely acts as a biofiltration swale. During late
summer/early fall, vegetation is removed from the east end of the ditch so
that flow is not restricted.

9

-------
OU 3 Attachment 2-2014 Technical Memorandum on Water Quality and Inspections and Maintenance

Facility covered by I&M plan

Current condition

Signs and fencing

No issues were identified with signs or fencing.

In general, site observations made by DOF in 2012 and 2013 indicate that the remedial systems installed
at the Tacoma Tar Pits site in 1995 are in acceptable condition and are functioning as intended.

Asphalt Permeability Testing

A separate technical memorandum was prepared by DOF in 2012 that describes the results (with photos)
of asphalt permeability testing completed in 2011 for the bottom of the asphalt-lined stormwater detention
basins at the Tacoma Tar Pits site (DOF 2012b). Four cores were collected from each basin for a total of
eight cores. Consistent with their 2011 work plan (DOF 201 la), DOF collected two cores from each
basin in areas where visible observation indicated asphalt to be in good condition and two cores from
each basin in areas with some evidence of surface asphalt deterioration (i.e., surface cracking).

Detention Basin No. 1 (1)B I)

Cores DB1-KT1 and DB1-KT4 were obtained in areas where no surface cracking of asphalt was
observed, while cores DB1-KT2 (core of primary interest to EPA) and DB1-KT3 were obtained in areas
where cracking was observed. Pertinent observations and test results for DB#1 are summarized below in

Table 4.

Table 4. DB#1 Observations and Results

Location

Asphalt
Thickness (ft)

Observation

Permeability (cm/sec)

DB1-KT1

0.46

Core in un-cracked asphalt

1.3E-8

DB1-KT2

0.42

Cracked asphalt - 1.5 inches deep

2.3E-7

DB1-KT3

0.33

Cracked asphalt - 1 to 1.25 inches deep

<1.0E-7

DB1-KT4

0.42

Core in un-cracked asphalt

<1.0E-7

DB#1 asphalt thickness ranged from 0.33 to 0.43 feet (approximately 4 to 5.5 inches). Surface cracking
did not extend more than approximately 1.5 inches deep below the asphalt surface at locations DB1-KT2
and DB1-KT3. The deepest crack in either basin (1.5 inches) was observed in the core from DB1-KT2.

DB#1 asphalt core permeability ranged from 1.3E-8 cm/sec to 2.3E-7 cm/sec. One of the four core test
results was slightly higher than the performance criterion of lE-7cm/sec; the permeability at DB1-KT2
was 2.3E-7 cm/sec. The average of the test results is less than the performance criterion (approximately
6.6E-8 cm/sec) assuming a value of 1E-8 cm/sec for cores DB1-KT3 and DB1-KT4 where no flow was
observed during the testing and the permeability was determined to be less than 1E-7 cm/sec.

Detention Basin No. 2 (DB#2)

Cores DB2-KT1 and DB2-KT4 were obtained in areas where cracked asphalt was observed, while cores
DB2-KT2 and DB2-KT3 were obtained in areas where cracking was not observed. Pertinent
observations and test results are summarized below in Table 5.

Table 5. DB#2 Observations and Results

Location

Asphalt

Observation

Permeability (cm/sec)

10

-------
OU 3 Attachment 2-2014 Technical Memorandum on Water Quality and Inspections and Maintenance



Thickness (ft)





DB2-KT1

0.50

Asphalt surface cracking

3.2E-8

DB2-KT2

0.52

Core in un-cracked asphalt

<1.0E-7

DB2-KT3

0.46

Core in un-cracked asphalt

3.7E-9

DB2-KT4

0.42

Cracked asphalt - 1 inch deep

8.0E-8

DB#2 asphalt thickness ranged from 0.42 to 0.52 feet (approximately 5 to 6 inches). Surface cracking did
not extend more than approximately 1 inch deep below the asphalt surface at locations DB2-KT1 and
DB2-KT-4. DB#2 asphalt permeability ranged from 3.7E-9 cm/sec to less than 1.0E-7 cm/sec. The four
test results indicate the permeability of DB-2 asphalt is less than the performance criterion of 1E-7
cm/sec.

Detention Basin Asphalt Repair

In a letter dated November 13, 2012, EPA requested that DOF repair the cracks in the asphalt at the DB1-
KT2 sampling location (EPA 2012a). EPA also recommended that periodic inspections and repair of the
asphalt should occur.

The cracks were sealed in August 2013 as shown in Figures 27 to 30 of the 2012-2013 Inspection and
Maintenance Monitoring Report (DOF 2014c). An example of the repair is shown in Figure 11 of this
technical memorandum. Specifically, DOF subcontracted Asphalt Patch Systems of Puyallup,
Washington to clean and fill the cracks in the low-permeability asphalt that line the storm water detention
basins (DB#1 and DB#2). DB#1 (western basin) is a single basin that receives runoff from the
stabilized/covered waste pile and is approximately 51,000 square feet. DB#2 (eastern basin) is divided
into thirds, receives runoff from Simons Metals, and is approximately 49,150 square feet.

On August 14th, 2013, after an extended period of dry weather leaving the basins dry, a vacuum-equipped
street sweeper was deployed to remove sediment and debris in DB# 1 and in the southern two-thirds of
DB#2. The remaining third of DB#2, which contained a heavy layer of sediment because it serves as
Simon's primary settlement basin, was scraped and swept clean by Simons on August 20, 2013. The
basins were inspected to identify cracks for repair by DOF. On August 21, 2013, Asphalt Patch Systems
mobilized to the site to fill the cracks. The cracks were further cleaned using a hand-broom followed by a
high-velocity backpack blower. The cracks were filled with Dura Fill H.S Crack Filler A-420, a
rubberized joint and crack sealing compound that requires pre-melting. The material was melted in
propane-fired vessels and applied using a hand-operated applicator cart.

The majority of the cracks resided in DB#1 and approximately 1,350 lineal feet were sealed.
Approximately 100 lineal feet of cracking in DB#2 and 180 lineal feet along Simon's perimeter road
adjacent to the basins were also sealed.

2.2. I&M Summary and Recommendations

In general, site observations made by DOF in 2012 and 2013 indicate that the remedial systems installed
at the Tacoma Tar Pits site in 1995 are in acceptable condition and are functioning as intended. The
cracked asphalt has been repaired. In 2012, EPA asked PSE's contractor (DOF) to incorporate periodic
observations of asphalt integrity and repair into their annual I&M activities. DOF has not updated either
their 2006 Asphalt Repair/Maintenance Plan for the Detention Basins or their 1995 Inspection and
Maintenance Manual. The following action is recommended:

11

-------
OU 3 Attachment 2-2014 Technical Memorandum on Water Quality and Inspections and Maintenance

• DOF should inform EPA of their planned procedures for regularly inspecting and repairing the
asphalt, and indicate which of their documents will be updated to incorporate those activities.

3. Documents Reviewed

City of Tacoma (and PSE). 2012-2017 Permit No. TAC-031-2011. Permit renewed 5/1/12. Issued to
Dalton, Olmsted & Fuglevand, Inc .

Dalton, Olmsted & Fuglevand, Inc. (DOF). 2002. Revised Water Quality Monitoring Program, Tacoma
Historical Coal Gasification Site. January 4, 2002.

DOF. 2003. Groundwater Remediation System, Operation and Maintenance Plan, Tacoma Historical
Coal Gasification Site. Prepared for Puget Sound Energy, Inc. February 2003.

DOF 2009a. Dalton, Olmsted & Fuglevand, Inc (DOF). Quarterly Report. April 1, 2009 to June 30, 2009.
Permit No. 001-636-456. Tacoma Historical Coal Gasification Site. July 14, 2009.

DOF 2009b. Quarterly Report. July 1, 2009 to September 30, 2009. Permit No. 001-636-456. Tacoma
Historical Coal Gasification Site. October 12, 2009.

DOF 2010a. Quarterly Report. October 1, 2009 to December 31, 2009. Permit No. 001-636-456. Tacoma
Historical Coal Gasification Site. January 14, 2010.

DOF 2010b. Quarterly Report. January 1, 2010 to March 31, 2010. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. April 13, 2010.

DOF 2010c. Quarterly Report. April 1, 2010 to June 30, 2010. Permit No. 500043736. Tacoma Historical
Coal Gasification Site. July 30, 2010.

DOF 2010d. Quarterly Report. July 1, 2010 to September 30, 2010. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. October 14, 2010.

DOF 2010e. Water Quality Monitoring Report. March and June 2009 Sampling Events. Tacoma
Historical Coal Gasification Site. May 14, 2010.

DOF 201 Of. Water Quality Monitoring Report. September and December 2009 Sampling Events. Tacoma
Historical Coal Gasification Site. December 21, 2010.

DOF 2011a. Technical Memorandum. Asphalt Permeability Testing Work Plan, Detention Basins
THCGS. September 9, 2011.

DOF 201 lb. Quarterly Report. October 1, 2010 to December 31, 2010. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. January 12, 2011.

DOF 2011c. Quarterly Report. January 1, 2011 to March 31, 2011. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. April 10, 2011.

DOF 201 Id. Quarterly Report. April 1, 2011 to June 30, 2011. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. July 14, 2011.

12

-------
OU 3 Attachment 2-2014 Technical Memorandum on Water Quality and Inspections and Maintenance

DOF 201 le. Quarterly Report. July 1, 2011 to September 30, 2011. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. October 10, 2011.

DOF 201 If. Water Quality Monitoring Report. March and June 2010 Sampling Events. Tacoma
Historical Coal Gasification Site. January 10, 2011.

DOF 2012a. Technical Memorandum. Results of Trench Line Sampling, Tacoma Historical Coal
Gasification Site (Tacoma Tar Pits), Tacoma, Washington. Dec 9, 2012.

DOF 2012b. Technical Memorandum. Results of Asphalt Permeability Testing, Detention Basins,

THCGS. May 8, 2012.

DOF 2012c. Quarterly Report. October 1, 2011 to December 31, 2011. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. January 6, 2012.

DOF 2012d. Quarterly Report. January 1, 2012 to March 31, 2012. Permit No. 500043736. Tacoma
Historical Coal Gasification Site. April 12, 2012.

DOF 2012e. Quarterly Report. April 1, 2012 to June 30, 2012. Permit No. TAC-031-2011. Tacoma
Historical Coal Gasification Site. July 13, 2012.

DOF 2012f. Quarterly Report. July 1, 2012 to September 30, 2012. Permit No. TAC-031-2011. Tacoma
Historical Coal Gasification Site. October 12, 2012.

DOF2012g. Water Quality Monitoring Report. September and December 2010 Sampling Events. Tacoma
Historical Coal Gasification Site. January 9, 2012.

DOF 2012h. Water Quality Monitoring Report. March and June 2011 Sampling Events. Tacoma
Historical Coal Gasification Site. August 7, 2012.

DOF 2012i. Water Quality Monitoring Report. September and December 2011 Sampling Events. Tacoma
Historical Coal Gasification Site. August 13, 2012.

DOF. 2012j. Inspection and Maintenance Report. January 2010 to December 2011. Tacoma Historical
Coal Gasification Site. Prepared for PSE by DOF, Inc. May 2012.

DOF 2013a. Technical Memorandum. New Monitoring Well Installations, Tacoma Historical Coal
Gasification Site, Tacoma, Washington. December 23, 2013.

DOF 2013b. Quarterly Report. October 1, 2012 to December 31, 2012. Permit No. TAC-031-2011.
Tacoma Historical Coal Gasification Site. January 8, 2013.

DOF 2013c. Quarterly Report. January 1, 2013 to March 31, 2013. Permit No. TAC-031-2011. Tacoma
Historical Coal Gasification Site. April 10, 2013.

DOF 2013d. Quarterly Report. April 1, 2013 to June 30, 2013. Permit No. TAC-031-2011. Tacoma
Historical Coal Gasification Site. July 12, 2013.

DOF 2013e. Quarterly Report. July 1, 2013 to September 30, 2013. Permit No. TAC-031-2011. Tacoma
Historical Coal Gasification Site. October 7, 2013.

13

-------
OU 3 Attachment 2-2014 Technical Memorandum on Water Quality and Inspections and Maintenance

DOF 2013f. Water Quality Monitoring Report. March and June 2012 Sampling Events. Tacoma
Historical Coal Gasification Site. December 21, 2013.

DOF2013g. Water Quality Monitoring Report. September and December 2012 Sampling Events. Tacoma
Historical Coal Gasification Site. December 27, 2013.

DOF 2014a. Water Quality Monitoring Report. March and June 2013 Sampling Events. Tacoma
Historical Coal Gasification Site. March 28, 2014.

DOF 2014b. Water Quality Monitoring Report. September and December 2013 Sampling Events. Tacoma
Historical Coal Gasification Site. March 31, 2014.

DOF 2014c. Inspection and Maintenance Report. January 2012 to December 2013. Tacoma Historical
Coal Gasification Site. Prepared for PSE. January 2014.

DOF 2014d. Quarterly Report. October 1, 2013 to December 31, 2013. Permit No. TAC-031-2011.
Tacoma Historical Coal Gasification Site. January 13, 2014.

U.S. Environmental Protection Agency (EPA). 1987. Record of Decision for Commencement Bay, Near
Shore/Tide Flats OU 23 (Tacoma Tar Pits), Pierce County, WA. December 30, 1987.

Ebasco. 1995. Inspection and Maintenance Manual, Tacoma Historical Coal Gasification Site. Prepared
for Washington Natural Gas Company. August 1995.

EPA. 1991. Explanation of Significant Differences for Commencement Bay, Near Shore/Tide Flats OU 23
(Tacoma Tar Pits), Pierce County, WA. November 1, 1991.

EPA. 1995. Explanation of Significant Differences for the Tacoma Tar Pits Operable Unit. May 9, 1995.

EPA. 2009. Five-Year Review Report. Third Five-Year Review Report for Commencement Bay
Nearshore/Tideflats SuperfundSite, Tacoma, Washington. Prepared by U.S. Environmental Protection
Agency, Region 10. December 23, 2009.

EPA. 2012a. Letter dated November 13, 2012 from Tamara Langton (EPA) to Matt Dalton (DOF)
regarding EPA Comments on the Asphalt Permeability Testing Results and the Trench Line Sampling
Results, Tacoma Historical Coal Gasification Site (Tacoma Tar Pits).

14

-------
OU 3 Attachment 2-2014 Technical Memorandum on Water Quality and Inspections and Maintenance

OU 3 Attachment 2 - FIGURES

15

-------
Tacoma Historical Coal Gasification Site
Tacoma, Washington

North Branch Influent Concentrations

East Branch Influent Concentrations

7000
^ 6000

U)

3

£ 5000
o

-N

J= 4000
c
a>

§ 3000

0

1	2000

N
C

m 1000
0

Apr-01	Jan-04	Oct-06	Jul-09	Apr-12	Dec-14

OU 3 Att 2 - Figure 1. Benzene Influent Concentrations through 2013 (Source: DOF 2014b)

-------
AGI-13M(R) V AGW, TTP-6S

® AGI-13SCR) ^^"^"eJjalJandoned



®
DOF-28M

Scale in Feet

®

®	MW-03

DOF-27M

Site Boundary

Tacoma

Treatment

Plant

Approximate Trend
of Twin 48" Diameter
Sewer Lines

Tacoma Historical Coal Gasification Site
Water Sampling Locations
WNG-001-01 FIGURE 2 Dec. 2013

Dalton, Olmsted & Fuglevand, Inc.

OU 3 Att 2 - Figure 2. Sampling Locations (Source: DOF 2014b)

-------
TTP-2IV!

Approximate' (13 ug/l)

Trend of Inside

Rim: 10.40 Feet
IE: -6.2 feet

(vertical datum: NGVD29)

©8®M aicqjEi
©SMKf*

Date: June 11, 2011
(Google Earth)

i	a

0	70

Scale in Feet
(approximate)

Man-Hole

Existing Monitoring
Well

/t\ Push-Probe (June
'2012)

Highest Benzene
(1.5 ug/l) Cone. Detected -
June 2012

Benzene Below ROD
Criterion

Benzene Above ROD
Criterion

0~\ yt Proposed Additional
VF/r Monitoring Well



Ref; Push-ProbeLoc.cdr

Tacoma Historical Coal Gasification Site
Tacoma, Washington

Push-Probe and Well
Locations

WNG-001 FIGURE 3 Sept. 2012

Dalton, Olmsted & Fug lev and, Inc.

OH 3 Att 2 - Figure 3. Probe Locations (Source: DOF 2012a)

-------
TTP-18M Area
(North Branch) \

r

Legend

TTP-12M Monitoring Well Location
and Benzene Cone, (ug/l)
<0,5 jun. 2012 unless otherwise
noted

Note: All wells installed in
separate boreholes

Detected Benzene Cone, (ug/l)
Pumping Well Location

15

+ TW-1/P-1

r--i

Previous Estimated Area

¦-.J

Benzene > 53 ug/l

ggfii

Estimated Area Benzene

¦--J

> 53 ug/l

i ¦ »

Estimated Area Benzene

¦ ¦ ¦"

> 1000 ug/l

Ref:benext6 12trench.cdr

SITE BOUNDARY

Areaof Interest

Tacoma

Treatment

Plant

TTP-3M Area °°2^
(East Branch)

OU3 Att 2 - Figure 4. Benzene Plume as of June 2012 (Source: DOF 2013f)

©

DOF-20M
<0.55(3/12)

Approximate Trend
of Twin 48" Diameter
Sewer Lines

Tacoma Historical Coal Gasification Site

Benzene Plume - June 2012

WNG-001-01 FIGURE 5 Oct. 2012

Dalton, Olmsted & Fuglevand, Inc.

-------
OU 3 Att 2 - Figure 5. Vertical Profile of Probe Sampling Results (Source: DOF 2012a)

-------
Legend

© TTP-12M
<0.5

Note: All wells installed In
separate boreholes

E WP-13

I—I

'	}

+ TW-1/P-1 Pumping Well Location

r " "i Previous Estimated Area
'mm J	Benzene > 53 ug/l

Estimated Area Benzene

>	53 ug/l

Estimated Area Benzene

>	1000 ug/l

Ref:benext 12 13.cdr

WP-13

Monitoring Well Location
and Benzene Cone, (ug/l)
Dec. 2013 unless otherwise
noted

Tacoma

Treatment

Plant

Water Quality Probe Location
Feb. To Apr. 99

TTP-3M Area
(East Branch)

Approximate Trend
of Twin 48" Diameter
Sewer Lines

Tacoma Historical Coal Gasification Site

Benzene Plume - December 2013

WNG-001-01 FIGURE 10 Mar. 2014

nnl+rm Olmsted & Fuglevand, Inc.

OU 3 Att 2 - Figure 6. Benzene Plume as of December 2013 and Data for DOF-35M, DOF-36M (Source: DOF 2014b)

SITE BOUNDARY

0 150 300
Scale in Feet

MW-03
<0.10(9-13)

AGI-13M(R)

AGI-6M

(abandoned)

V ®

_TTP-6M(R)
&Nm

TTP-18M Area
(North Branch)

Estimated Former Extent of
Benzene Plume

DOF-33M
<0.10

WP-19

DOF-28M

<0.10(9-13)

-------
Legend

Monitoring Weil Location

Note: All wells installed in
separate boreholes

Ground Water Treatment
Well

Water Level Elevation, December 19, 2013

t (National Geodetic Vertical Datum
- See Table 2

Ground-Water Contour

Tacoma

Treatment

Plant

Approximate Trend
of Twin 48" Diameter
Sewer Lines

Estimated Ground-Water
Direction

-V \ DOF-19M
Well C

©

DOF-20M

Tacoma Historical Coal Gasification Site
Groundwater Contours
Sand Unit - December 2013
WNG-001-01 FIGURE 7 Mar. 2014

iisl.

OU 3 Att 2 - Figure 7. Groundwater Contours in Sand Aquifer as of December 2013 (Source: DOF 2014b)

-------
06/08 12/08 0//09 01/10 08/10 02/11 09/11 04/12 10/12 05/13 11/13 06/14

Sampling Date

100000

_ 10000

—TTP-2M
^^TTP-3M
^^D0F-19M
^^DOF-20M
^i^DOF-24M
^^DOF-25M
DOF-34M

OU 3 Att 2 - Figure 8. Mann-Kendall Graph of Benzene Concentrations in East Branch Wells (2009-2013)

-------
10000

0.01

Sampling Date

—~—TTP-18M
^^DOF-27M
^^DOF-28M
^^D0F-31M
^i^DOF-33M
^^MW-03

OU 3 Att 2 - Figure 9. Mann-Kendall Graph of Benzene Concentrations in North Branch Wells (2009-2013)

-------
TTP-18M Area
(North Branch) \

Estimated Former Extent of
Benzene Plume	I

SITE BOUNDARY

Legend

TTP-12M
<0.5

Monitoring Well Location
and Benzene Cone, (ug/l)
December 2009 unless otherwise
noted

Note: All wells installed in
separate boreholes

Tacoma

Treatment

Plant

• WP-13
+ TW-1/P-1

Water Quality Probe Location
Feb. ToApr. 99

Pumping Well Location

i	1

¦-.J

r— i

Ref:benext12 09.cdr

Previous Estimated Area
Benzene > 53 ug/l

Estimated Area Benzene

>	53 ug/l

Estimated Area Benzene

>	1000 ug/l

Estimated Flow Direction

TTP-3M Area
(East Branch)

DOF-20M
1.2(9/09)

Approximate Trend
of Twin 48" Diameter
Sewer Lines

Tacoma Historical Coal Gasification Site

Benzene Plume - December 2009

WNG-001-01 FIGURE 10 Mar. 2010

D alt on, Olmsted & Fuglevand, Inc.

OU 3 Att 2 - Figure 10. Benzene Plume as of December 2009 (Source: DOF 2010a)

-------
OU 3 Att 2 - Figure 11. Photo of 2013 Asphalt Crack Repair in Detention Basin (Source: DOF 2014c)

-------
OU3 Attachment 3 - Public Input on Tacoma Tar Pits Site

-------
OU 3 Attachment 3 - Public Input on TacomaTar Pits Site

From:

To:

Cc:

Subject:
Date:

Lanaton. Tamara

Keelev. Karen: Rochlin. Kevin: Rvan. William (Region 101: Williams. Jonathan
Blocker. Shawn: Gallaher. Jo
RE: CBNT FYR - Public Input?

Wednesday, April 16, 2014 1:04:04 PM

Yes. I received one public inquiry on Tacoma Tar Pits yesterday.

Inquirer: Reporter from Seattle Globalist, Lael Henterly, doing on an article on the Northwest
Detention Center which is an Immigration, Customs and Enforcement (ICE) facility located on the
northwest portion of the Tacoma Tar Pits Site.

Questions: What is a Superfund Site? What is a Five-Year Review? What is the history (past uses)
of this Site? What contamination is/was on the Site? What cleanup actions have taken place? What
do the recent groundwater monitoring reports show, especially those on the Northwest Detention
Center portion of the property.

Response: Briefly answered the questions above, and also said that I am not expecting any surprises
duringthis Five-Year Review because of the results of the quarterly groundwater monitoring
reports, and the annual "above-ground" inspection and maintenance reports. I am sending her
more information on the Site, including the 2013 groundwater monitoring reports. I also told her
that the final Five-Year Report will be available in December 2014.

From: Keeley, Karen

Sent: Wednesday, April 16, 2014 12:54 PM

To: Langton, Tamara; Rochlin, Kevin; Ryan, William (Region 10); Williams, Jonathan
Cc: Blocker, Shawn; Gallaher, Jo
Subject: CBNT FYR - Public Input?

Please send me an email with a note clarifying 'yes or no' if you received any
public input (closed yesterday).

If you received information, please identify your'project/site' by the NAME that
we are using on our FYR spreadsheet, and a short bullet of the comment (if
verbal) or a copy of the comment (if email/letter).

I will make sure it gets in the correct section of the FYR Site File.

I did not hear anything from CHB.

Karen Keeley | Superfund Remedial Project Manager
U.S. Environmental Protection Agency | Region 10

Office of Environmental Cleanup

1200 8th Avenue, Suite 900, EL	tttle, WA 98101

p: 206.553.2141

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

Tacoma Tar Pits 2014 Five-Year-Review
Site Inspection Roster
June 12, 2014

Name

Affiliation

Phone No.

Tamara Langton

EPA Remedial Project Manager

206-553-2709

Karah Haskins

USACE (on behalf of Veronica Henzi)

206-764-6964

John Rork

Puget Sound Energy

425-456-2228

Matt Dalton

Dalton, Olmsted & Fuglevand, Inc.
(PSE's Contractor)

360-380-0862

Dave Cooper

Dalton, Olmsted & Fuglevand, Inc.

425-827-4588

Mark Stafford

City of Tacoma, Public Works

253-502-2110

Alan Aplin

City of Tacoma, Public Works

253-502-2110

Greg Barrowman

Simon Metals Operations Manager

253-507-9866

1

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

Five-Year Review Site Inspection Checklist

I. SITE INFORMATION

Site name: Tacoma Tar Pits (OU3)

Date of inspection: Thursday, June 12, 2014

Location: Tacoma, Pierce County, Washington

EPA ID: WAD980726368

Agency, office, or company leading the five-year
review: EPA Region 10

Weather/temperature Overcast, 70 degrees F

Remedy Includes: (Check all that apply)
[¦] Landfill cover/containment
0Access controls
fHInstitutional controls
[¦]Groundwater pump and treatment
[¦] Surface water collection and treatment
EH Other:

~Monitored natural attenuation
I I Groundw ater containment
O Vertical barrier walls

Attachments: [¦] Inspection team roster attached

s Site map attached

II. INTERVIEWS (Check all that apply)

1. O&M site manager John Rork

PSE Project Manager

Name	Title

Interviewed 11 at site ~ at office ~ by phone Phone no. 	

Problems, suggestions; ~ Report attached Informally interviewed during site inspection;

June 12, 2014
Date

2. O&M staff Ma" Dalton (PRP's contractor)

Dalton, Olmstead, Fuglevand I June 12, 2014

Name	Title

Interviewed s at site I lat office ~ by phone Phone no. 	

Problems, suggestions; ~ Report attached	

Date

2

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

3.

Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response
office, police department, office of public health or environmental health, zoning office, recorder of
deeds, or other city and county offices, etc.) Fill in all that apply.

Agency
Contact

Name Title Date Phone no.
Problems; suggestions; PI Report attached

Agency

Contact Dalton, Olmstead, Fuglevand Inc. June 12, 2014

Name Title Date Phone no.
Problems; suggestions; PI Report attached

Agency
Contact

Name Title Date Phone no.
Problems; suggestions; n Report attached

Agency
Contact

Name Title Date Phone no.
Problems; suggestions; n Report attached

4.

Other interviews (optional) ~ Report attached.



III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

1.

O&M Documents

[I] O&M manual [I] Readily available [I] Up to date ~ N/A

¦	As-built drawings El Readily available © Up to date ~ N/A

¦	Maintenance logs | Readily available | Up to date ~ N/A
Remarks

2.

Site-Specific Health and Safety Plan ~ Readily available ~ Up to date ~ N/A
~ Contingency plan/emergency response plan Q Readily available ~ Up to date ~ N/A
Remarks gpj|| p|an anc| MSDS sheets on site.

3

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

3.

O&M and OSHA Training Records

Remarks

El Readily available

~ Up to date

~n/a

4.

Permits and Service Agreements

~	Air discharge permit
El Effluent discharge

~	Waste disposal, POTW
I-! Other permits
Remarks

~	Readily available
El Readily available

~	Readily available

~	Readily available

~	Up to date
H]Up to date

~	Up to date

~	Up to date

~	n/a

~	n/a

H N/A

~	n/a

5.

Gas Generation Records [¦] Readily available
Remarks Qas generation is not a concern with this landfill.

~ Up to date

¦ N/A

6.

Settlement Monument Records

Remarks

~ Readily available

~ Up to date

~ n/a

7.

Groundwater Monitoring Records
Remarks Not kept on site.

El Readily available

El Up to date

~n/a

8.

Leachate Extraction Records

Remarks

1 1 Readily available

1 1 Up to date

|N/A

9.

Discharge Compliance Records

~ Air

El Water (effluent)

Remarks Records are not kept on site,

~ Readily available
1 1 Readily available

~ Up to date
1 1 Up to date

~	n/a

~	n/a

10.

Daily Access/Security Logs

Remarks

El Readily available

El Up to date

~ n/a

4

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

IV. O&M COSTS

O&M Organization

~	State in-house

~	PRP in-house
~Federal Facility in-house

~	Other

~	Contractor for State
[I] Contractor for PRP

~	Contractor for Federal Facility

O&M Cost Records

~ Readily available ~ Up to date
Original O&M cost estimate	

~ Funding mechanism/agreement in place
		~ Breakdown attached

Total annual cost by year for review period if available

From



To





~Breakdown attached



Date



Date

Total cost



From



To





~ Breakdown attached



Date



Date

Total cost



From



To





~ Breakdown attached



Date



Date

Total cost



From



To





~ Breakdown attached



Date



Date

Total cost



From



To





~ Breakdown attached



Date



Date

Total cost



Unanticipated or Unusually High O&M Costs During Review Period

Describe costs and reasons:

V. ACCESS AND INSTITUTIONAL CONTROLS H Applicable ~ N/A

A. Fencing

1. Fencing damaged	~ Location shown on site map QGates secured Q N/A

Remarks Fencing was in good condition.

B. Other Access Restrictions

~ Location shown on site map ~ N/A
Rare trespassing occurrences at site, which have not affected remedy.

1. Signs and other security measures

Remarks

5

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

C. Institutional Controls (ICs)

1. Implementation and enforcement

Site conditions imply ICs not properly implemented	~ Yes H No ~ N/A

Site conditions imply ICs not being fully enforced	~ Yes ¦ No ~ N/A

Type of monitoring (e.g., self-reporting, drive by) on-site inspection

Frequency Quarterly at a minimum

DOF, the PRP Remedial contractor

Responsible party/agency

Contact Matthew Dalton	Hydrogeologist

Name	Title	Date Phone no.

Reporting is up-to-date

~

Yes

~

No

~

N/A

Reports are verified by the lead agency

~

Yes

IB

No

~

N/A

Specific requirements in deed or decision documents have been met

H

Yes

~

No

~

N/A

Violations have been reported

~

Yes

~

No

IB

N/A

Other problems or suggestions: ~ Report attached

2. Adequacy	|B ICs are adequate ~ ICs are inadequate ~ N/A

Remarks

D. General

1. Vandalism/trespassing ~ Location shown on site map ~ No vandalism evident
Remarks pare trespassing related to Simon Metals business.

2. Land use changes on site |B N/A

Remarks

3. Land use changes off site IB N/A

Remarks

VI. GENERAL SITE CONDITIONS

A. Roads	H] Applicable ~ N/A

1. Roads damaged	~ Location shown on site map ~ Roads adequate IB N/A

Remarks

6

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

B.

Other Site Conditions





Remarks





VII. LANDFILL COVERS ~ Applicable

~ n/a

A.

Landfill Surface





1.

Settlement (Low spots) ~ Location shown on site map
Areal extent Depth

[I] Settlement not evident



Remarks





2.

Cracks

Lengths

1 1 Location shown on site map
Widths Depths

El Cracking not evident



Remarks





3.

Erosion

Areal extent

~ Location shown on site map
Depth

El Erosion not evident



Remarks





4.

Holes

Areal extent

~ Location shown on site map
Depth

El Holes not evident



Remarks





5.

Vegetative Cover [I] Grass [B]Cover properly established

1 1 No signs of stress ~ Trees/Shrubs (indicate size and locations on a diagram)
Remarks j^g grass covering is maintained annually.

6.

Alternative Cover (armored rock, concrete, etc.)

Remarks

~ n/a

7.

Bulges

Areal extent

~ Location shown on site map
Height

El Bulges not evident



Remarks





7

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

8.

Wet Areas/Water Damage

1 1 Wet areas

~	Ponding

~	Seeps

~	Soft subgrade
Remarks

El Wet areas/water damage not evident
I"! Location shown on site map Areal extent
I-! Location shown on site map Areal extent
I"! Location shown on site map Areal extent
r~|Location shown on site map Areal extent

9.

Slope Instability

Areal extent
Remarks

~ Slides

~ Location shown on site map [I] No evidence of slope instability

B.

Benches

I N/A

B1 Applicable



(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope
in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined
channel.)

1.

Flows Bypass Bench

Remarks



~ Location shown on site map [I] N/A or okay

2.

Bench Breached

Remarks



1 1 Location shown on site map | N/A or okay

3.

Bench Overtopped

Remarks



1 1 Location shown on site map | N/A or okay

C.

Letdown Channels [¦] Applicable ~ N/A

(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)

1.

Settlement

Areal extent

~ Location shown on site map [I] No evidence of settlement
Depth



Remarks





2.

Material Degradation ~ Location shown on site map |H]No evidence of degradation
Material type Areal extent



Remarks





3.

Erosion

Areal extent

~ Location shown on site map [¦] No evidence of erosion
Depth



Remarks





8

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

4.

Undercutting ~ Location shown on site map © No evidence of undercutting
Areal extent Depth



Remarks





5.

Obstructions Type IB] No obstructions PI Location shown on site map
Areal extent Size



Remarks





6.

Excessive Vegetative Growth Type

1 No evidence of excessive growth

~ Vegetation in channels does not obstruct flow

|~~| Location shown on site map Areal extent

Remarks



D.

Cover Penetrations ~ Applicable © N/A



1.

Gas Vents ~ N/A ~ Active ~ Passive ~ Properly secured/locked ~ Functioning
~ Routinely sampled ~ Good condition ~ Evidence of leakage at penetration

Remarks

2.

Gas Monitoring Probes

~	Properly secured/locked ~ Functioning

~	Evidence of leakage at penetration
Remarks

~	Routinely sampled

~	Needs Maintenance

~	Good condition

~	N/A

3.

Monitoring Wells (within surface area of landfill)

~	Properly secured/locked ~ Functioning

~	Evidence of leakage at penetration
Remarks

~	Routinely sampled

~	Needs Maintenance

~	Good condition

~	N/A

4.

Leachate Extraction Wells

~ Properly secured/locked ~ Functioning
1 1 Evidence of leakage at penetration
Remarks

~ Routinely sampled
1 1 Needs Maintenance

~	Good condition

~	N/A

5.

Settlement Monuments ~ Located
Remarks

~ Routinely surveyed

~n/a

9

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

E.

Gas Collection and Treatment ~ Applicable

Hn/a

1.

Gas Treatment Facilities

~	Flaring Q Thermal destruction

~	Good condition Q Needs Maintenance
Remarks

~ Collection for reuse

2.

Gas Collection Wells, Manifolds and Piping

~ Good condition Q Needs Maintenance
Remarks



3.

Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
~ Good condition Q Needs Maintenance ~ N/A
Remarks

F.

Cover Drainage Layer (¦] Applicable

~ n/a

1.

Outlet Pipes Inspected | Functioning
Remarks n0 problems mentioned or observed.

~ n/a

2.

Outlet Rock Inspected ~ Functioning
Remarks

~ n/a

G.

Detention/Sedimentation Ponds [¦] Applicable

~ n/a

1.

Siltation ~ N/A ~ Siltation not evident
Areal extent Depth



Remarks2 Asphalt-lined basins. Minor siltation is evident in the Detention Basin 2. Detention
basins are swept occasionally.

2.

Erosion Areal extent Depth

IB] Erosion not evident



Remarks



3.

Outlet Works [¦] Functioning Q N/A

Remarks outlet pipe of Detention Basin 1 appears to be in good condition.

4.

Dam ~ Functioning (¦] N/A
Remarks



10

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

H. Retaining Walls ~ Applicable 0 N/A

1.

Deformations ~ Location shown on site map ~ Deformation not evident
Horizontal displacement Vertical displacement
Rotational displacement
Remarks

2.

Degradation Q Location shown on site map ~ Degradation not evident
Remarks

I. Perimeter Ditches/Off-Site Discharge 0 Applicable ~ N/A

1.

Siltation ~ Location shown on site map | Siltation not evident

Areal extent Depth

Remarks

2.

Vegetative Growth Q Location shown on site map ~ N/A

[I] Vegetation does not impede flow
Areal extent Type

Remarks jhere are some blackberry bushes, but they do not block the flow of water in the

r\orimAtor rlitr>har

3.

Erosion ~ Location shown on site map | Erosion not evident
Areal extent Depth

Remarks channels drain runoff by pipe directly into detention basin

4.

Discharge Structure 0 Functioning ~ N/A

Discharge pipes flow directly into Detention Basin 1.

VIII. VERTICAL BARRIER WALLS ~ Applicable 0 N/A

1.

Settlement ~ Location shown on site map ~ Settlement not evident

Areal extent Depth

Remarks

2.

Performance Monitoring Type of monitoring
I | Performance not monitored Q Evidence of breaching
Frequency Head differential
Remarks

IX. GROUNDWATER/SURFACE WATER REMEDIES 0 Applicable ~ N/A

A.

Groundwater Extraction Wells, Pumps, and Pipelines 0 Applicable ~ N/A

1.

Pumps, Wellhead Plumbing, and Electrical

El Good condition © All required wells properly operating Q Needs Maintenance ~ N/A
Remarks

11

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

2.

Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances

0 Good condition Q Needs Maintenance
Remarks

3.

Spare Parts and Equipment

~ Readily available ~ Good condition 0 Requires upgrade ~ Needs to be provided
Remarks

There are spare air strippers available

B. Surface Water Collection Structures, Pumps, and Pipelines 0 Applicable ~ N/A

1.

Collection Structures, Pumps, and Electrical

1 1 Good condition ~ Needs Maintenance

Remarks Surface water detention basins are the collection structure. Cracking is patched with
polymer as needed.

2.

Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances

~ Good condition 0 Needs Maintenance
Remarks

3.

Spare Parts and Equipment

~ Readily available ~ Good condition Q Requires upgrade ~ Needs to be provided
Remarks

C.

Treatment System 0 Applicable ~ N/A

1.

Treatment Train (Check components that apply)

1 1 Metals removal ~ Oil/water separation ~ Bioremediation
El Air stripping © Carbon adsorbers
I-! Filters

I-! Additive (e.£., chelation agent, flocculent)

I-! Others

1 1 Good condition ~ Needs Maintenance

~	Sampling ports properly marked and functional

~	Sampling/maintenance log displayed and up to date

~	Equipment properly identified

I-! Quantity of groundwater treated annually
I"! Quantity of surface water treated annually
Remarks

2.

Electrical Enclosures and Panels (properly rated and functional)
~N/A ~ Good condition Q Needs Maintenance

Remarks Appeartc> be in good condtion.

12

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

3.

Tanks, Vaults, Storage Vessels

ON/A © Good condition © Proper secondary containment ~ Needs Maintenance
Remarks seconc|ary containment has a overflow shutoff float.

4.

Discharge Structure and Appurtenances

~ N/A (¦] Good condition Q Needs Maintenance
Remarks pipeline from plant is buried, but has leak detection system.

5.

Treatment Building(s)

1 1 N/A H] Good condition (esp. roof and doorways) ~ Needs repair
El Chemicals and equipment properly stored

I^ciTicirlvS

Fence and locked gate appear to be in good

i:±: - -ri - - - i - r i 	 x i



6.

Monitoring Wells (pump and treatment remedy)

[I] Properly secured/locked [I] Functioning (¦] Routinely sampled ElGood condition
~ All required wells located ~ Needs Maintenance ~ N/A
Remarks

D. Monitoring Data

1.

Monitoring Data

[I] Is routinely submitted on time [I] Is of acceptable quality

2.

Monitoring data suggests:

El Groundwater plume is effectively contained [¦] Contaminant concentrations are declining

D.

Monitored Natural Attenuation

1.

Monitoring Wells (natural attenuation remedy)

~ Properly secured/locked ~ Functioning Q Routinely sampled ~ Good condition
~All required wells located 1 iNccds Maintenance |H]N/A
Remarks

X. OTHER REMEDIES

If there are remedies applied at the site which are not covered above, attach an inspection sheet describing
the physical nature and condition of any facility associated with the remedy. An example would be soil
vapor extraction.

13

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

XL OVERALL OBSERVATIONS

A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume,
minimize infiltration and gas emission, etc.).

The waste pile cap and cover remedy are intended to encapsulate treated soils and minimize precipitation infiltration. This remedy appears to be functioning as intended.

The groundwater extraction and treatment system uses air stripping to eliminate benzene from groundwater and uses granular activated carbon to sorb VOCS from the vapor
stream. Treated groundwater effluent is discharged to the City of Tacoma. Inspection by the PSE occurs quarterly and the City of Tacoma inspects annually. There was a
discharge criteria (0.50 mg/L) exceedance of 0.51 mg/L found by PSE and reported to the City of Tacoma. After maintenance to the air stripper was completed, the discharge
criteria was met.

B. Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protectiveness of the remedy.

O&M procedures appear to be functioning as intended. Any issues are corrected in a timely manner.

C. Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be
compromised in the future.

None

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.

None

14

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

Photo 1, Tall grass growing in drainage ditch. Grass is maintained annually.

I

it

Photo 2. Sedimentation in Detention Basin 2.

15

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

Photo 3. Detention Basin 1

Photo 4. Drainage into Detention Basin 1

16

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

Photo 5. Drainage pipe into Detention Basin 1.

Photo 6. Groundwater treatment plant.

17

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

Photo 7. Spare air stripper parts.

Photo 8. Perimeter drain clear grates.

18

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

Photo 9. Vegetation growing in armored drainage channel between waste pile and access road.

Photo 10. NW Detention Center Expansion from access road on top of waste pile.

19

-------
OU 3 Attachment 4 - Site Inspection Team Roster, Checklist, and Photographs

Photo 11. Waste pile from entrance to access road.

Photo 12. Top of waste pile.

20

-------
OU 3 Attachment 5 - ARARs Review Summary

-------
OU 3 Attachment 5 - Tacoma Tar Pits ARARs Summary

Media

Source/ARAR Citation

Requirement Synopsis

Status

Current ARAR Evaluation

Soil

[Federal] Resource
Conservation and Recovery
Act (RCRA) 42 USC 6901,
Subtitle C, 40 CFR264,
Subpart G

Post-closure care must be provided for at least thirty years and
includes monitoring, reporting, and maintenance of waste
containment systems. Covers and similar structures must not be
disturbed unless special conditions arise. A local land use authority
must be notified of the presence of remaining contamination and the
locations of waste facilities. Also, the previous use of the site and
restrictions on the future use of the site must be recorded in the
property deed.

Relevant and
appropriate

Still relevant and appropriate. No changes which affect site or remedy.
Monitoring, reporting, and maintenance of waste-pile cover continues.

Soil

[Federal] RCRA 42 USC
6901, Subtitle C, 40 CFR
264, Subpart N

Provisions pertaining to the capping, monitoring, closure, and post-
closure care of the site. A final cover must be placed which
minimizes the migration of liquids through the landfill, requires
minimal maintenance, promotes drainage, and minimizes degradation
of the surface, accommodates settling and subsidence without the loss
of effectiveness, and has permeability less than the underlying
materials. The cap must be inspected and maintained, and
groundwater monitoring conducted.

Relevant and
appropriate

Still relevant and appropriate. No changes which affect site or remedy.
Monitoring, reporting, and maintenance of waste-pile cover continues.

Soil

[Federal] Department of
Transportation (DOT) 49
CFR Parts 171 to 173

Transport, packaging, labeling, placarding, and manifesting of
hazardous waste shipments. These regulations apply to the off-site
shipment of contaminated soils and perhaps spent activated carbon.
Waste materials must be identified, loaded in non-leaking containers,
labeled and placarded as appropriate for the contents, and manifested
to verify that the shipments reach their intended destination.

Applicable

Currently only potentially applicable to transport off site of spent carbon
(if determined to be hazardous waste) from groundwater treatment plant
vapor treatment train.

Surface
Water

[Federal] Clean Water Act
(CWA) 33 USC 1251

National Pollution Discharge Elimination System (NPDES, 40 CFR
122). These regulations govern point source discharges into navigable
waterways such as the Puyallup River. Limits on the concentrations
of contaminants which may be discharged are determined on a case-
by-case basis.

Applicable

Updates/changes to 40 CFR 122 since the 1987 ROD do not affect site or
remedy. Treated groundwater is discharged to City of Tacoma POTW
under their NPDES permit; continues to apply to untreated surface water
discharging from site retention basins into BNSF drainage ditch.

1

-------
OU 3 Attachment 5 - Tacoma Tar Pits ARARs Summary

Media

Source/ARAR Citation

Requirement Synopsis

Status

Current ARAR Evaluation

Surface
Water

[Federal] Federal Water
Quality Criteria

Water quality criteria are established placing limits on the
concentration of compounds in fresh and marine waters. These
criteria may apply to discharges into off-site surface water. The
action levels include water quality criteria for on site and boundary
surface waters.

Applicable

ROD-selected indicator chemicals in surface water are: benzo(a)pyrene,
PCBs, benzene, and lead. 1987 ROD clean up level for lead in surface
water at site boundary was 3.2 ug/1, and was based on chronic freshwater
ambient water quality criteria (CFAWQC) and the detection limit at that
time. Current CFAWQC is 2.5 ug/1 since detection limit has been
reduced. Similarly, clean up level for lead in surface water on the site was
reduced from 172 to 65 ug/1 (during the third FYR period). Surface water
lead concentrations during the fourth FYR period in the "SW" sample
location (BNSF ditch, boundary) did not exceed 1.7 ug/L.

Ground-
water

[Federal] RCRA 42 USC
6901, Subtitle C, 40 CFR
264, Subpart F

Pertains to groundwater monitoring, hazardous constituents,
concentration limits, points of compliance, and corrective action. A
program of groundwater monitoring must be implemented to detect
the presence of contaminants at the point of compliance, which is
usually at site boundaries. If concentrations of particular compounds
are detected above designated limits more extensive monitoring is
necessary and corrective actions may be required.

Relevant and
appropriate

RCRA, 42 USC 6901, Subtitle C was amended in 1984, 1992, and 1996;
however, the substantive requirements that apply to the groundwater
remedy at the Tacoma Tar Pits site (40 CFR 264) remain unchanged
since the time the 1987 ROD was signed and has no impact on the
protectiveness of the groundwater remedy. ROD-selected indicator
chemicals in groundwater are: benzo(a)pyrene, PCBs, benzene, and lead.
ARAR is still relevant and appropriate since benzene in groundwater is
above clean up levels at site boundary.

2

-------
OU 3 Attachment 5 - Tacoma Tar Pits ARARs Summary

Media

Source/ARAR Citation

Requirement Synopsis

Status

Current ARAR Evaluation

Ground-
water

[Federal] Safe Drinking
Water Act (SWDA) 42 USC
300, 40 CFR141

Maximum contaminant levels (MCLs) must be attained for sources of
drinking water. The MCL for lead was included in the action levels.
Drinking water regulations are relevant and appropriate to the lower
aquifers at the site.



ROD-selected indicator chemicals in groundwater are: benzo(a)pyrene,
PCBs, benzene, and lead. Of the 1987 ROD indicator chemicals, lead was
the only one for which the groundwater clean up goal/maximum
allowable contaminant concentration was based solely on its Maximum
Contaminant Level (MCL, 40 CFR 141). At the time of the ROD the
MCL for lead was 50 ug/1; however, in 1992 this value was lowered to 15
ug/1, where it currently remains. These chemicals are at acceptable levels
in the lower aquifers at the site, even considering the lowered action level
for lead. The last time groundwater was tested for lead was in 2001,
where the maximum concentration within the fill/sand aquifers was 14.4
ug/1, and within the lower aquifers was 1.5 ug/1. The ROD requires clean
up criteria be achieved for these chemicals in the upper aquifers at the
site. ARAR including new action level for lead, is still relevant and
appropriate; however, groundwater from all aquifers at/downgradient of
the site is not used for drinking purposes.

3

-------
OU 3 Attachment 5 - Tacoma Tar Pits ARARs Summary

Media

Source/ARAR Citation

Requirement Synopsis

Status

Current ARAR Evaluation

Soil

[State] Washington
Administrative Code (WAC)
17-303-081 to 103

Designation of Dangerous Waste (DW) and Extremely Hazardous
Waste (EHW). The state definition of a hazardous waste incorporates
EPA designation of hazardous waste which is based on the compound
being specifically listed as such or on the waste exhibiting the
properties of reactivity, ignitability, corrosivity, or Extraction
Procedure (EP) toxicity. Ecology distinguishes hazardous waste as
Extremely Hazardous Waste (EHW) or Dangerous Waste (DW). The
distinction is based on the properties of persistence, concentration,
carcinogenicity, mutagenicity, teratogenicity, concentration of certain
compounds, and toxicity. Residues, contaminated soils, water, or
other debris from the clean up of spills of compounds listed on the
"moderately dangerous chemical products list" (WAC 173-303-9903)
in excess of 400 pounds are designated as DW. If the spilled
compounds are listed on the "acutely dangerous chemical products
list" (WAC 173-303-9903), soils, residues, water, or other debris in
excess of 220 pounds are considered EHW. Materials containing
greater than 1 percent PAH are considered EHW when the total
quantity exceeds 220 pounds. However, wastes which were not
designated as hazardous waste at the time of disposal are not
considered DW or EHW.

Relevant and
appropriate

At the time of the ROD, EPA and Ecology had determined that the EHW
classification, while not applicable because on site disposal pre-dated
hazardous waste classification, was relevant and appropriate.

4

-------
OU 3 Attachment 5 - Tacoma Tar Pits ARARs Summary

Media

Source/ARAR Citation

Requirement Synopsis

Status

Current ARAR Evaluation

Surface
Water

[State] WAC 173-201

Water Quality Standards for Surface Waters of the State of
Washington. Surface water bodies are classified according to the
water quality and uses of the water. The surface waters near the site
are classified as follows:

Class B (good) - Puyallup River, Inner Commencement Bay
Class C (fair) - Commencement Bay - City Waterway
Criteria are established for fecal coliform bacteria, dissolved oxygen,
total dissolved gas, temperature, pH, and turbidity. In addition,
concentrations of contaminants must be below levels which may
adversely affect human health, the environment, or uses of the water
body. The criteria and classifications of the State Water Quality
Standards do not apply within a dilution zone defined by Ecology.
Within the dilution zone, fish and shellfish must not be killed or
aesthetic values diminished.

Applicable

Update to 173-201A-240. Fresh Water Designated Uses and
Criteria/Toxic Substances. PCB cleanup level for surface water at site
boundary and groundwater in sand and fill aquifers stated in ROD is 0.2
ug/1 and was based on the chronic freshwater ambient water quality
criterion and detection limit at that time. Since then the State's freshwater
Water Quality Standards criterion for PCBs in surface water have been
reduced to 0.014 ug/1. No PCBs were detected in RI and have been
discontinued since at least 1999, although detection limits have decreased
since the RI. Remedy still protective.

Surface
Water

[State] WAC 173-216

NPDES Permits administered by the State. Discharges of water to off-
site navigable waterways may require an NPDES permit. The
concentration limits of contaminant discharges are determined on a
case-by-case basis.

Applicable

PSE holds Industrial Wastewater Discharge Permit No. TAC-031-2011
authorizing discharge of treated groundwater to Tacoma sanitary sewer.
ARAR still applies.

Surface
Water,
Ground-
water

[State] RCW 90.48, 90.52,
90.54

Water Pollution Control and Discharge Standards. Waters of the
State of Washington, which include surface water and groundwater,
are to be protected to maximize their beneficial use. Materials and
substances which might enter these waters must receive prior
treatment with known, available, and reasonable methods.

Applicable

Powers, duties and functions of water pollution control commission,
director thereof, transferred to Department of Ecology. RCW 90.48
includes oil, sewer, hazardous waste and most discharges. Does not affect
site or remedy. Additional obligations related to oil entering State waters,
fees and credits; does not affect site or remedy.

Surface
Water,
Ground-
water

[State] State Water Code
(RCW 90.03) and Water
Rights (RCW 90.14)

These laws specify the conditions for extracting surface water or
groundwater for nondomestic uses. Water extraction must be
consistent with beneficial uses of the resources and must not be
wasteful. Groundwater extraction wells, which may be used to
control the migration of contamination, must comply with the
substantive requirements necessary to obtain a water rights permit.
Water rights laws may pertain if groundwater is extracted for
treatment.

Applicable

No water code changes that affect site or remedy. No water rights
changes since ROD.

5

-------
OU 3 Attachment 5 - Tacoma Tar Pits ARARs Summary

Media

Source/ARAR Citation

Requirement Synopsis

Status

Current ARAR Evaluation

Ground-
water

[State] WAC 173-303-645

Groundwater protection requirements for waste management
facilities are generally comparable to Federal regulations. The point
of compliance, the determination of dangerous constituents which are
monitored, and the compliance concentrations, however, are
determined by Ecology on a case-by-case basis.

Applicable

Grammatical changes to WAC in 2009 do not affect site or remedy; no
other changes that affect site or remedy.

Ground-
water

[State] WAC 173-154

Upper Aquifers and Upper Aquifer zones must be protected to the
extent practicable to avoid depletions, excessive water level declines,
or reductions in water quality in order to preserve the water for
domestic, stockwater, and similar uses, and preserve spring and
stream flow.

Applicable

These WAC rules have not been updated since the last FYR; site remains
in compliance.

Ground-
water

[State] RCW 13.104 and
WAC 173-160

Minimum standards exist for resource protection and water well
construction, construction reports, and examination and licensing
well construction contractors and equipment operators. These
standards apply if monitoring or extraction wells are installed.

Applicable

Monitoring/extraction wells in upper aquifer zones have been installed in
accordance with WAC 173-360; minor ARAR changes do not affect site
or remedy.

Ground-
water

[State] WAC 173-240

Submission of plans and reports. Ecology must review plans for
wastewater treatment facilities.

Applicable

No changes since ROD.

Air

[State] WAC 173-400-
040(5)

Contaminant air emissions from any sources must not be detrimental
to the health, safety, or welfare of any person and must not damage
any property or business. Emissions from incinerators must satisfy
this requirement.

Applicable

Rule updated in 2005 to conform to recent Federal changes with respect
to new source review. Does not affect site or remedy.

TBC or Other since ROD was issued

Soil,
Surface
water,
Ground-
water

Washington Model Toxics
Control Act (RCW
70.105D.900)

The Washington State Model Toxics Control Act (MTCA) was
promulgated in 1989 under Washington Administrative Code (WAC)
173-340, two years after the Tacoma Tar Pits ROD was signed. It
states that hazardous waste clean up must be conducted in
consideration of human and environmental health. Communities must
be notified of releases of hazardous, clean up remedies, enforcement
of standards, state funding procedures have been modified.

To Be
Considered

This rule established that the appropriate clean up level for sites
undergoing remedial action are the clean up levels in effect at the time
the final clean up action was selected (WAC 173-340-702(12)(a-c)).
Since the ROD identified the final clean up action and clean up levels
prior to the promulgation of MTCA, the original MTCA is not an ARAR.
Likewise, MTCA as amended in February 2001 and October 2007 is not
an ARAR.

6

-------
OU 3 Attachment 5 - Tacoma Tar Pits ARARs Summary

Media

Source/ARAR Citation

Requirement Synopsis

Status

Current ARAR Evaluation

Soil

WAC 16-752, Washington
Noxious Weeds Law

Washington State has enacted laws to control the introduction and
spread of designated, non-native noxious weeds.

To Be
Considered

Spotted Knapweed was observed atop the engineered waste pile cover
during the fourth FYR Site Inspection. Spotted Knapweed is on the
Washington State Class B Noxious Weed List, and is designated for
control in the Tacoma area. This requirement, however, was not deemed
an ARAR or a To Be Considered (TBC) requirement at the Tacoma Tar
Pits site as it does not cause the soil remedy component to be less
protective against potential exposure to hazardous substances for humans
or avian receptors. Should a vegetation management plan be developed
for the site, control of Spotted Knapweed should be a component of that
plan as it is less than optimum habitat for birds.

7

-------