FOURTH FIVE-YEAR REVIEW REPORT FOR
COMMENCEMENT BAY NEARSIIORE/T1 DEFEATS SUPERFUND
SITE
PIERCE COUNTY, WASHINGTON
PRO^°
Prepared by
U.S. Environmental Protection Agency
Region 10
SEATTLE, WASHINGTON
Canii Grandinetti, Program Manager
Remedial Cleanup Program
Date
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Executive Summary
This is the fourth Five-Year Review (FYR) for the Commencement Bay Nearshore/Tideflats
Superfund site (CB/NT site) located in Tacoma, Pierce County, Washington State. The triggering
action for this statutory FYR was the signing of the previous FYR on December 23, 2009. This
National Priorities List (NPL) site is divided into six Operable Units (OUs):
OU 01 Commencement Bay Nearshore/Tideflats Sediments;
OU 02 Asarco Tacoma Smelter Facility (currently renamed OU 20);
OU 03 Tacoma Tar Pits;
OU 04 Asarco Off-Property (referred to as Ruston/North Tacoma Study Area, currently
renamed OU 22);
OU 05 Commencement Bay Nearshore/Tideflats Sources (associated with OU 01); and
OU 06 Asarco Sediments (referred to as Asarco Sediments/Groundwater, currently renamed OU
19).
For the CB/NT site, there are three separate project areas that are being managed as distinct sites.
These project areas include the CB/NT Sediments and Sources (OU 01 and OU 05); the Asarco
Smelter Facility and surrounding impacted areas (OU 20, OU 22, and OU 19); and the Tacoma
Tar Pits (OU 03). The CB/NT Sediments OU (OU 01) includes eight contaminated sediment
Problem Areas within six marine waterways. These Problem Areas consist of the Head and
Mouth of Hylebos Waterway, the Sitcum Waterway, the St. Paul Waterway, the Middle
Waterway, the Head and Mouth of Thea Foss Waterway, and the Wheeler-Osgood Waterway.
The CB/NT Sediments OU also includes two non-time-critical removal actions known as the
Olympic View Resource Area and the Occidental Site. The CB/NT Sources OU (OU 05)
identifies and controls sources of contamination to the marine sediments associated with each of
the eight Problem Areas. The CB/NT Sediments and Sources OUs are under one Record of
Decision (ROD). The CB/NT Asarco OUs (OU 20, OU 22, and OU 19) are addressed by three
RODs, and the Tacoma Tar Pits OU (OU 03) is addressed by one ROD. This FYR addresses all
OUs except for CB/NT Sources (OU 05).
Cleanup of the OUs addressed in this FYR has been conducted by Responsible Parties under
oversight by the U.S. Environmental Protection Agency (EPA).
For CB/NT Sources (OU 05), the Washington Department of Ecology (Ecology) is lead agency
for CB/NT source control actions. The strategic relationship and importance of coordination
between sediment cleanup and source control actions is described in Sections 5.1.5 and 5.2 of the
CB/NT ROD (OU 01 and OU 05). The EPA and Ecology Source Control Strategy (EPA 1992)
states that sediment cleanup will not be implemented until adequate source control efforts have
been implemented to minimize the potential for sediment recontamination. The primary
objective under CB/NT Sources (OU 05) was to control major sources of contamination to the
waterways prior to implementation of sediment remediation in each of eight Problem Areas.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Source control completion in a Problem Area indicated that Ecology and EPA believed that
source control measures were adequate for sediment remedial action to move forward in a
Problem Area. This determination was documented in a Source Control Completion Report that
was approved prior to remedy implementation in each of the eight Problem Areas. For CB/NT
Sources (OU 05), known source control actions were implemented and deemed to be complete
enough to begin sediment remediation, and thus, the protectiveness of those source control
actions does not need to be re-evaluated in discussions for a separate OU (i.e., OU 05 Source
Control) in EPA five-year reviews. Rather, any source control actions that are implemented
under state or state-delegated programs [e.g., state MTCA cleanups, issuance of NPDES permits
to individual permitees as well for the City of Tacoma's Municipal Separate Storm Sewer
System (MS4)] at the site, including actions that require operations and maintenance or long-
term monitoring or reporting activities, are the responsibility of the state. Similar to Superfund,
state MTCA regulations (WAC 173-340-420) require a review of post-cleanup conditions and
monitoring data that may be required at least every five years to ensure that human health and
the environment are being protected. In addition, since approximately 2004, known remaining
source control actions that require EPA Superfund regulatory oversight and affect the
protectiveness of a completed sediment remedy in a problem area are discussed for each unique
Problem Area. Additional details on the source control strategy are described in Section 4 of the
2004 five-year review for the CB/NT site.
The purpose of an FYR is to determine whether the remedy at a site is protective of human
health and the environment. In addition, FYR reports identify issues or deficiencies found
during the review, if any, and provide recommendations to address them.
Brief site descriptions are summarized below.
Commencement Bay Nearshore/Tideflats Sediments (OU 01)
The CB/NT Sediments OU 01 is located in Tacoma, Washington at the southern end of the main
basin of Puget Sound (Figure 4-1). The site encompasses an active commercial seaport and
includes 10-12 square miles of shallow water, shoreline, and adjacent land, most of which is
highly developed and industrialized. The marine and estuarine portions of the site also support
important recreational and tribal fisheries. The site is located in a tribal Usual and Accustomed
fishing area.
Contaminants in the CB/NT area originate from both upland and in-water sources. Early
industrial surveys conducted by the Tacoma-Pierce County Health Department (TPCHD) and the
Port of Tacoma indicated that there are more than 281 active industrial facilities in the CB/NT
area. With industrialization, the release of hazardous substances and waste materials into the
environment resulted in alterations to the chemical quality of waters and sediments in many areas
of the bay. Contaminants found in the nearshore area include arsenic, lead, zinc, cadmium,
copper, mercury, and various organic compounds such as polychlorinated biphenyls (PCBs),
polycyclic aromatic hydrocarbons (PAHs), and phthalates.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
The cleanup goal for the Commencement Bay problem areas is reduction of contaminant
concentrations in sediments to levels that will support a healthy marine environment and will
protect the health of people eating seafood from the bay1'2. The ROD designated biological test
requirements and associated sediment chemical concentrations referred to as Sediment Quality
Objectives (SQOs) in order to achieve this goal. SQOs for all problem chemicals were set based
on an evaluation of the ecological and human health risks posed by these chemicals. The SQO
for PCBs was based on the human health risk assessment. SQOs for all other chemicals were
based on the ecological risk assessment because the ecologically-based cleanup levels were
determined to be also protective of human health. A specific cleanup level/cleanup objective
based on seafood tissue data was not a requirement identified in the ROD or ESDs for the site,
and has not been derived as a performance standard for any of the response actions in
Commencement Bay based on ARARs in the ROD. While the ROD and ESDs for the CB/NT
site use the term "cleanup goal," it is clear that the intent of that language, with respect to the
protection of the health of people eating seafood from the Bay, is that the term "cleanup goal" is
synonymous with EPA's current terminology "remedial action objective (RAO)" Given that the
term "RAO" is not used in EPA's decision documents for the site, the term "remedial objective"
will be used in this FYR for discussion pertaining to the cleanup goal related to human health
concerns. Recent fish tissue data for bioaccumulative chemicals have not been collected in
Commencement Bay and evaluated, so it is not known whether contaminant levels in fish tissues
have been reduced since the remedies have been implemented, particularly for PCBs (which
have a human-health based Sediment Quality Objective).
The ROD selected a cleanup remedy that identified eight problem areas for sediment cleanup and
allowed flexibility to use any one, or a combination of, five key elements in any particular area.
As described in the Declaration and Section 10.2 of the ROD, these elements are: 1) site use
restrictions to reduce potential human health exposure to site contamination, particularly
ingestion of contaminated seafood, 2) source control to prevent recontamination of sediments
and meet Applicable or Relevant and Appropriate Requirements (ARARs), 3) natural recovery
for marginally contaminated sediments that are predicted to achieve acceptable sediment quality
within a reasonable timeframe, 4) sediment remedial action to address sediments containing
contamination that is expected to persist for unacceptable periods of time, using in-place
capping, dredging/confined aquatic disposal, dredging/nearshore disposal, and dredging/upland
disposal, and 5) source and sediment monitoring to characterize the effectiveness of source
controls and identify whether additional actions are necessary to ensure that all necessary
remedial actions have been undertaken in each problem area and to evaluate the effectiveness of
the components of the remedy (including disposal sites and habitat mitigation/restoration areas)
in achieving the sediment quality objectives and in relation to habitat function.
1 Since the CB/NT ROD (EPA 1989) for the Sediments and Source Control OUs was written prior to EPA's (1991,
1999) guidance on preparation of Proposed Plans and RODs, the short narrative statements defining "remedial
action objectives" that are provided in recent RODs are not present in the CB/NT ROD.
2 As described in the CB/NT ROD (EPA 1989; Declaration, p. 1), the overall goal of the selected remedy is "to
protect the marine environment and thereby reduce associated public health concerns." The selected remedy "is
protective of the marine environment and related human health concerns" (ROD; Declaration, p. 2). The subsequent
PCB ESD (EPA 1997; p.4) reiterated that the cleanup goal for the Commencement Bay problem areas is to achieve
reduction of contaminant concentrations in sediments [emphasis added] to levels that will support a healthy marine
environment and will protect the health of people eating seafood from the Bay.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
For each CB/NT Waterway Problem Area, and the two Non-Time-Critical Removal Action
areas, a summary of issues, recommendations, and protectiveness statements is provided in the
FYR Summary Form following this Executive Summary. The protectiveness statements are also
provided below.
Commencement Bay Nearshore/Tideflats, Waterway Problem Areas and Removal Action
Areas (OU 01)
For the Hylebos Waterway, the remedy is expected to be protective of human health and the
environment upon completion. In the interim, remedial action construction completed to date
has adequately addressed all exposure pathways that could result in unacceptable risks in those
areas. Remedial action construction has been accomplished under the Head and Mouth of
Hylebos Waterway Consent Decrees, whereas work being performed pursuant to the Occidental
Site Administrative Order on Consent is at the end of Remedial Investigation and the beginning
of the Feasibility Study. Also, work being performed at the Arkema site pursuant to a state
MTCA Agreed Order is in the RI/FS phase, with EPA coordination and oversight.
For the Sitcum Waterway, the remedy has been successfully completed, and all required long-
term monitoring efforts have been completed. The remedy remains protective of human health
and the environment, and exposure pathways that could result in unacceptable risks are being
controlled.
For the St. Paul Waterway, the remedial actions have been successfully completed, and all
required long-term monitoring efforts have been completed. The remedy remains protective of
human health and the environment, and exposure pathways that could result in unacceptable
risks are being controlled.
For the Middle Waterway, all remedial actions have been completed, the remedy is currently
protective of human health and the environment, and exposure pathways that could result in
unacceptable risks are being controlled. In order for the remedy to be protective in the long-term,
the Sediment Quality Objectives need to be met according to the timeframes established in the
Middle Waterway Explanation of Significant Differences (ESDs), or any exceedances need to be
shown to be biologically insignificant in all enhanced natural recovery (ENR) and natural
recovery areas, and ICs must be fully implemented.
For the Olympic View Resource Area, the remedy is protective of human health and the
environment. All long-term monitoring efforts have been completed, and exposure pathways
that could result in unacceptable risks are being controlled.
For the Thea Foss and Wheeler-Osgood Waterways, the remedy is protective of human health
and the environment. Sediment COC concentrations in the waterway have decreased since
completing the sediment remedial actions, indicating that the caps installed in the waterway are
stabilizing and performing as designed (no upward migration of contamination has been
documented). Cap integrity monitoring, which includes visual and hydrographic survey work,
indicates that capped and natural recovery areas are stabilizing and meeting performance criteria
in much of the waterway. The capped and natural recovery areas in a large portion of the
waterway are supporting benthic communities. Institutional controls have been put in place that
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
enhance the long-term integrity of the remedy. The City of Tacoma has implemented an
aggressive stormwater monitoring and source control program that has reduced contamination
entering the waterway. That program is expected to continue into the foreseeable future.
Taken as a whole, the remedies for the Sediments OU are expected to be protective when
completed. In the interim, remedial activities completed to date have adequately addressed all
exposure pathways that could result in unacceptable risks in those areas. Until site remedial
objectives are met [see Section 4.1.1], site use restrictions (i.e., fish and shellfish consumption
advisories) shall remain in effect to limit human exposure to contaminated seafood. The absence
of fish tissue contaminant data does not mean that the remedy is not protective (see EPA 2001, p.
4-14). Recent fish tissue data for bioaccumulative chemicals have not been collected in
Commencement Bay and evaluated, so it is not known whether contaminant levels in fish tissues
have been reduced since the remedies have been implemented, particularly for PCBs (which
have a human-health based Sediment Quality Objective). Future fish tissue sampling results will
be used along with other lines of evidence to evaluate protectiveness of the remedies in the long-
term.
Commencement Bay Nearshore/Tideflats, Asarco Area (OUs 20, 22 and 19)
The Asarco portions of the CB/NT Superfund site consist of the Asarco Smelter Facility (Asarco
Smelter; OU 20, also known as OU 2), which consists of the Smelter property and the slag
peninsula; the Ruston/North Tacoma Study Area (Study Area; OU 22, also known as OU 4),
which consists of contaminated properties in an approximate one-mile arc surrounding the
smelter; and the Asarco Sediments/Groundwater (Asarco Sediments; OU 19, also known as OU
6), which encompasses the sediments offshore of the smelter and the Yacht Basin formed by the
slag peninsula.
The Asarco Smelter is located along the Commencement Bay shoreline within the municipal
boundaries of Ruston and Tacoma, Washington. The upland portion of the Smelter Facility is
approximately 100 acres in size, and encompasses a 67-acre former smelter (currently being
redeveloped) and a 23-acre slag breakwater peninsula. Operation of the Asarco smelter for over
95 years resulted in contamination, primarily with arsenic and lead, of the smelter site, offshore
sediments, and the surrounding residential area.
For the Asarco Smelter, the remedy is expected to be protective of human health and the
environment upon completion (i.e., once all redevelopment has been completed by Point Ruston
LLC). In the interim, remedial activities completed to date have adequately addressed all
exposure pathways that could result in unacceptable risks in those areas. Exposure pathways that
could result in unacceptable risks are being prevented because the site is being controlled by the
developer during construction using best management practices as described in the Development
and Occupancy Plan (Hydrometrics 2013b). For areas that have already been constructed, O&M
requirements to maintain protectiveness are described in the Operation, Maintenance and
Monitoring Plan (Hydrometrics 2013a). Within the next FYR period, EPA anticipates repairing
the habitat basin and completing the armoring of the remaining portions of the slag peninsula
shoreline that required armoring as part of the remedy in the ROD.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
For the Asarco Ruston/North Tacoma Study Area, the remedy is protective of human health and
the environment. The Expedited Response Action in 1989-91 at 10 non-residential high-use
areas addressed immediate concerns. The subsequent removal/replacement of soils with
concentrations above the action level brought long-term risk exposures within EPA's acceptable
risk range. These cleanup actions were completed in 2012. Community protection measures,
mostly educational in nature, are in place for those areas that have soil arsenic concentrations
between the MTCA cleanup level of 20 ppm and the EPA action level of 230 ppm. Ecology has
assumed responsibility for all future work, including properties where owners have refused
sampling or cleanup.
For the Asarco Sediments, the remedy is expected to be protective of human health and the
environment upon completion, once Point Ruston LLC and EPA have implemented the remedy
for the Yacht Basin sediments. In the interim, remedial activities completed to date in the capped
offshore sediments (i.e., where the remedy has been implemented) have adequately addressed all
exposure pathways that could result in unacceptable risks in those areas.
Commencement Bay Nearshore/Tideflats, Tacoma Tar Pits (OU 03)
The Tacoma Tar Pits OU is located in Tacoma, Washington, within the Tacoma Tideflats
industrial area near Commencement Bay. It is situated on a peninsula of land located between
the Puyallup River and the Thea Foss Waterway, approximately three-quarters of a mile north of
Interstate 5 (Figure 6-1). The total area of the site encompasses approximately 52 acres, and
several active facilities are currently within the site boundaries including Simon Metals (a metals
recycling business), the Northwest Detention Center (NWDC; an immigration detention facility),
and a capped engineered waste pile and groundwater treatment plant constructed as part of the
remedial action for the site.
Results of site investigations conducted in the 1980s indicated that soil, surface water, and
groundwater across most of the site were contaminated with organic and inorganic contaminants
from former onsite coal gasification plant operations and the recycling of automobiles and
electrical transformers. The primary contaminants included metals, PAHs, PCBs, and various
volatile organic compounds (VOCs), including benzene. Soil and surface water cleanup criteria
have been achieved; in 1998, due to continued exceedances of the groundwater cleanup criteria,
EPA directed the PRP to design and install a groundwater extraction and treatment system to
treat on-site groundwater contamination (focused on benzene) and to prevent it from migrating
off site and potentially impacting the Puyallup River. The groundwater extraction and treatment
has been operating since 2002.
The results of this FYR indicate that the Tacoma Tar Pits remedy is functioning as intended and
currently protects human health and the environment in the short-term because 1) sources of
contamination (e.g., waste materials and contaminated soils) have been excavated, disposed of
off site or treated and contained on site, 2) low permeability caps and surface water controls have
been placed across critical areas of the site, 3) institutional controls that prohibit using site
groundwater are in place, and 4) the groundwater extraction and treatment system has contained
contaminated groundwater such that exposures are under control and there are no unacceptable
risks to humans or the environment, e.g. contaminated site groundwater is not being used as, or
migrating to, a drinking water source nor is it discharging to the downgradient Puyallup River.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
However, in order for the remedy to remain protective over the long-term, the follow-up actions
recommended in this report need to be implemented which include 1) continuing maintenance of
the cap, cover and ancillary surface water drainage features, 2) optimizing all property owner
compliance with institutional control requirements, and 3) continuing operation and optimization
of the groundwater extraction, treatment and monitoring systems to reduce the size and
concentration of the benzene-contaminated groundwater plume across the site.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Five-Year Review Summary Form
SITE IDENTIFICATION
Site Name: Commencement Bay Nearshore/Tideflats (CB/NT)
EPA ID:
WAD980726368
Region: 10
State: WA
City/County: Tacoma/Pierce County
NPL Status: Final
Multiple OUs?
Yes
Has the site achieved construction completion?
No
Lead agency: EPA
[If "Other Federal Agency", enter Agency name]'.
Author name (Federal or State Project Manager): Nancy Harney, Karen Keeley, Tamara
Langton, Kevin Rochlin, Bill Ryan, Jonathan Williams
Author affiliation: US EPA Region 10
Review period: December 2013 to December 2014
Date of site inspection: Ongoing at each waterway and/or each Operable Unit
Type of review: Post-SARA
Review number: Fourth
Triggering action date: Previous FYR report signed on December 23, 2009
Due date (fiveyears after triggering action date): December 23, 2014
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Five-Year Review Summary Form (continued)
Issues/Recommendations
()l (s) w it lion I Issiies/Reconinieiuliilions I clout ilicil in (ho l"i\o-Yoar Kc\ic\\:
Asarco Smelter (OU 20)
()l (s) w it lion I Issiies/Reconinieiuliilions Identified in (ho li\e-Ye;ir Rexiew:
Ruston/North Tacoma Study Area (OU 22)
()l (s) withoul Issues/Reconinienditlions Identified in (ho l"i\o-Yoar Rexiew:
Asarco Sediments (OU 19)
Issnos and Recomiiienditlioiis Identified in (ho l"i\o-Yoar Rexiew:
OU(s): 01,
CB/NT
Sediments
Issue Category: Monitoring
Issue: Recent fish tissue data for bioaccumulative chemicals have not been
collected in Commencement Bay. Thus, it is not known whether contaminant
levels in fish tissues have been reduced since the remedies have been
implemented, particularly for PCBs (which have a human-health based Sediment
Quality Objective), and whether fish advisories should be continued, modified, or
removed.
Recommendation: Develop and implement a Quality Assurance Project Plan,
including a sampling plan for collection and analysis of bay-wide fish tissue data
for bioaccumulative chemicals (particularly for PCBs, which have a human-health
based Sediment Quality Objective). Provide results to appropriate state and local
agencies to evaluate protectiveness of health-based fish consumption advisories
for Commencement Bay.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight Party
Milestone Date
No
Yes
EPA
EPA
December 2019
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Five-Year Review Summary Form (continued)
OU(s): 03,
Tacoma Tar Pits
Issue Category: Remedy Performance
Issue: Benzene concentrations in the groundwater plume within the sand aquifer
continue to exceed ROD criterion across the site.
Recommendation: Evaluate and address issues related to benzene exceedances
and make recommendations for optimizing the groundwater extraction and
treatment (GWET) system and the groundwater monitoring systems to reduce the
benzene plume.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight Party
Milestone Date
No
Yes
PRP
EPA
December 2019
OU(s): 03,
Tacoma Tar Pits
Issue Category: Remedy Performance
Issue: The ROD groundwater remedy and RAOs focused on treatment and
containment of the contaminated plume, but do not appear to have considered
groundwater restoration.
Recommendation: Evaluate whether groundwater restoration at this site is
feasible and necessary to 1) comply with ARARs, CERCLA, and EPA's
CERCLA groundwater policies, and 2) ensure long-term protectiveness.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight Party
Milestone Date
No
Yes
EPA
EPA
December 2019
OU(s): 03,
Tacoma Tar Pits
Issue Category: Institutional Controls
Issue: Property owner compliance with site institutional control requirements is
not optimal.
Recommendation: Request site property owners to comply with all Consent
Decree conveyance of site/institutional control requirements. Voluntary
compliance with the state of Washington's Uniform Environmental Covenants
Act (UECA) should also be requested to ensure the long-term effectiveness of site
institutional controls.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight Party
Milestone Date
No
Yes
Other
EPA
December 2019
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Five-Year Review Summary Form (continued)
Protectiveness Statement(s)
Include each individual OU protectiveness determination and statement. If you need to add more
protectiveness determinations and statements for additional OUs, copy and paste the table below as
many times as necessary to complete for each OU evaluated in the FYR report.
Operable Unit: Protectiveness Determination: Addendum Due Date
01, CB/NT Sediments Will be Protective (if applicable):
Click here to enter date.
Protectiveness Statement:
Taken as a whole, the remedies for the Sediments OU are expected to be protective when completed.
In the interim, remedial activities completed to date have adequately addressed all exposure pathways
that could result in unacceptable risks in those areas. Until site remedial objectives are met (see
Section 4.1.1), site use restrictions (i.e., fish and shellfish consumption advisories) shall remain in
effect to limit human exposure to contaminated seafood. The absence of fish tissue contaminant data
does not mean that the remedy is not protective (see EPA 2001, p. 4-14). Recent fish tissue data for
bioaccumulative chemicals have not been collected in Commencement Bay and evaluated, so it is not
known whether contaminant levels in fish tissues have been reduced since the remedies have been
implemented, particularly for PCBs (which have a human-health based Sediment Quality Objective).
Future fish tissue sampling results will be used along with other lines of evidence to evaluate
protectiveness of the remedies in the long-term. Please note that protectiveness statements for each
Problem Area Waterway (e.g., Hylebos, Sitcum, St. Paul, Middle, Thea Foss, and Wheeler-Osgood
Waterways) and the removal action are provided in Section 8.
Operable Unit: Protectiveness Determination: Addendum Due Date
OU 20, Asarco Smelter Will be Protective (if applicable):
Click here to enter date.
Protectiveness Statement:
The remedy is expected to be protective of human health and the environment upon completion (i.e.,
once all redevelopment has been completed by Point Ruston LLC). In the interim, remedial activities
completed to date have adequately addressed all exposure pathways that could result in unacceptable
risks in those areas. Exposure pathways that could result in unacceptable risks are being prevented
because the site is being controlled by the developer during construction using best management
practices as described in the Development and Occupancy Plan (Hydrometrics 2013b). For areas that
have already been constructed, O&M requirements to maintain protectiveness are described in the
Operation, Maintenance and Monitoring Plan (Hydrometrics 2013a). Within the next FYR period,
EPA anticipates repairing the habitat basin and completing the armoring of the remaining portions of
the slag peninsula shoreline that required armoring as part of the remedy in the ROD.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Five-Year Review Summary Form (continued)
Operable Unit: Protectiveness Determination: Addendum Due Date
OU22, Ruston/North Protective (if applicable):
Tacoma Study Area Click here to enter date.
Protectiveness Statement:
The remedy is protective of human health and the environment. The Expedited Response Action in
1989-91 at 10 non-residential high-use areas addressed immediate concerns. The subsequent
removal/replacement of soils above the action level brought long-term risk exposures within EPA's
acceptable risk range. These cleanup actions were completed in 2012. Community protection
measures, mostly educational in nature, are in place for those areas that have soil arsenic
concentrations between the MTCA cleanup level of 20 ppm and the EPA action level of 230 ppm.
Ecology has assumed responsibility for all future work, including properties where owners have
refused sampling or cleanup.
Operable Unit: Protectiveness Determination: Addendum Due Date
OU 19, Asarco Sediments Will be Protective (if applicable):
Click here to enter date.
Protectiveness Statement:
The remedy is expected to be protective of human health and the environment upon completion, once
Point Ruston LLC and EPA have implemented the remedy for the Yacht Basin sediments. In the
interim, remedial activities completed to date in the capped offshore sediments (i.e., where the remedy
has been implemented) have adequately addressed all exposure pathways that could result in
unacceptable risks in those areas.
Operable Unit: Protectiveness Determination: Addendum Due Date
03, Tacoma Tar Pits Short-term Protective (if applicable):
Click here to enter date.
Protectiveness Statement:
The results of this FYR indicate that the Tacoma Tar Pits remedy is functioning as intended and
currently protects human health and the environment in the short-term because 1) sources of
contamination (e.g., waste materials and contaminated soils) have been excavated, disposed of off site
or treated and contained on site, 2) low permeability caps and surface water controls have been placed
across critical areas of the site, 3) institutional controls that prohibit using site groundwater are in
place, and 4) the groundwater extraction and treatment system has contained contaminated
groundwater such that exposures are under control and there are no unacceptable risks to humans or
the environment, e.g. contaminated site groundwater is not being used as, or migrating to, a drinking
water source nor is it discharging to the downgradient Puyallup River. However, in order for the
remedy to remain protective over the long-term, the follow-up actions recommended in this report
need to be implemented which include 1) continuing maintenance of the cap, cover and ancillary
surface water drainage features, 2) optimizing all property owner compliance with institutional control
requirements, and 3) continuing operation and optimization of the groundwater extraction, treatment
and monitoring systems to reduce the size and concentration of the benzene-contaminated groundwater
plume across the site.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Five-Year Review Summary Form (continued)
Sitewide Protectiveness Statement (not applicable)
For sites that have achieved construction completion, enter a sitewide protectiveness determination
and statement.
Protectiveness Determination: Addendum Due Date (if applicable):
Choose an item. Click here to enter date.
Protectiveness Statement:
Click here to enter text.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Table of Contents
1. Introduction 1
2. Site Chronology 3
3. Background 3
3.1. Site Location and Description 3
3.2. Land and Resource Use 3
3.3. History of Contamination 4
3.4. Initial Response 4
3.4.1. Commencement Bay Nearshore/Tideflats Sediments 4
3.4.2. Asarco Area 4
3.4.3. Tacoma Tar Pits 4
3.5. Basis for Taking Action 4
3.5.1. Commencement Bay Nearshore/Tideflats Sediments 4
3.5.2. Asarco Area 4
3.5.3. Tacoma Tar Pits 5
4. Remedial Actions and Five-Year Review Process for CB/NT Sediments Operable Unit 01
("Problem Area Waterways") 6
4.1. Remedy Selection 6
4.1.1. Cleanup Objectives 6
4.1.2. Selected Remedy 10
4.1.3. Source Control Strategy 11
4.1.4. Explanation of Significant Differences 11
4.1.5. Sitewide Biological Assessment 11
4.1.6. Sitewide 404(b)(1) Analysis 11
4.1.7. Dredged Material and Disposal Sites 11
4.1.8. CERCLA Removal Actions 11
4.1.9. Puyallup Land Settlement 14
4.1.10. Partial Deletion of the Site 14
4.2. Hylebos Waterway 14
4.2.1. Background 14
4.2.2. Site Chronology 15
4.2.3. Remedial Actions 15
4.2.4. Progress since the Last Five-Year Review 26
4.2.5. Five-Year Review Process 27
4.2.6. Technical Assessment 28
4.2.7. Issues and Recommendations/Follow-up Actions 30
4.2.8. Protectiveness Statement 30
4.3. Sitcum Waterway 30
4.3.1. Background 30
4.3.2. Site Chronology 31
4.3.3. Remedial Actions 31
4.3.4. Progress since the Last Five-Year Review 33
4.3.5. Five-Year Review Process 34
4.3.6. Technical Assessment 36
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4.3.7. Issues and Recommendations/Follow-up Actions 37
4.3.8. Protectiveness Statement 37
4.4. St. Paul Waterway 37
4.4.1. Background 37
4.4.2. Site Chronology 37
4.4.3. Remedial Actions 37
4.4.4. Progress since the Last Five-Year Review 38
4.4.5. Five-Year Review Process 38
4.4.6. Technical Assessment 41
4.4.7. Issues and Recommendations/Follow-up Actions 42
4.4.8. Protectiveness Statement 42
4.5. Middle Waterway 42
4.5.1. Background 42
4.5.2. Site Chronology 42
4.5.3. Remedial Actions 43
4.5.4. Progress since the Last Five-Year Review 49
4.5.5. Five-Year Review Process 51
4.5.6. Technical Assessment 56
4.5.7. Issues and Recommendations/Follow-up Actions 60
4.5.8. Protectiveness Statement 60
4.6. Olympic View Resource Area 60
4.6.1. Background 60
4.6.2. Site Chronology 60
4.6.3. Removal Actions 60
4.6.4. Progress since the Last Five-Year Review 61
4.6.5. Five-Year Review Process 61
4.6.6. Technical Assessment 63
4.6.7. Issues and Recommendations/Follow-up Actions 64
4.6.8. Protectiveness Statement 64
4.7. Thea Foss and Wheeler-Osgood Waterways 64
4.7.1. Background 64
4.7.2. Site Chronology 64
4.7.3. Remedial Actions 65
4.7.4. Progress since the Last Five-Year Review 90
4.7.5. Five-Year Review Process 90
4.7.6. Technical Assessment 92
4.7.7. Issues and Recommendations/Follow-up Actions 94
4.7.8. Protectiveness Statement 94
4.8. CB/NT Sediments OU 01, OU-wide Issue 95
4.8.1. CB/NT Sediments OU 01, OU-wide Issue and Recommendation/Follow-up
Action 95
4.8.2. Progress since the Last Five-Year Review 101
4.8.3. Issues and Recommendations/Follow-up Actions 103
4.8.4. Protectiveness Statement 103
4.9. CB/NT Sediments OU 1, Commencement Bay Environmental Data 103
5. Remedial Actions and Five-Year Review Process for CB/NT Asarco Operable Units 20, 22,
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and 19 106
5.1. Background 106
5.2. Site Chronology 107
5.2.1. Recent Site Chronology 107
5.2.2. Asarco Bankruptcy Information and Summary of Enforcement Actions 108
5.3. Remedial Actions 110
5.3.1. Remedy Selection 110
5.3.2. Remedy Implementation Ill
5.3.3. Post-Construction Monitoring/Operation and Maintenance 118
5.4. Progress since the Last Five-Year Review 118
5.4.1. Previous Protectiveness Statements 119
5.4.2. Status of Recommendations 119
5.5. Five-Year Review Process 121
5.6. Technical Assessment 123
5.6.1. Technical Assessment Summary 125
5.7. Issues and Recommendations/Follow-up Actions 126
5.8. Protectiveness Statement 126
6. Remedial Actions and Five-Year Review Process for CB/NT Tacoma Tar Pits Operable Unit
03 127
6.1. Background 127
6.2. Site Chronology 128
6.3. Remedial Actions 128
6.3.1. Remedy Selection 128
6.3.2. Explanation of Significant Differences 128
6.3.3. Remedy Implementation 128
6.3.4. Post-Construction Monitoring/Operation and Maintenance 128
6.3.5. Remedy and O&M Costs 129
6.4. Progress since the Last Five-Year Review 129
6.4.1. Previous Protectiveness Statement 129
6.4.2. Status of Recommendations 130
6.5. Five-Year Review Process 133
6.5.1. Administrative Components 133
6.5.2. Community Involvement 133
6.5.3. Document Review 134
6.5.4. Data Review and Evaluation 134
6.5.5. Site Inspection 141
6.5.6. Interviews 141
6.5.7. Identification of Institutional Controls 142
6.6. Technical Assessment 142
6.6.1. Technical Assessment Summary 145
6.7. Issues and Recommendations/Follow-up actions 146
6.8. Protectiveness Statement 146
7. Summary of Issues and Recommendations/Follow-Up Actions 147
8. Summary of Protectiveness Statements 153
8.1. OU 01 CB/NT Sediments, OU-Wide 153
8.1.1. OU 01 CB/NT Sediments, Hylebos Waterway 153
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8.1.2. OU 01 CB/NT Sediments, Sitcum Waterway 153
8.1.3. OU 01 CB/NT Sediments, St. Paul Waterway 153
8.1.4. OU 01 CB/NT Sediments, Middle Waterway 154
8.1.5. OU 01 CB/NT Sediments, Olympic View Resource Area 154
8.1.6. OU 01 CB/NT Sediments, Thea Foss and Wheeler-Osgood Waterways 154
8.2. OU 20 Asarco Smelter, CB/NT Asarco Area 154
8.3. OU 22 Ruston/North Tacoma Study Area, CB/NT Asarco Area 155
8.4. OU 19 Asarco Sediments, CB/NT Asarco Area 155
8.5. OU 3 CB/NT Tacoma Tar Pits 155
9. Next Review 155
Tables (located within body of text)
Table 4-1. Sediment Cleanup Levels, identified as Sediment Quality Objectives 6
Table 4-2. Recommendations for Middle Waterway from the Third FYR and Progress 50
Table 4-3. Areas A and B Post-Remediation Chemical Exceedances for 2007 through 2012
(Sediment SQO Exceedances Only) 55
Table 4-4. Area C Post-Remediation (Sediment SQO Exceedances Only) 56
Table 5-1. 2006 Implementation Schedule for Point Ruston LLC for Remedial Action 109
Table 5-2. Recommendations for Asarco OUs from the Third FYR and Progress 120
Table 6-1. Recommendations for Tacoma Tar Pits OU from the Third FYR and Progress 130
Table 6-2. Tacoma Tar Pits Areas Subject to I&M, and Current Condition 134
Table 6-3. Mann-Kendall Test for Trends in East Branch Boundary & Downgradient Wells
(2009-2013) 138
Table 6-4. Mann-Kendall Test for Trends in North Branch Boundary & Downgradient Wells
(2009-2013) 139
Table 7-1. Summary of Issues and Recommendations/Follow-up Actions for the 2014 FYR . 147
Table 7-2. Action Items That Do Not Affect Remedy Protectiveness 149
Figures (located after text)
Figure 3-1. Mitigation and Restoration Projects
Figure 4-1. Commencement Bay Nearshore/Tideflats Vicinity Map
Figure 4-2. Vibracore sample locations in Hylebos Waterway
Figure 4-3. Sediment Management Unit (SMU) Locations for Middle Waterway, Areas A and B
Figure 4-4. Additional Response Actions in Middle Waterway, Area A
Figure 4-5. Before and After Photos for Middle Waterway, Area A
Figure 4-6. Final EPA-Approved Remedies Applied to Middle Waterway, Areas A and B
Figure 4-7. Prior Remedial Actions Completed in Middle Waterway, Area C
Figure 4-8. Surface Sample and Dive Transect Locations for Year 8 (2012) Sampling
Figure 4-9. Excavated Areas with 2009 Backfill Sample Collection Locations (SMU 51a)
Figure 4-10. Year 5 (2009) Sediment Cap Sample Locations in SMU 51b
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Figure 4-11. Excavated Areas with 2013 Backfill Sample Collection Locations (SMU 51a)
Figure 4-12. Year 10 (2013) Sediment Cap Sample Locations in SMU 51b
Figure 4-13. Olympic View Resource Area (Site) and Other Waterways
Figure 4-14. Olympic View Resource Area govME Website
Figure 4-15. Olympic View Resource Area No Anchor Flyer
Figure 4-16. Thea Foss and Wheeler-Osgood Waterways
Figure 4-17a. Thea Foss and Wheeler-Osgood Completed Remedial Action Areas - Part 1 of 2
Figure 4-17b. Thea Foss and Wheeler-Osgood Completed Remedial Action Areas - Part 2 of 2
Figure 4-18a. SQO Exceedances in Year 7 (2013) - Part 1 of 2
Figure 4-18b. SQO Exceedances in Year 7 (2013) - Part 2 of 2
Figure 4-19. Utilities' OMMP Monitoring Locations
Figure 4-20. Puget Sound Recreational Marine Areas
Figure 4-21. Station Locations for the 2008 Urban Waters Initiative Sediment Study
Figure 5-1. Map of Asarco Area Sites (not including Ruston / North Tacoma Study Area)
Figure 5-2. Taxpayer Parcel Map
Figure 5-3. Locations of Former Asarco Docks in Commencement Bay
Figure 5-4. Map of Ruston/North Tacoma Study Area Zones
Figure 5-5. Map of Sediments OU (OU 6 = OU 19)
Figure 5-6. Map of Slag Peninsula Showing Areas Where Work is Planned
Figure 5-7. Approximate Location of Shallow Yacht Basin Sediments for Excavation
Figure 5-8. Offshore Sediments Capped by Point Ruston LLC
Figure 5-9. Map of Point Ruston Planned Development
Figure 5-10. 2011 Former Dock Areas Capped by DNR
Figure 6-1. Tacoma Tar Pits Site Vicinity Map
Figure 6-2. Tacoma Tar Pits Site Features
Figure 6-3. Photo of 2013 Asphalt Crack Repair in Detention Basin
Figure 6-4. Aquifer Locations and Vertical Profile of Probe Sampling Results
Figure 6-5. Benzene Influent Concentrations through 2013
Figure 6-6. Sampling Locations
Figure 6-7. Benzene Plume as of December 2013 and Data for Wells DOF-35M, DOF-36M
Figure 6-8. Groundwater Contours in Sand Aquifer as of December 2013
Figure 6-9. Benzene Plume as of December 2009
Attachments (located after text)
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]
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OU 20, 22, and 19 Attachments
OU 20, 22, and 19 Attachment 1 - List of Documents Reviewed
OU 20, 22, and 19 Attachment 2 - Site Inspection 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
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Acronyms and Abbreviations
AET Apparent Effects Threshold
AKART All Known, Available, and Reasonable Treatment
AOC Administrative Order on Consent
APP Associated Petroleum Products
ARAR Applicable or Relevant and Appropriate Requirement
BBP benzyl butyl phthalate
BEHP bis(2-ethylhexyl)phthalate (also known as di(2-ethylhexyl)phthalate; DEHP)
BMP best management practice
BNRR Burlington Northern Railroad
BNSF Burlington Northern/Santa Fe
CB/NT Commencement Bay Nearshore/Tideflats
CD Consent Decree
CDF confined disposal facility
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFAWQC chronic freshwater ambient water quality criteria
CFR Code of Federal Regulations
CHB Citizens for a Healthy Bay
COC contaminant of concern
CSC Correctional Services Corporation
CSI Comprehensive Supplemental Investigation
CSL cleanup screening level
CSM Conceptual Site Model
cy cubic yards
DDT di chl orodiphenyltri chl oroethane
DMMP Dredged Material Management Program
DNAPL Dense, non-aqueous phase liquid
DNR Washington State Department of Natural Resources
DOF Dalton, Olmsted & Fuglevand, Inc.
DOH Washington State Department of Health
E&E Ecology and Environment
Ecology Washington State Department of Ecology
ENR enhanced natural recovery
EPA U.S. Environmental Protection Agency
ESA Endangered Species Act
ESD Explanation of Significant Differences
FS Feasibility Study
FWDA Foss Waterway Development Authority
FYR Five-Year Review
GCL geocomposite clay liner
gpm gallons per minute
HCC Hylebos Cleanup Committee
HDPE high-density polyethylene
HP AH high molecular weight polycyclic aromatic hydrocarbons
IA Interagency Agreement
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IC
Institutional Control
IDDE
illicit discharge detection and elimination
JS&S
Joseph Simon & Sons
LMRP
Long-term Monitoring and Reporting Plan
LP AH
low molecular weight polycyclic aromatic hydrocarbon
LTMP
Long-Term Monitoring Plan
LWD
large woody debris
MAROS
Monitoring and Remediation Optimization Software
MCL
Maximum Contaminant Level
mg/kg
milligrams per kilogram
MLLW
mean lower low water
MOU
Memorandum of Understanding
MTCA
Model Toxics Control Act (of Washington State)
MWAC
Middle Waterway Action Committee
MWQC
marine water quality criteria
NCDF
nearshore confined disposal facility
NCP
National Oil and Hazardous Substances Pollution Contingency Plan
NGVD
National Geodetic Vertical Datum
NO A A
National Oceanic and Atmospheric Administration
NPDES
National Pollutant Discharge Elimination System
NPL
National Priorities List
NWDC
Northwest Detention Center
O&M
Operation and Maintenance
OMMP
Operations, Maintenance, and Monitoring Plan
OCF
onsite containment facility
OF
Outfall
OSWER
Office of Solid Waste and Emergency Response
OU
Operable Unit
OVRA
Olympic View Resource Area
PAH
polycyclic aromatic hydrocarbon
PCB
polychlorinated biphenyl
PCE
Perchloroethylene or tetrachloroethene
PDT
Project Delivery Team
PLC
Programmable Logic Controller
POTW
Publicly-Owned Treatment Works
ppm
parts per million
ppt
parts per trillion
PRG
Preliminary Remediation Goal
PRP
Potentially Responsible Party
PSE
Puget Sound Energy
PSWQA
Puget Sound Water Quality Authority
PVC
polyvinyl chloride
RA
Remedial Action
RAOs
Remedial Action Objectives
RACR
Remedial Action Construction Report
RCRA
Resource Conservation and Recovery Act
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RCW
Revised Code of Washington
RD
Remedial Design
RI/FS
Remedial Investigation/Feasibility Study
RNA
regulated navigation area
ROD
Record of Decision
RPD
Redox potential discontinuity
RPM
Remedial Project Manager
RSE
Remedial Systems Evaluation
SARA
Superfund Amendments and Reauthorization Act
SDWA
Safe Drinking Water Act
SMA
Sediment Management Area
SMS
Sediment Management Standards
SMU
Sediment Management Unit
SOW
Statement of Work
SPI
Sediment Profile Imaging
SQO
Sediment Quality Objective
SQS
Sediment Quality Standard
SR
State Route (i.e., State Highway)
SRAL
Sediment Remedial Action Level
SSPM
stormwater suspended particulate matter
SVOC
Semi-volatile organic compounds
SW
Surface water
SWPO
Shellfish and Water Protection Office
TBC
To Be Considered
TCE
trichloroethene
TCLP
Toxicity Characteristic Leaching Procedure
TEQ
Toxicity Equivalent Quotient
TIC
Temporary impermeable cap
TSCA
Toxic Substances Control Act
TPCHD
Tacoma-Pierce County Health Department
TPH
total petroleum hydrocarbon
TSP
Tacoma Smelter Plume
UAO
Unilateral Administrative Order
UECA
Uniform Environmental Covenants Act
UPRR
Union Pacific Railroad
USACE
U.S. Army Corps of Engineers
USCG
U.S. Coast Guard
USEPA
U. S. Environmental Protection Agency (also EPA)
USFWS
U. S. Fish and Wildlife Service
VCP
Voluntary Cleanup Program (Washington State Department of Ecology)
VOC
volatile organic compound
WAC
Washington Administrative Code
Mg/kg
micrograms per kilogram
Hg/L
micrograms per liter
(ig/m3
Micrograms per meter cubed
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
COMMENCEMENT BAY NEARSHORE/TIDEFLATS
SUPERFUND SITE
TACOMA, WASHINGTON
1. Introduction
The Commencement Bay Nearshore/Tideflats Superfund site (CB/NT site) is located in Tacoma,
Pierce County, Washington at the southern end of the main basin of Puget Sound. This National
Priorities List (NPL) site is divided into six Operable Units (OUs):
OU 01 Commencement Bay Nearshore/Tideflats Sediments.
OU 02 Asarco Tacoma Smelter Facility (currently renamed OU 20).
OU 03 Tacoma Tar Pits.
OU 04 Asarco Off-Property (referred to as Ruston/North Tacoma Study Area, currently
renamed OU 22).
OU 05 Commencement Bay Nearshore/Tideflats Sources.
OU 06 Asarco Sediments (currently renamed Asarco Sediments/Groundwater OU 19).
For the CB/NT site, there are three separate project areas that are being managed as distinct sites.
These project areas include the Commencement Bay Nearshore/Tideflats Sediments and Sources
(OU 01 and OU 05); the Asarco Smelter Facility and surrounding impacted areas (OU 20, OU
22, and OU 19); and the Tacoma Tar Pits (OU 03).
The CB/NT Sediments OU (OU 01) includes the following eight contaminated sediment
Problem Areas within six marine waterways: Head and Mouth of Hylebos Waterway, Sitcum
Waterway, St. Paul Waterway, Middle Waterway, Head and Mouth of Thea Foss (formerly City)
Waterway, and Wheeler-Osgood Waterway. The CB/NT Sediments OU also includes two non-
time-critical removal actions known as the Olympic View Resource Area and the Occidental
Site. The CB/NT Sources OU (OU 05) identifies and controls sources of contamination to the
marine sediments associated with each of the eight Problem Areas. The CB/NT Sediments and
Sources OUs are under one Record of Decision (ROD) (EPA 1989).
The CB/NT Asarco OUs (OU 20, OU 22, and OU 19) are addressed by three RODs (EPA 1995,
EPA 1993, and EPA 2003, respectively), and the Tacoma Tar Pits OU (OU 03) is addressed by
one ROD3 (EPA 1987). This Five-Year Review (FYR) addresses all OUs, except for CB/NT
Sources.
3 In the Tacoma Tar Pits ROD, the Tacoma Tar Pits site is identified as OU 23. For this fourth FYR, it will be
referred to as OU 03.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Cleanup of the OUs addressed in this FYR has been conducted by Responsible Parties, under
oversight by the U.S. Environmental Protection Agency (EPA). For CB/NT Sources (OU 05),
the Washington Department of Ecology (Ecology) is the lead regulatory agency for CB/NT
source control actions. The strategic relationship and importance of coordination between
sediment cleanup and source control actions is described in Sections 5.1.5 and 5.2 of the CB/NT
ROD (OUOl and OU 05).
The EPA and Ecology "Source Control Strategy, Commencement Bay Nearshore/Tideflats
Superfund Site" (EPA/Ecology May 1992) states that sediment cleanup will not be implemented
until adequate source control efforts have been implemented to minimize the potential for
sediment recontamination. The primary objective under CB/NT Sources (OU 05) was to control
major sources of contamination to the waterways prior to implementation of sediment
remediation in each of eight Problem Areas. Source control completion in a Problem Area
indicated that Ecology and EPA believed that source control measures were adequate for
sediment remedial action to move forward in a Problem Area. This determination was
documented in a Source Control Completion Report that was approved prior to remedy
implementation in each of the eight Problem Areas. For CB/NT Sources (OU 05), known source
control actions were implemented and deemed to be complete enough to begin sediment
remediation, and thus, the protectiveness of those source control actions does not need to be re-
evaluated in discussions for a separate OU (i.e., OU 05 Source Control) in EPA five-year
reviews. Rather, any source control actions that are implemented under state or state-delegated
programs (e.g., state MTCA cleanups, issuance of NPDES permits to individual permitees as
well for the City of Tacoma's Municipal Separate Storm Sewer System [MS4]) at the site,
including actions that require operations and maintenance or long-term monitoring or reporting
activities, are the responsibility of the state. Similar to Superfund, state MTCA regulations
(WAC 173-340-420) require a review of post-cleanup conditions and monitoring data that may
be required at least every five years to ensure that human health and the environment are being
protected. In addition, since approximately 2004, known remaining source control actions that
require EPA Superfund regulatory oversight and affect the protectiveness of a completed
sediment remedy in a problem area are discussed for each unique Problem Area. Additional
details on the source control strategy are described in Section 4 of the 2004 five-year review for
the CB/NT site.
The purpose of a FYR is to evaluate the implementation and performance of a remedy in order to
determine if the remedy at a site remains protective of human health and the environment. In
addition, FYR reports identify issues or deficiencies found during the review, if any, and
document recommendations to address them.
The EPA is preparing this FYR pursuant to the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) §121 and the National Contingency Plan (NCP).
CERCLA §121(c) states:
"If the President selects a remedial action that results in any hazardous
substances, pollutants, or contaminants remaining at the site, the President shall
review such remedial action no less often than each five years after the initiation
of such remedial action to assure that human health and the environment are
being protected by the remedial action being implemented. In addition, if upon
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
such review it is the judgment of the President that action is appropriate at such
site in accordance with section [104] or [106], the President shall take or require
such action. The President shall report to the Congress a list offacilities for
which such review is required, the results of all such reviews, and any actions
taken as a result of such reviews. "
EPA interpreted this requirement further in the NCP, at 40 Code of Federal Regulations (CFR)
§300.430(f)(4)(ii), which states:
"If a remedial action is selected that results in hazardous substances, pollutants,
or contaminants remaining at the site above levels that allow for unlimited use
and unrestricted exposure, the lead agency shall review such action no less often
than every five years after the initiation of the selected remedial action. "
EPA Region 10 conducted this FYR on the remedy implemented at the CB/NT Site. EPA is the
lead agency for developing and implementing the remedy for the site.
This is the fourth FYR for the CB/NT Site. The triggering action for this statutory review is the
completion date of the previous FYR. This FYR was conducted from December 2013 through
November 2014. This report documents the results of the review. For this FYR, the U.S. Army
Corps of Engineers (USACE), Seattle District, provided support to EPA under an Interagency
Agreement. Also, for some portions of the site, Responsible Parties conducted analyses in
support of the FYR, which are described in unique sections below.
2.Site Chronology
Information for this section is in the third FYR (EPA 2009), which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
3. Background
3.1. Site Location and Description
Information for this section is in the third FYR (EPA 2009), which is available online at
http://yosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
3.2. Land and Resource Use
Information through 2009 for this section is in the third FYR, which is available online at
http://yosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
In March 2013, EPA compiled information on habitat restoration and mitigation projects within
the general Commencement Bay area. Figure 3-1 shows restoration and mitigation projects that
were completed or were underway in the Commencement Bay area prior to June 2010. Some
proposed mitigation and restoration projects are also shown on the map. Certain mitigation and
restoration projects that are located further upstream of the Puyallup River (e.g., 96th Street
Oxbow, Sportsman Oxbow, Old soldiers Home, Pioneer Way, Sha Dadx) remain in the .kmz file
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
maintained by EPA, but are not depicted in the Commencement Bay Area (Figure 3-1). Data
regarding the specific projects and boundaries are considered estimates, and for any official
agency decision, the agency shall rely upon the original source of data or information, not the
.pdf file or .kmz file, as the basis for that decision.
The Tacoma Tar Pits site and surrounding area is located within the city limits of Tacoma, in the
industrialized tide flats where the Puyallup River discharges to Commencement Bay on Puget
Sound. The site and adjacent properties are zoned as "PMI - Port Maritime Industrial." The site
is currently occupied by the following businesses: 1) Simon Metals, a metals recycling business,
2) the Northwest Detention Center (NWDC), an immigration detention facility located on the
former Hygrade meat packing plant property, 3) Tri-Pak, a transloading facility, 4) Burlington
Northern Railroad (BNRR) and Union Pacific Railroad (UPRR) rail lines, 5) a Puget Sound
Energy (PSE) natural gas regulation station, 6) an Associated Petroleum Products (APP) card
lock fueling station, and 7) a portion of the City of Tacoma's vactor facility along Cleveland
Way, which was established in that location during the period of this FYR.
3.3. History of Contamination
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
3.4. Initial Response
3.4.1. Commencement Bay Nearshore/Tideflats Sediments
Information for this section is in the third FYR, which is available online at
http://yosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
3.4.2. Asarco Area
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
3.4.3. Tacoma Tar Pits
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
3.5. Basis for Taking Action
3.5.1. Commencement Bay Nearshore/Tideflats Sediments
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
3.5.2. Asarco Area
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
3.5.3. Tacoma Tar Pits
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
4. Remedial Actions and Five-Year Review
Process for CB/NT Sediments Operable Unit 01
("Problem Area Waterways")
4.1. Remedy Selection
EPA issued the CB/NT ROD in September 1989. EPA selected a remedial action for the
following eight of nine sediment Problem Areas that were identified during the RI/FS: 1) Mouth
of Hylebos Waterway, 2) Head of Hylebos Waterway, 3) Sitcum Waterway, 4) St. Paul
Waterway, 5) Middle Waterway, 6) Head of Thea Foss Waterway, 7) Mouth of Thea Foss
Waterway, and 8) Wheeler-Osgood Waterway (see Figure 4-1). The ninth problem area, the
sediments (OU 19) offshore from the Asarco Tacoma Smelter, was addressed in a separate ROD
signed in July 2000.
4.1.1. Cleanup Objectives
Information for this section is in the third FYR (EPA 2009), which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt. The cleanup goal for the Commencement
Bay problem areas is reduction of contaminant concentrations in sediments to levels that will
support a healthy marine environment and will protect the health of people eating seafood from
the bay. As described in the CB/NT ROD (EPA 1989; Declaration, p. 1), the overall goal of the
selected remedy is "to protect the marine environment and thereby reduce associated public
health concerns." The selected remedy "is protective of the marine environment and related
human health concerns" (EPA 1989; Declaration, p. 2). The subsequent PCB ESD (EPA 1997;
p.4) reiterated that the cleanup goal for the Commencement Bay problem areas is to achieve
reduction of contaminant concentrations in sediments [emphasis added] to levels that will
support a healthy marine environment and will protect the health of people eating seafood from
the Bay.
The ROD designated biological test requirements and associated sediment chemical
concentrations referred to as Sediment Quality Objectives (SQOs) in order to achieve this goal
(see Table 4-1 below).
Table 4-1. Sediment Cleanup Levels, identified as Sediment Quality Objectives
Chemical Sediment Quality Objective
Metals (mg/kg dry weight; ppm)
Antimony
150 B
Arsenic
57 B
Cadmium
5.1 B
Copper
390 L
Lead
450 B
Mercury
0.59 L
Nickel
140 A,B
Silver
6.1 A
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Table 4-1. Sediment Cleanup Levels, identified as Sediment Quality Objectives (continued)
Chemical
Sediment Quality Objective '•l x''
Zinc
410 B
Organic Compounds (jig/kg dry weight; ppb)
Low Molecular Weight PAH
5,200 L
Naphthalene
2,100 L
Acenaphthylene
1,300 A,B
Acenaphthene
500 L
Fluorene
540 L
Phenanthrene
1,500 L
Anthracene
960 L
2-Methylnaphthalene
670 L
High Molecular Weight PAH
17,000 L
Fluoranthene
2,500 L
Pyrene
3,300 L
Benz(a)anthracene
1,600 L
Chrysene
2,800 L
Benzofluoranthenes
3,600 L
Benzo(a)pyrene
1,600 L
Indeno( 1.2.3-c.d)pyrcne
690 L
Dibenzo(a,h)anthracene
230 L
Benzo(g,h,i)perylene
720 L
Chlorinated Organic Compounds
1,3 -Dichlorobenzene
170 A,L
1,4-Dichlorobenzene
110 B
1,2-Dichlorobenzene
50 L, B
1,2,4-Trichlorobenzene
51 A
Hexachlorobenzene (HCB)
22 B
Total PCBs
300 2,3
Phthalates
Dimethyl phthalate
160 L
Diethyl phthalate
200 B
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Table 4-1. Sediment Cleanup Levels, identified as Sediment Quality Objectives (continued)
Chemical Sediment Quality Objective '•l x''
Di-n-butyl phthalate
1,400
A,L
Butyl benzyl phthalate
900
A,B
Bis(2-ethylhexyl)phthalate
1,300
B
Di-n-octyl phthalate
6,200
B
Phenols
Phenol
420
L
2-Methylphenol
63
A,L
4-Methylphenol
670
L
2,4-Dimethylphenol
29
L
Pentachlorophenol
360
A
Miscellaneous Extractables
Benzyl alcohol
73
L
Benzoic acid
650
L,B
Dibenzofuran
540
L
Hexachlorobutadiene
11
B
N-nitrosodiphenylamine
28
B
Volatile Organics
Tetrachloroethene
57
B
Ethylbenzene
10
B
Total xylenes
40
B
Pesticides
P,P' - DDE
9
B
P,P' -DDD
16
B
P,P' - DDT
34
B
Source: CB/NT ROD (EPA 1989; Section 7.2.4 and Table 5) and CB/NT ESD (EPA 1997). The CB/NT ROD
established sediment cleanup levels, called Sediment Quality Objectives (SQOs). Note that Table 5 of the CB/NT ROD
refers to Sediment Cleanup Objectives in error; the correct term is Sediment Quality Objectives, as referenced in Section
7.2.4 of the ROD.
1. These values (except for total PCBs) represent the lowest AET for the three biological effects indicators:
A - amphipod mortality bioassay (acute test)
L - oyster larvae abnormality bioassay (acute test)
B - benthic infauna (chronic test)
2. The CB/NT ROD (1989) identified the Sediment Quality Objective for total PCBs as 1,000 ng/kg for the protection
of benthic organisms (ecological risk assessment) and 150 ng/kg for protection of human health (seafood consumption;
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Table 4-1. Sediment Cleanup Levels, identified as Sediment Quality Objectives (continued)
Chemical Sediment Quality Objective
human health risk assessment). The CB/NT ESD (1997) modified the Sediment Quality Objective for total PCBs to 300
|ig/kg. to be achieved within 10 years after cleanup through natural recovery processes. The ESD stated that post-
cleanup average PCB concentrations are expected to be less than 150 ng/kg total in all waterways at the CB/NT site.
This modified SQO of 300 ng/kg total PCBs was based on a re-evaluation of the human health risk assessment. [See
Footnote 3],
3. The CB/NT ESD (EPA 1997) stated: The purpose of this Explanation of Significant Differences (ESD) is to modify
the cleanup level for remediation of marine sediments contaminated with polychlorinated biphenyls (PCBs) at the
Commencement Bay Nearshore/Tideflats (CB/NT) Superfund site. EPA's September 30, 1989, Record of Decision
(ROD) for the CB/NT Site established cleanup levels, called Sediment Quality Objectives (SQOs), for several problem
chemicals found to be causing adverse effects to human health and the environment at the CB/NT Site. The SQO for
PCBs was set at 150 fig/kg (micrograms per kilogram) dry weight (DW). The ROD required that the SQOs be met
within ten years after completion of sediment remedial action. The ROD predicted that, ifsediments with PCB
concentrations greater than a Sediment Remedial Action Level (SRAL) of240 - 300 fig/kg PCBs were removed, the 150
Hg/kg PCB SQO would be met in 10 years through natural recovery processes. With this ESD, EPA is modifying the
PCB SRAL to 450 fig/kg, to be achieved during cleanup, and the PCB SQO to 300 fig/kg, to be achieved within 10years
after cleanup. Cleanup to 450 fig/kg is expected to result in a post-cleanup average PCB concentration of less than 150
Hg/kg in all waterways at the CB/NT Site.
4. The CB/NT ROD and ESD should be consulted and relied upon for determination and use of SQOs for the
CB/NT site.
5. The CB/NT ROD (EPA 1989) also identifies sediment toxicity tests that may be used to override the SQOs, except
for PCBs (human health-derived SQO), as indicated in Section 8.25 of the ROD: "When both biological and
chemical test results are available for a particular sediment sampling station, the results of a particular biological test
will outweigh the AET predictions of that biological effect based on chemistry."
6. A specific cleanup level/cleanup objective based on seafood tissue data was not a requirement identified in the
ROD or ESDs for the site, and has not been derived as a performance standard for any of the response actions in
Commencement Bay based on ARARs in the ROD.
SQOs for all problem chemicals were set based on an evaluation of the ecological and human
health risks posed by these chemicals. The SQO for PCBs was based on the human health risk
assessment. SQOs for all other chemicals were based on the ecological risk assessment because
the ecologically-based cleanup levels were determined to be also protective of human health. A
specific cleanup level/cleanup objective based on seafood tissue data was not a requirement
identified in the ROD or ESDs for the site, and has not been derived as a performance standard
for any of the response actions in Commencement Bay based on ARARs in the ROD. While the
ROD and ESDs for the CB/NT site use the term "cleanup goal" it is clear that the intent of that
language, with respect to the protection of the health of people eating seafood from the Bay, is
that the term "cleanup goal" is synonymous with EPA's current terminology "remedial action
objectives (RAO)." Given that the term "RAO" is not used in EPA's decision documents for the
site, the term "remedial objective" will be used in this five-year review for discussion pertaining
to the cleanup goal to related to human health concerns. As set forth in the 1997 ESD, the
sediment cleanup for PCBs is expected to result in a post-cleanup average PCB concentration of
less than 150 |ig/kg1 in all waterways at the CB/NT site, which was determined to be protective
4 The 1997 Explanation of Significant Differences (ESD) modified the cleanup level for remediation of marine
sediments contaminated with polychlorinated biphenyls (PCBs) at the CB/NT site. The 1989 ROD established
cleanup levels, called SQOs, for several problem chemicals found to be causing adverse effects to human health and
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
of human health. Based on the method described in the ESD, EPA calculated that a PCB SQO of
150 |ig/kg would result in attainment of PCB concentrations in fish tissue similar to those in
Puget Sound reference areas (36 |ig/kg). Recent fish tissue data for bioaccumulative chemicals
have not been collected in Commencement Bay and evaluated, so it is not known whether
contaminant levels in fish tissues have been reduced since the remedies have been implemented,
particularly for PCBs (which have a human-health based Sediment Quality Objective). Future
fish tissue sampling results will be used along with other lines of evidence to evaluate
protectiveness of the remedies in the long-term.
As described in the third FYR (EPA 2009), new information on Tribal seafood consumption
rates and exposure durations for Tribal populations5 became available during that period. EPA
identified the consumption rates and exposure duration as new information that could impact the
estimated risk associated with residual polychlorinated biphenyls (PCBs), which could call into
question the long-term protectiveness of the remedy. The complete evaluation is provided in
Section 4.2.6 of the third FYR. Based on EPA's evaluation in the third FYR, EPA believes that
this new information neither calls into question the protectiveness of the remedy, nor requires
any additional action at this time. EPA believes that the PCB sediment quality objective (SQO;
300 |^g/kg), which was based on a human health risk assessment, remains protective.
Regarding the fish and shellfish tissue sampling program recommended in the third FYR (see
Section 4.8 of this fourth FYR), it is important to clarify that a specific cleanup level/cleanup
objective based on fish tissue data was not a requirement identified in the ROD, and has not been
derived as a performance standard for any of the response actions in Commencement Bay based
on ARARs in the ROD. However, Section 11.1 of the CB/NT ROD suggests that fish tissue
contaminant levels are an important indicator of human health exposure, and specifies that site
use restrictions, such as advisories that limit seafood consumption, will be implemented to
protect human health until recovery is complete. Accordingly, in the previous FYRs for the
CB/NT Site, EPA identified plans to conduct a fish tissue sampling program.
4.1.2. Selected Remedy
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
the environment at the CB/NT Site. The SQO for PCBs was set at 150 ng/kg dry weight. The ROD required that the
SQOs be met within ten years after completion of sediment remedial action. The ROD predicted that, if sediments
with PCB concentrations greater than a Sediment Remedial Action Level (SRAL) of 240 - 300 ng/kg PCBs were
removed, the 150 ng/kg PCB SQO would be met in 10 years through natural recovery processes. With the 1997
ESD, EPA modified the PCB SRAL to 450 |ig/kg. to be achieved during cleanup, and the PCB SQO to 300 |ig/kg.
to be achieved within 10 years after cleanup, and EPA stated that the cleanup to 450 ng/kg is expected to result in a
post-cleanup average PCB concentration of less than 150 ng/kg in all waterways at the CB/NT Site. Based on the
method described in the ESD, EPA calculated that a PCB SQO of 150 ng/kg would result in attainment of PCB
concentrations in fish tissue similar to those in Puget Sound reference areas (36 |ig/kg). With regards to ecological
risk, the ESD summarized the updated ecological risk analysis, which showed that the 300 |ig/kg PCB SQO and 450
|ig/kg PCB SRAL is protective of the benthic community, juvenile salmonids, shorebirds and piscivorous birds.
Cleanup to the 300 ng/kg PCB SQO will reduce all HQs estimated for these species to 1 or below.
5 EPA Region 10's "Framework for Selecting and Using Tribal Fish and Shellfish Consumption Rates for Risk-
Based Decision Making at CERCLA and RCRA Cleanup Sites in Puget Sound and the Strait of Georgia" (EPA
2007; hereinafter referred to as the Framework).
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
4.1.3. Source Control Strategy
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.1.4. Explanation of Significant Differences
Information for this section is in the third FYR, which is available online at
http://yosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.1.5. Sitewide Biological Assessment
Information through 2009 for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
Since 2009, the following species have been listed as threatened or endangered, or critical habitat
for the species has been designated, under the Endangered Species Act (ESA):
• Pacific eulachon (Thaleichthyspacificus) in March 2010, and critical habitat was
designated in October 2011;
• Bocaccio (Sebastespaucispinis), canary rockfish (Sebastespinniger), and yelloweye
rockfish (,Sebastes ruberrimus) in April 2010; critical habitat for these three species was
designated in August 2013;
• Revised critical habitat for bull trout (Salvelinus confluentus) in September 2010;
• Streaked horned lark (Eremophila alpestris strigata) in November 2013; and
• Taylor's Checkerspot butterfly (Euphydryas editha taylori) in November 2013 and critical
habitat in October 2013.
The eastern distinct population segment of Steller sea lions was de-listed in November 2013
(NFMS 2013).
4.1.6. Sitewide 404(b)(1) Analysis
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.1.7. Dredged Material and Disposal Sites
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.1.8. CERCLA Removal Actions
4.1.8.1 Olympic View Resource Area
A non-time-critical removal action was conducted in 2001 to address contaminated marine
sediments at the Olympic View Resource Area (OVRA). The OVRA was not identified as a
problem area in the CB/NT ROD, but it is located within the boundaries of the CB/NT site.
In 1997, the OVRA site was identified as one of five City restoration projects addressed in the
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
City's Natural Resource Trustee Consent Decree (CD) to settle the City's liability for natural
resource damages at the CB/NT site. As part of studies at OVRA, dioxin sediment
contamination was found, and it was determined to be an imminent and substantial threat to
human health and the environment. Section 4.6 describes the cleanup action taken in this area.
4.1.8.2 Occidental Chemical
Background: A 1997 CERCLA AOC with Occidental Chemical led to development and partial
implementation of two non-time-critical removal actions at its (now former) chlor-alkali plant
and adjacent areas along the Hylebos Waterway. The Area 5106 Removal Action included
dredging, treatment, and disposal of approximately 36,000 cubic yards (cy) of sediment
contaminated predominantly with chlorinated organic solvents and degradation products. The
in-water work (October 2002 through February 2003) was completed as designed, but
contaminated sediment, approaching residual DNAPL concentrations, was found to extend
deeper than anticipated. Additional response actions were conducted under the Area 5106 UAO
to partly characterize the remaining contamination. The Embankment Area Removal Action led
to the 2003 draft design of a permeable cap to cover the intertidal and subtidal Occidental
property embankment to the toe of the subtidal slope. Information obtained from the Area 5106
Removal Action and Embankment Area work identified contamination which could not be
addressed by the cap as designed and pointed to the need for additional in-water and upland
source control measures.
In 2005, remaining work from each of these two removal actions were melded into an overall
Occidental Site CERCLA Administrative Order on Consent (AOC) to address remaining soil,
groundwater, and sediment contamination. The AOC extends through the Remedial
Investigation/Feasibility Study (RI/FS) and Remedial Design (RD). Another legal mechanism
will be needed to implement the Remedial Action (RA) after the selected remedy has been
designed under the AOC. CERCLA response actions at the Occidental Site from 2005 through
2009 are summarized in the previous FYR. From 2010 through 2014, several site investigation
studies were conducted under the 2005 Amendment to the 1997 CERCLA AOC as summarized
below. These studies culminated in an approved conceptual site model (CSM) report in April
2014. An overview of work performed during the past five years is presented below.
2010: Investigations associated with a deep, improperly abandoned water supply well postulated
to be leaking freshwater, and thus complicating interpretation of field data collected 2005 to
2009, were conducted. The data obtained helped to better characterize part of a high-density
plume formed by salt brine and caustic soda releases, identified stratigraphic control associated
with the density plume depth, and found no discernible hydraulic impacts from the abandoned
water well on site.
Several phases of elevated (9-14 pH) neutralization pilot testing work, in-situ and ex-situ, were
summarized into a draft summary report.
Occidental completed a draft groundwater flow model for EPA and Ecology review, and then
proposed an interim action to install a sheet-pile wall, to replace the treatment plant, and to
enhance the existing extraction well network. EPA and Ecology rejected the interim action
proposal because the proposed sheet-pile wall could be inconsistent with future response actions
needed to address contaminated sediment and groundwater, the partial hydraulic containment
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
plan depended upon a draft groundwater flow model that the agencies had not reviewed, and
additional data were needed to complete the nature/extent of contamination and groundwater
flow site characterization work. EPA and Ecology pointed out that other types of interim
actions, which would not interfere with potential future response actions, would be welcomed.
2011: EPA and Ecology identified the need to fill several significant data gaps to characterize the
nature/extent of contamination, groundwater flow, and contaminant transport. A revised project
schedule was developed to fill necessary data gaps and complete the RI.
2012: The Comprehensive Supplemental Investigation (CSI) work plan was approved. Field
work included numerous shallow and deep monitoring well installations to obtain contaminant
distribution, groundwater density, and hydraulic pressure data, and several soil borings to
characterize chlorinated volatile organic compounds (VOCs), dense non-aqueous phase liquid
(DNAPL), and elevated pH (9-14) areas caused by historic caustic soda releases.
An evaluation of the existing groundwater treatment plant was performed to assess its life
expectancy and potential use as part of any future remedial alternatives.
2013: Occidental proposed an interim action to replace the groundwater treatment plant and
install a new extraction well system designed in response to the updated understanding of
groundwater contamination. The agencies agreed with this work being conducted in parallel
with completing the RI/FS and remedy selection. EPA and Ecology review of the draft interim
action work plan was completed in June 2013. Occidental then withdrew the proposal, and the
agencies accepted that withdrawal in July.
A work plan for additional deep monitoring well installation and extraction well pilot testing was
approved. The wells were installed and an initial pumping well aquifer test was conducted.
EPA and Ecology provided comments in November 2013 on the draft pH pilot testing summary
report. The comments identified revisions needed to finalize the report and additional pH
neutralization testing needed.
With the completion of RI data acquisition, Occidental developed the draft CSM report for EPA
and Ecology review. Occidental also submitted a draft Evaluation of Remedial Technologies
(ERT) report as an initial screening of technologies prior to beginning the FS.
A work plan for vapor intrusion (VI) investigation of buildings at the Occidental Site was
approved by EPA in February. An initial round of indoor air and subslab vapor sampling was
conducted in March. A second round in July used both Summa canisters for short-term (hours)
measurements and passive samplers for longer-term (one week) indoor air measurements.
2014: The draft CSM report was modified in response to EPA and Ecology comments and
approved in April. The draft Site Characterization report (SCR) was submitted in August, and
the final SCR is anticipated to be approved in December.
Ongoing treatability testing associated with high pH neutralization, extraction well pilot testing,
and contaminant transport modeling parameter investigations are expected to continue.
Treatability testing needed to further evaluate certain remedial technologies is expected to occur.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
A third round of VI sampling occurred under an amendment to the 2013 approved work plan in
March for buildings not recommended to be mitigated. This round of sampling included both
Summa canister and passive samplers for indoor air measurements. A VI mitigation design plan
for buildings to be mitigated was submitted in April and approved by EPA in June 2014.
4.1.9. Puyallup Land Settlement
The CB/NT site is within the usual and accustomed fishing and gathering areas for the Puyallup
Tribe of Indians (Tribe), and thus the Tribe has an ongoing interest in site cleanup efforts.
Additionally, the Puyallup Land Transfer Consent Decree (United States v Port of Tacoma,
Puyallup Tribe of Indians as Intervenor) [CD], No. C94-5648 (W.D. Wash. Jan. 1995) describes
the obligations and responsibilities that the Port of Tacoma (Port) and the Tribe have regarding
environmental cleanups and long-term monitoring at six properties within the CB/NT Site, which
were transferred from the Port of Tacoma to the Puyallup Tribe. The Consent Decree was
associated with the 1988 Puyallup Settlement Agreement and the Puyallup Land Claims
Settlement Act of 1989. Two Port mitigation actions being performed under this CD are within
the Mouth of Hylebos Problem Area (see Section 4.2). The Tribe is the beneficial owner of the
trust lands on which these mitigation sites are located. The Port and Tribe have proposed that the
Tribe designate the mitigation sites as "Conservancy" and that the Tribe take action, under Tribal
law, to protect them.
The Tribe, the Port, and EPA developed a 2012 Contingency Plan in response to EPA identifying
work that had not been completed as required by the 1995 CD. The Contingency Plan presents
mitigation actions at two locations to address a shortfall of intertidal wetland mitigation credit at
the Outer Hylebos Mitigation Site, which was constructed pursuant to the 1995 CD.
Implementation of the 2012 Contingency Plan began with construction of the two mitigation
areas during the spring and summer of 2012. EPA conducted a field inspection of the two sites in
September 2013 and found them to be functioning well. A second EPA field inspection occurred
on May 16, 2014 and EPA also found the sites to be functioning within the performance
standards; however, ongoing maintenance will be needed to ensure continued compliance.
Monitoring at the mitigation site is required for a minimum of five years, and if performance
standards are not met, will continue longer.
4.1.10. Partial Deletion of the Site
Information through 2009 for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.2. Hylebos Waterway
4.2.1. Background
The Hylebos Waterway is the northeastern-most waterway in the CB/NT area (see Figure 4-1).
Since the early 1900s, the three-mile-long waterway has been the site of several industries, such
as manufacturing of chlorine and chlorinated chemicals, shipbuilding and repair, scrap metal
recycling, lumber milling, and log exporting. Sampling during the 1984 RI showed several
contaminants of concern in Hylebos Waterway sediments, including arsenic, VOCs, polycyclic
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
aromatic hydrocarbons (PAHs), hexachlorobenzene, hexachlorobutadiene, and PCBs. The 1989
ROD identified contaminated sediment problem areas at the Mouth and Head of Hylebos
Waterway that required Superfund cleanups.
Other information through 2009 for this section is in the third FYR (EPA 2009), which is
available online at http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.2.2. Site Chronology
Site chronology information through 2009 is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
Site chronology information since 2009 is included below.
2010 CERCLA Mitigation Requirements Evaluation for sediment management area
(SMA) 421; Head of Hylebos sediment sampling conducted at Schnitzer Steel;
Occidental Site RI investigations focused on groundwater flow.
2011 Hylebos Bridge Rehabilitation Project Post-construction Sediment Monitoring
Report; Port of Tacoma acquired U.S. Navy property within and adjacent to
southern part of Occidental Site; Occidental Site RI data gaps identified; Head of
Hylebos Remedial Action Construction Report (RACR) approved.
2012 CSI Work Plan approved for Occidental Site; Draft Operations, Maintenance, and
Monitoring Plan (OMMP) for Mouth of Hylebos submitted; Slip 5 Mitigation Site
Monitoring Report (Year 6); Pre-OMMP Sediment Sampling for Head of Hylebos
Waterway performed.
2013 Mouth of Hylebos RACRs conditionally approved for Segment 5 and Slip 1
nearshore confined disposal facility (NCDF), Segment 3/4 and Slip NCDF, and Pier
24/25 embankment cap; RI field work for Occidental Site completed.
2014 Final CSM report approved for Occidental Site; Draft OMMP for Pier 24/25 cap
submitted; Pre-OMMP sampling for Mouth and Head planned.
4.2.3. Remedial Actions
4.2.3.1 Remedy Selection
Remedy selection for the CB/NT Sediments OU 01 was described in Section 4.1.
4.2.3.2 Remedy Implementation (Sources)
Information through 2009 for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt. Source control efforts are continuing with a
particular focus on the Arkema and Occidental sites.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
4.2.3.2.1 Arkema
EPA and Ecology have been concerned about arsenic-contaminated groundwater and high pH
plumes at the former Elf Atochem 2901 Taylor Way property, later acquired by Arkema
Chemical, at the Head of Hylebos waterway.
In 2011, Ecology developed a Model Toxics Control Act (MTCA) Agreed Order with the Port of
Tacoma to replace the pre-MTCA enforcement order with Arkema, and effectively released
Arkema from state liability.
EPA has not released Arkema from its liability under CERCLA. EPA certification of Remedial
Action to be completed, under the Head of Hylebos CD, is dependent upon cleanup of the
Arkema site to EPA's satisfaction. Arkema site cleanup has been progressing under the 2011
Ecology MTCA Order.
4.2.3.2.2 Occidental Site
A second major source of remaining contamination is the former production facility and
surrounding areas of the Occidental Chemical Corporation, within and adjacent to the Mouth of
Hylebos Waterway. Key accomplishments during the past five years were described in Section
4.1.8.
4.2.3.3 Remedial Action (Sediments)
Information through 2009 for this section is in the third FYR, which is available online at
http://yosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt. Information for the Head and Mouth of
Hylebos Waterways for the fourth FYR period (2009-2014) is presented below.
4.2.3.3.1 Segments 1 and 2 (Head of Hylebos)
Surface sediment6 samples (top 10 cm) were collected in accordance with the EPA-approved
Sampling and Analysis Plan at the Schnitzer Steel property during October 2010 along the
shoreline cap. Samples were analyzed for metals, PCBs, PAHs, dichlorodiphenyltrichloroethane
(DDT), and semi-volatile organic compounds (SVOCs). The Sediment Quality Standards (SQS)
were exceeded as follows: PCBs at 9 stations; benzyl butyl phthalate (BBP) at 7 stations; bis(2-
ethylhexyl)phthalate (BEHP) at 4 stations; zinc at 3 stations; and mercury at 1 station. A dive
inspection of the outfall found it was in disrepair but still functional (DOF 201 la).
The Sediment Sampling Data Report (2012) describes the sediment sampling conducted during
February 2012 at the Head of the Hylebos (DOF 2012). The purpose of the sediment sampling
was to establish current sediment chemical concentrations in a manner that allows for direct
comparison to the 2004-2006 Type 4 post-dredging confirmation sampling data. This data
collection effort was implemented to support the development of a revised long-term OMMP.
Concentrations of 15 of the 20 analytes in all the confirmation areas decreased between 2004-
2006 and 2012, in some cases possibly due only to lower analytical detection limits achieved in
2012. Concentrations of 4 of the 20 analytes increased in between 2004-2006 and 2012 (total
PCBs 3.9 times greater; arsenic 1.7; zinc 1.9; benzo(b+k)fluoranthene 1.1). Total PCBs were the
6 Surface sediment is the top 10 cm of sediment; all sediment below (deeper than) 10 cm is subsurface sediment.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
only parameter with 2012 individual sample results that exceed the Sediment Quality Objective
(SQO)7 within three confirmation sampling areas (CO-6b, C0-10, CO-11). The increased
averaged concentrations of the four analytes, especially for PCBs, warrant additional
investigation.
A Sampling and Analysis Plan (SAP) Addendum was prepared in April 2010 for data gaps as
part of the Arkema Site 2006 MTCA Agreed Order RI/FS following removal of the
woodwaste/slag containment cell at the former Arkema log sort yard facility at 3009 Taylor
Way, Tacoma, Washington. The SAP Addendum for data gaps was prepared in accordance with
Sections 5.3.1 and 5.3.3 of the RI/FS Work Plan. The remedial action construction report
(RACR) for the Head of Hylebos Waterway sediment remediation project, which describes
remedial work completed from 2002 through 2006, was originally submitted in July 2006, then
updated to reflect additional response actions and resubmitted in 2009, and approved by EPA on
August 31, 2011. The RACR attests that the construction was completed as required by EPA-
approved plans. Remedial actions completed included the dredging of 405,000 cy of sediment
over approximately 42 acres, capping of intertidal and subtidal slope over approximately 1.5
acres, and long-term monitoring of the cap at General Metals. EPA certification of Remedial
Action completion under the CD will depend upon longer-term monitoring results and cleanup of
the Arkema Site to EPA's satisfaction.
4.2.3.3.2 Segments 3, 4, and 5 (Mouth of Hylebos)
Remedial Action dredging did not occur within the 11th Street (Hylebos) Bridge Right-of-Way
(ROW), and sampling data within the ROW and nearby is sparse. This issue was brought into
focus when the City of Tacoma alerted EPA of its plans to rebuild (rehabilitate) the bridge, with
the in-water construction portion of the work scheduled between August 2009 and February
2010. The in-waterway work required removal of pilings within the ROW and installation of
new approaches on either side of the span. This work has been completed.
Discrete composite surface sediment samples (0 to 10 cm) were collected from 24 locations (and
combined in seven samples) on September 6 and 7, 2011, to characterize the post-construction
conditions associated with the Hylebos Bridge rehabilitation. Contaminants of concern (COCs)
were either not detected or were detected at concentrations less than SQOs in five of the seven
composite surface sediment samples. In two samples, two COCs were detected at concentrations
greater than the SQOs (fluoranthene, pyrene) and all other COCs were either not detected or
were detected at concentrations less than the SQOs. For example, even though the concentrations
of PAHs and several other SVOCs were detected at higher concentrations in the post-
construction samples (September 2011) than in pre-construction samples (July 2009), the
detected concentrations of those chemicals were still well below the SQOs in 2011 except for
fluoranthene and pyrene. Analytical variability likely accounted for the change in detected
concentrations because the method of sample extraction for SVOCs and PCBs changed between
the pre- and post-construction sampling events, from the sonication method to the microwave
method. Analytical results for samples prepared using the microwave method have generally
7 As defined in the CB/NT ROD (EPA 1989), an SQO is "a discrete and measurable target for project cleanup
related to the Puget Sound goal. The objective is measurable in terms of specific human health risk assessments and
environmental effects tests, and associated interpretive guidelines. The resulting biological effect levels or chemical
concentrations are scientifically acceptable definitions of the sediment quality goal using available information."
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
been higher than for samples prepared using the sonication method. Therefore, the change in
PAH and other chemical concentrations observed in the post-construction samples may largely
be the result of analytical variability. In general, the comparison of pre-construction (July 2009)
and post-construction (September 2011) results indicated that COC concentrations remained
relatively unchanged in surface sediment within the right-of-way of the Hylebos Bridge
Rehabilitation Project.
Mouth of Hylebos Pier 24 and 25 RACR
The RACR for the Pier 24 and 25 Embankment Remediation Project was finalized in December
2013, consistent with EPA conditional approval in September 2013. The 2007 to 2008 remedial
action construction work documented in the RACR involved capping contaminated intertidal and
subtidal sediments after partial or complete excavation of identified PCB and arsenic hot spots,
consistent with the approved remedial design.
Remediation for the project generally included capping the embankment slopes below
approximately elevation 15 to 17 feet mean lower low water (MLLW) beneath Pier 24 and Pier
25. The embankment was capped along the North Slope bayward of existing heavy rock riprap
below about 5 feet to minus 10 feet (+5 to -10 MLLW).
Capping extended through the subtidal zone to elevations below -30 MLLW on both the Hylebos
Waterway side and the North Slope (within Commencement Bay itself). Capping for the upper
and lower cap component for Pier 25 and the North Slope consisted of a layer of gravelly sand
covered by a layer of crushed rock. The sand cap consisted of a minimum 2-foot-thick layer of
gravelly sand. This sand and gravel blend was successful at maintaining stability during and
following placement, with no obvious slumping, sliding, or significant down-slope movement of
the material. To protect the sand cap on the lower slope of the Pier 25 embankment against
potential wave scour and propeller-wash, a minimum 1-foot-thick layer of angular, 1.5-inch-
minus crushed rock was placed as armor.
Excavation activities before capping were conducted at two locations in 2007 to remove
sediments with arsenic concentrations substantially in excess of the 57 mg/kg SQO. An
estimated 52 cy of excavated material were removed from the Pier 25 area, and an estimated 50
cy of material were removed from the North Slope area. Removal of the PCB hot spot materials
required four separate rounds of excavation and verification sampling. Final excavation was
successful in removing Toxic Substances Control Act (TSCA)-level material from the PCB hot
spot area. The excavation was backfilled on January 25, 2008.
Mouth of Hylebos Segment 3/4 RACR
The Final RACR for Segment 3/4 dredging and for the primary and final cap for the Slip 1
nearshore confined disposal facility (NCDF) was conditionally approved by EPA in September
2013. The report summarizes construction activities completed for the dredging of Segment 3
and 4 and associated disposal of sediments at the Slip 1 NCDF, and for the completion of a
primary and final cap at the NCDF. Site construction work was performed between July 2004
and March 2006.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
In some areas of Segments 3/4 COCs in surface sediment were below SQOs while being above
SQOs in subsurface sediment. These were "no action" areas and generally no dredging was
performed in these areas. Other areas in Segment 3/4 have contaminated subsurface sediment
and surface sediment that was found to be marginally contaminated, and in these areas the
remedial action was "natural recovery" where recovery to SQO chemical criteria was expected to
occur within 10 years following completion of remedial actions. In sediment management areas
(SMAs) where remedial dredging occurred, it was usually to the depth of the clean native
sediment surface, and confirmation sampling was conducted to verify that the bottom of
contamination had been reached. In both no-action and natural-recovery areas, where remedial
action dredging did not occur, the depth of subsurface contamination is likely limited to the
recent sediment (deposited within the last 50 to 100 years atop the dredged native sediment
surface) unless its affected by contaminated groundwater.
All sediments from SMAs within Segments 1, 3, and 4 were transported and disposed of at the
Slip 1 NCDF. Dredging was completed in October 2004 for all areas except Taylor Way
properties. The volume of material placed in the NCDF from Segments 1, 3, and 4 was 223,040
cy. The design volume (without contingency) for Segments 1,3, and 4 was estimated at 133,200
cy (excluding SMA 42IB). The NCDF was able to accept 90,000 cy from SMA 42IB because
the previously planned excess capacity sediment from the Duwamish Waterway was not
deposited into Slip 1, and thus additional capacity was available. The design volume did not
include SMA 421B because the embankment at SMA 421B at Taylor Way properties was
originally proposed for capping, not dredging. However, during cap design review, a revision to
dredge the embankment area instead of capping it was proposed by the performing parties,
reviewed, and conditionally approved by the EPA on October 15, 2004.
After all dredged sediments had been placed in the NCDF, it was capped with first a primary
cap, which was then covered with a final cap layer. A 7-foot-thick layer of clean sandy material
was placed to complete the primary cap to approximately +16 feet MLLW. Imported material
from the buttress (berm) was placed in the NCDF (Slip 1) in the upper 12 to 18 inches of the
primary cap. The final cap was constructed over the primary cap by the Port of Tacoma in March
2006. The final cap consisted of 12 inches of base course material capped with 10 inches of
asphalt concrete pavement. This amount exceeded the requirements of the final design, which
called for 8 inches of base course material and 6 inches of asphalt. A thicker pavement section
was installed to accommodate future use of the site.
No capping of dredged areas was completed based on the post-construction sediment quality
verification sampling. In accordance with the work plan, sediment remediation was considered
successful if the 95 percent upper confidence limit (UCL) concentration for all COCs did not
exceed SQOs, and if no single sample concentration exceeded the location-specific sediment
remedial action level (SRAL). Post-dredge sampling concentrations exceeded SQOs, but were
below SRALs for SMAs 421B, 123, and S44. SMAs 421B and S44 are considered natural-
recovery areas, whereas SMA 123 was backfilled with several feet of clean material.
Mouth of Hylebos Segment 5 and Slip 1 NCDF RACR
The RACR for Segment 5 and Slip 1 was conditionally approved by EPA in September 2013.
The report summarizes construction activities completed for the dredging of Segment 5 and
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
associated disposal of sediments at the Slip 1 NCDF and the completion of the Stage II
containment berm at the NCDF. Site construction work was performed between July 2003 and
February 2004.
Some areas of Segment 5 were found to contain subsurface contamination, but surface sediment
met SQOs, and dredging was not planned for these no-action areas. Similarly, some areas of
Segment 5 were found to have subsurface contamination, where surface sediment did not meet
SQOs but was within SRALs, and dredging was not planned in these natural-recovery areas.
Where remedial action dredging occurred, as designed, it was typically to the depth of the native
sediment surface. The total volume of sediments dredged in Segment 5 and placed in the
approved offshore disposal location was 150,838 cy. The design volume (without contingency)
for offshore disposal of dredged material was estimated at 163,500 cy.
As part of the preliminary characterization activities conducted in 1994 for the CB/NT site, a
portion of Segment 5 adjacent to the Occidental Chemical Corporation property, referred to as
Area 5106, was found to be impacted with a mixture of chlorinated organic chemicals, primarily
tetrachloroethene (also known as perchloroethylene (PCE)), trichloroethene (TCE),
hexachlorobenzene (HCB), and hexachlorobutadiene (HCBD). Sampling indicated that
sediments from Area 5106 were not appropriate for disposal with the remainder of the Segment 5
sediments. Dredging, treatment, and dewatering of Area 5106 sediment occurred between
October 2002 and February 2003 as a non-time-critical removal action under a separate
CERCLA unilateral administrative order (UAO). Confirmation sampling, however, indicated
concentrations of chlorinated organic chemicals that exceeded SQO chemical criteria within the
underlying native sediment by several orders of magnitude. Consequently, additional post-Area
5106 sediment removal investigations were performed to delineate the nature and extent of
remaining subsurface sediment and groundwater contamination in this area. Analytical data from
borings indicated that exceedances of SQO chemical criteria in this area were observed for PCE,
TCE, HCB, and HCBD. Remaining work required under the Area 5106 UAO was incorporated
into the Occidental Site CERCLA AOC as amended in 2005.
The volume of material placed in the NCDF from Segment 5 was 254,281 cy. The total volume
of sediments from all sources disposed of in the Slip 1 NCDF was approximately 450,000 cy.
Approximately 200,000 cy of material was found suitable for open-water disposal.
The construction of the Slip 1 Stage I Containment Berm was completed on January 16, 2003.
This was a component of the conversion of Slip 1 to an NCDF to contain dredged sediments that
were unsuitable for unconfined open-water disposal in Commencement Bay. The Stage I earthen
containment berm was constructed across the mouth of Slip 1 to create an enclosed basin for the
future placement of dredged sediments in the NCDF. The berm construction included excavation
of the existing sediment, backfilling with imported fill, and construction of the berm Stage I to a
height of -5.0 MLLW. The Stage II berm was constructed to +14 feet MLLW, and a sediment
transfer facility was constructed on top of the berm to transfer sediments from the Blair
Waterway side of the berm into Slip 1. A total of 25,271 tons of select fill, 20,979 tons of
blended riprap, and 238 tons of light riprap was used to construct the berm.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Federal Navigation Channel Dredged Material Characterization
As authorized by Congress, the USACE, Seattle District, conducts maintenance dredging of the
Hylebos Waterway Federal Navigation Channel. The authorized depth for that portion of the
channel proposed for dredging in 2014 was -30 feet MLLW. The channel bottom width is 200
feet, with the following exceptions: the width is increased to 250 feet at the bend upstream of the
East 11th Street Bridge, to 300 feet at the Lincoln Avenue bend, to 510 feet at the channel
widening above Lincoln Avenue, and to 770 feet at the turning basin at the head of the
waterway.
USACE proposed to dredge portions of the authorized navigation channel between the mouth
and the head of the waterway where shoaling has occurred. Two feet of allowed over-depth
dredging (-32 feet MLLW) was to be included in the proposed dredging. Bathymetric surveys
conducted by Seattle District in June 2012 and March 2013 indicate that approximately 47,445
cy of material would need to be removed from the waterway to restore authorized channel
depths.
USACE, with input from EPA and Ecology, completed a SAP in October 2013 for characterizing
sediment to be removed for channel maintenance dredging in FY 2013/2014. Sediment
vibracores were collected at sixty locations at the five shoal areas from November 4 to
November 13, 2013 (see Figure 4-2). Composite samples were characterized in the five shoal
areas along the Mouth, Middle, and Head of the Hylebos Waterways. Dredged Material
Management Program (DMMP) chemicals of concern were detected above the screening level
(SL) and bioaccumulation trigger (BT) in all five shoal areas. Mercury, pyrene, 2,4-
dimethylphenol, hexachlorobutadiene, hexachlorobenzene, and dieldrin were detected above the
SL in at least one shoal area. Total PCBs exceeded the SL in four of the five shoal areas. The
toxicity equivalent (TEQ) calculated for dioxin/furan congeners exceeded the BT at all waterway
shoal areas. Tributyltin was detected above the BT in three of five shoal areas (USACE 2014,
Data Report, Hylebos Waterway Federal Navigation Channel, Dredged Material
Characterization). Based upon these results, USACE has dropped its maintenance dredging
plans.
The quality of sediment within the proposed dredge prisms was characterized in bulk (from 0 to
4 feet), without regard to the distribution of contamination with respect to depth. Therefore, the
data cannot be used to determine whether the contaminated sediment within the formerly
proposed dredge prisms is found within the biologically active zone (generally the top 10
centimeters).
Helena Star (Derelict Vessel) Removal Surface Sediment Characterization
The U.S. Coast Guard, Ecology, and Washington Department of Natural Resources jointly acted
to remove the sunken vessel Helena Star from the Head of Hylebos Waterway in July 2014.
Previous work by the U.S. Coast Guard had removed petroleum products and other hazardous
materials from the sunken vessel. The vessel sunk in a part of the waterway where subsurface
sediment characterization by the Corps of Engineers had identified subsurface contamination and
the quality of surface sediment was not known. Ecology and EPA coordinated efforts to collect
and analyze surface sediment samples before and after the sunken vessel removal. Based upon
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
available information, the sediment samples were analyzed for metals, PCBs, and dioxins/furans.
Results are expected to be available in October 2014.
4.2.3.3.3 Disposal of Dredged Material
Information through 2009 for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.2.3.3.4 Habitat Mitigation
Information through 2009 for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
Key events associated with mitigation sites during the 2009-2014 timeframe include the
following:
• Mouth of Hylebos Consent Decree (CD) Slip 5 Mitigation Area annual post-construction
monitoring occurred, with EPA approval of final report in 2013.
• Mouth of Hylebos CD Clear Creek Mitigation Area annual post-monitoring occurred as
planned through 2012. Additional monitoring occurred in 2013 as performance standards
were not all met. Additional monitoring, but only every five years, is anticipated as
described in the final report.
• Puyallup Land Transfer CD (1995) Contingency Plan was approved by EPA in 2012 for
two mitigation sites in the Hylebos Waterway. The Port of Tacoma completed
construction in 2012. EPA field inspections occurred in September 2013 and May 2014,
and results indicated both sites are performing well so far. Annual monitoring is required
through at least 2017.
Details are provided below.
Mouth of Hylebos (Segments 3, 4, and 5) Consent Decree
The Clear Creek Habitat Improvement Project, Phase II site (habitat site) was constructed as one
of the habitat components of the mitigation package for the construction of the Mouth of the
Hylebos Waterway Segment 5 Remediation, Slip 1 NCDF Project. The original monitoring
program for the habitat site was completed in 2009. In November 2009, the Port of Tacoma
planted the Riparian Planting Areas with native vegetation. The Port has conducted annual
maintenance of the area, including removal of invasive vegetation. In 2012, maintenance
activities included removal of Himalayan blackberry and the application of an approved
herbicide to control reed canary grass (Phalaris arundinacea). The Port committed to monitor
the Riparian Planting Area through 2012 to document the success of the planted area. While the
final report (November 2012) recommended that no further monitoring should be required, EPA
review of the November 2012 report found that monitoring had been conducted at a new
location, so the data were not comparable to the previous data. EPA required that additional
monitoring be conducted in 2013 and that an updated report be submitted. The 2014 report
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
documented that although not all performance standards had been strictly met, the intent had
been, and annual monitoring could be replaced by monitoring on a five-year basis.
The Slip 5 mitigation site was built to offset the adverse impacts associated with the construction
of the NCDF. The mitigation site included the creation of intertidal and subtidal habitat for use
by juvenile salmonids. The Year 6 monitoring report (2011) described physical and biological
monitoring to determine the acreage by habitat type, characterized the substrate, quantified and
estimated biomass of epibenthic invertebrates, determined usage by juvenile salmonids, and
identified habitat type and usage by avifauna. The 2011 survey indicated that 6.7 acres of aquatic
habitat exist, and juvenile salmonid and avifauna observations demonstrated full use of the site
by both salmonids and waterfowl. A substantial shift in sediment composition was noted
between 2008 and 2011, from high concentrations of gravel to overwhelmingly sand. This
change may have influenced the area available for epibenthic invertebrates. EPA approved the
final monitoring report for the Slip 5 mitigation site in 2012.
Consistent with requirements defined in the previous UAO and current CD between EPA and the
PRPs for remedial design and remedial action in the Mouth of the Hylebos Waterway, a plan to
dredge SMA 421B (Taylor Way) was submitted by American Construction (new property
owner) as an agent for the CERCLA PRPs, and was conditionally approved by EPA on October
15, 2004. The plan included dredging the entire SMA 42IB area to clean sediment elevations to
remove all contaminated sediments identified in SMA 42IB, especially PCBs present at
concentrations exceeding SQOs. The remedial action included the replacement of a failing
historical timber bulkhead with a new steel sheet-pile bulkhead. Remedial actions in SMA 42IB
occurred during November and December 2004, and resulted in dredging approximately 62,000
cy of contaminated sediments from the area, with disposal of these materials at the Slip 1 NCDF.
Following American Construction's dredging project within SMA 421B, area changes were
calculated as a net loss of littoral habitat (11.8 to -10 feet MLLW) of 1.39 acres and a net gain in
subtidal habitat (<10 feet MLLW) of 1.35 acres. American Construction prepared a Mitigation
Requirement Evaluation (2010) that proposed constructing an additional compensatory
mitigation project that would result in the creation of 0.22 acre of upper intertidal habitat. The
area changes resulting from the remedial action and the construction of the compensatory
mitigation project would result in a net gain in total aquatic habitat of 0.18 acre. An additional
0.33 acre of vegetated buffer (above +11.8 feet MLLW but within 25 feet) would be planted
around the constructed intertidal habitat, improving the function and value of the adjacent
intertidal habitat. EPA reviewed the proposed mitigation plan and found that the calculations did
not accurately represent losses, directed the performing parties to propose a mitigation plan
consistent with the need to replace lost shallow subtidal habitat, and described how this could
generally be accomplished. A revised proposal is anticipated in September 2014.
Puvallup Land Transfer CD
On June 3, 2010, EPA issued a dispute resolution decision affirming EPA's decision to approve
a wetland mitigation contingency plan that was developed and submitted to EPA by the Port of
Tacoma. The dispute was subject to the terms of the Puyallup Land Transfer Consent Decree,
United States v. Port of Tacoma, Puyallup Tribe of Indians, Intervenor, No. C94-5648, W.D.
Wash., January 15, 1995. The contingency plan (completed in April 2011) provides for
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
additional mitigation work at two locations, the Hylebos Peninsula Mitigation Site (0.68 acre)
and the Outer Hylebos Mitigation Site (0.42 acre), and will satisfy the performance standards
required by the initial mitigation effort. The restored intertidal salt marsh areas are expected to
directly support the production of juvenile salmonid prey organisms and serve as a net exporter
of organic detritus that will nourish the surrounding mudflats and help sustain salmonid species.
Construction at the two sites was completed in 2012. An EPA representative inspected the
mitigation sites in September 2013, and again in May 2014. Each inspection found them to be
on track for meeting design performance standards if regular maintenance to remove invasive
plants occurs.
4.2.3.4 Institutional Controls
Institutional controls for the Hylebos Waterway remedial actions include sitewide fish use
advisories maintained by the Tacoma-Pierce County Health Department (TPCHD) in designated
areas.
Site use restrictions are often needed for areas where contaminants remain in place (i.e., caps and
the NCDF). The following remedial action elements are subject to institutional controls:
• General Metals of Tacoma (MTCA covenant filed with title);
• Arkema southeast shoreline - notice to successor in title and MTCA covenant required by
consent decree;
• Blair Slip 1 NCDF, where contaminated sediments are to remain in a containment structure
for some time.
Institutional controls might also be needed to augment OMMPs in one or more of the following
areas:
• Piers 24 and 25 (remedial action construction completed 2008);
• Occidental site (after RD/RA is accomplished);
• Arkema site (after RD/RA is accomplished).
Institutional control plans or plans for other means to regulate subsurface exploration and/or
excavation necessary to protect response actions might also be developed for other areas of the
waterway and adjacent uplands. If so, this could be accomplished as part of the approval process
for upcoming remedial action construction completion documentation.
4.2.3.5 Occidental Site Removal Actions
Information through 2009 for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.2.3.6 Post-Construction Monitoring/Operation and Maintenance (O&M)
Long-term monitoring and maintenance is required for all of the remedial action components to
assess the overall effectiveness of the remedy and ongoing source control actions. Draft
OMMPs for both the Mouth and Head of Hylebos have been prepared. EPA has determined that
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
additional post-construction sampling, beyond the post-construction verification sampling, is
appropriate before finalizing a long-term OMMP. One round of surface sediment sampling has
occurred within the Head of Hylebos, and another is planned in 2014 to be coincident with post-
construction sediment sampling in the Mouth of Hylebos.
For the Hylebos Waterway, O&M monitoring will be required for the following key remedy
elements:
• Dredged, no action, and natural recovery areas, to evaluate sediment quality trends and
determine if recontamination is occurring;
• Intertidal and subtidal caps, to confirm that buried contaminants remain physically and
chemically isolated, and recontamination from the surface water column is not occurring;
• Blair Slip 1 NCDF, to confirm with groundwater monitoring that contaminants remain
within the disposal facility; and
• Mitigation sites (Blair Slip 5 and Clear Creek Phase II), to confirm that the desired habitat
function(s) are being achieved.
An OMMP - Part 2 ("OMMP-2") was submitted by Arkema Inc. in 2006 for capping elements
of remedial actions on the Arkema Southeast Shoreline of the Head of Hylebos Problem Area of
the CB/NT site. A combination of removal and capping has been implemented for the Arkema
Southeast Shoreline in accordance with Addendum No. 2 to the 2004 Remedial Action Work
Plan (subtidal cap) and Addendum No. 3 to the 2003 Work Plan (intertidal cap). OMMP-2
defines operations, maintenance, and monitoring of the two caps and would satisfy Section IV
Task 6 of the Head of Hylebos Waterway SOW for the capped areas. EPA has not approved this
OMMP and explained in a letter to Arkema that the cap was not designed to treat dissolved
arsenic. Cap construction was approved by EPA with the written understanding that source
control at the Arkema site still remains to be accomplished. Cleanup of the Arkema site to
EPA's satisfaction will need to occur before Remedial Action certification under the CD as
described in EPA's cap approval letter.
A revised draft OMMP for Piers 24 and 25 was submitted to EPA in February 2014. The project
involved capping contaminated intertidal and subtidal sediments and related remediation
activities as described in the Final RACR. Site construction work for the project was performed
between October 2007 and February 2008. This current, revised draft OMMP responds to
comments presented in EPA's conditional project approval document following EPA's review of
the design package (2007), and has been modified to address post-construction, long-term
maintenance and monitoring efforts throughout the anticipated lifetime of the cap for the Pier 24
and 25 Embankment Remediation Project.
A draft final Operations, Monitoring, and Maintenance Plan for the Mouth of Hylebos Waterway
(Segments 3, 4, and 5) was prepared in December 2012. The primary objective of the sediment
monitoring is to verify that surface sediment concentrations in post-dredging residual areas and
other natural recovery areas within Segments 3 to 5 achieve SQOs within the time-frame
established by EPA in the ROD and SOW. The Draft OMMP is being reviewed by EPA with the
expectation that pre-OMMP sampling will occur in the Mouth of Hylebos, consistent with that
which has occurred and is planned for the Head of Hylebos in 2014.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
4.2.4. Progress since the Last Five-Year Review
See the previous section for detailed information about progress during the period of this FYR in
the Head of Hylebos problem area, Mouth of Hylebos problem area, and Occidental Site.
4.2.4.1 Previous Protectiveness Statement
The protectiveness statement in the third FYR (2009) stated:
"For the Hylebos Waterway, the remedy is expected to be protective of human
health and the environment upon completion. Most remedial action construction
has been accomplished, and the additional actions needed for the remedy
throughout the waterway to be protective described in the ROD and this report,
are progressing toward completion."
4.2.4.2 Status of Recommendations
One issue with recommendation was made for the Hylebos Waterway in the third FYR, as
described below, and an evaluation of progress follows.
• Issue: Arkema site source control is needed to meet RA performance standards.
• Recommendation: Perform RI/FS and RD/RA for the Arkema site to investigate and
address contamination upland and beneath the waterway.
Note: This issue is now described as an action that needs to be implemented to complete
remedial action. Thus, for this FYR, the action is listed in Table 7-2 as an action item that
does not affect protectiveness.
RD and RA activities that were completed between 2001 and 2006 are documented in the 2011
RACR for the Head of Hylebos. RD and RA activities that have been completed recently were
focused on sediment sampling. Sediment sampling of the sediment cap was completed on
January 29, 2009, and there were no SQO exceedances for organic compounds, arsenic, or
mercury.
Sediment sampling was conducted on October 19-20, 2010 (adjacent to the Schnitzer Steel of
Tacoma shoreline sediment cap) after Ecology approved the Sediment SAP on April 14, 2010.
PCBs, BEHP, BBP, mercury, and zinc exceeded the SQS or SQOs. A diver inspection of the
outfall pipe during August 2010 found that approximately a 25-30 foot length of pipe was
exposed; however, the outfall is still functional. Additional sediment sampling was conducted
during February 14-17, 2012 at the Head of Hylebos Waterway. The 2012 sampling program
was based on replicating the 2004-2006 post-dredging Type 4 confirmation sampling program.
Concentrations of total PCBs, arsenic, zinc, and benzo(b+k)fluoranthene had increased in all
sampled areas, and total PCBs in 2012 exceeded the SQO.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
4.2.5. Five-Year Review Process
4.2.5.1 Administrative Components
The Hylebos Waterway FYR team was led by Jonathan Williams, EPA Remedial Project
Manager (RPM). Deborah Johnston (biologist) with USACE, Seattle District, assisted with the
review as a representative of the support agency.
By December 2013, the review team had been formed and the review schedule had been
established for the following activities:
• Document collection and review;
• Data assessment and analysis;
• Site inspection;
• Interviews and community notification and involvement; and
• FYR report development and review.
The FYR has a statutory completion date of December 23, 2014.
4.2.5.2 Community Involvement
On January 17, 2014, a display advertisement ran in the Tacoma News Tribune newspaper
providing notification and contact information for the FYR. In addition, on January 21, 2014,
EPA Community Relations staff sent postcards to stakeholders and neighbors included on the
CB/NT project mailing list (approximately 1,150 addressees), providing notification about the
FYR process. Both notifications requested that any information that people would like EPA to
consider during the review be provided to EPA before April 15, 2014.
On February 19, 2014, Kevin Rochlin, Bill Ryan, and Jonathan Williams (all with EPA Region
10) met with Bill Andersen, the Executive Director of Citizens for a Healthy Bay (CHB), at
which time EPA provided information on CB/NT activities and preparation of the fourth FYR. A
telephone interview was completed with CHB.
No input was received from the public for the overall CB/NT site Sediment OU or for the
Hylebos Waterway.
4.2.5.3 Document Review
A review of reports pertinent to this FYR was conducted by the review team. The types of
documents reviewed included decision documents, risk assessment documents, annual data
reports, technical memoranda, and other supporting materials. OU 01 Attachment 1 is a
complete list of documents reviewed during this FYR.
4.2.5.4 Data Review and Evaluation
Data review and evaluation of remedial activities are discussed in the previous Sections 4.2.3 and
4.2.4. In order to protect the remedy and prevent spreading of subsurface sediment
contamination within waterways, EPA has, to a great extent, depended upon coordination with
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
USACE, Seattle District, who issues permits under the Clean Water Act for in-water
construction projects. The Seattle District office has a Standard Operating Procedure (SOP) for
coordinating with EPA prior to issuing permits within the CB/NT site. This SOP allows EPA to
work through Seattle District to include permit conditions needed to prevent the spread of
contamination and/or protect remedial actions already accomplished. The Seattle District
Regulatory Branch has also developed standard permit language for CERCLA sites that is
applied even if EPA does not identify any particular concerns or the need for particular permit
conditions.
Operations, maintenance, and monitoring plans (OMMPs) are being developed for dredged,
capped, and natural recovery areas within Hylebos Waterway. As the OMMPs are developed,
EPA will evaluate whether some type of institutional controls are needed to supplement the
OMMP provisions.
4.2.5.5 Interviews
No interviews were conducted.
4.2.6. Technical Assessment
Question A: Is the remedy functioning as intended by the decision documents?
Answer: Yes.
However, not all remedial actions are complete. Ongoing response actions include RI/FS work
associated with the Occidental site (Mouth of Hylebos Problem Area) and the Arkema site (Head
of Hylebos Problem Area). A definitive assessment will require all aspects of the remedy to be
completed, and will require trend analysis of long-term monitoring data.
The ROD addresses source control and sediment remediation needed to reach sediment cleanup
objectives, which are then expected to provide a benthic habitat protective of human health and
the environment. Source control efforts are continuing, focused on the Arkema and Occidental
sites. Most surface sediment within the waterway has been remediated to SQOs.
To protect the remedy, EPA has, to a great extent, depended upon coordination with the USACE,
Seattle District, as described above (under Data Review and Evaluation). OMMPs, which might
include institutional controls (ICs), are being developed for long-term remedy protection and
evaluation purposes. Sitewide ICs in the form of fish advisories have been put in place to
provide current protectiveness.
Buried contaminated sediments are known and suspected to exist in some areas where remedial
dredging did not occur. To remain protective, these areas need to be relatively quiescent and
receive clean sediment. Active tugboat operations, both existing and proposed, in relatively
shallow waters could bring contaminated sediment to the surface.
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy still valid?
Answer: Yes.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Changes in Standards and To Be Considered. Applicable or relevant and appropriate
requirements (ARARs) cited in the ROD were reviewed to evaluate changes in the ARARs, if
any, since the third FYR. The 2013 revisions to the Sediment Management Standards (SMS)
resulted in no material changes relative to the pre-revision SMS and MTCA. The marine
sediment cleanup objective (SCO) benthic protection values under the 2013 SMS are the same as
the 1991 SQS values (which were established after the 1989 CB/NT ROD was issued), and the
requirements for protection of human health and higher trophic-level species are consistent with
MTCA, which was promulgated in 1996. EPA has previously determined that the CB/NT ROD
SQOs are protective in light of the 1991 SMS and MTCA.
There are no TBCs and no newly promulgated standards that might be ARARs to the site that
affect the protectiveness of the remedy.
Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics. The
ROD described current and future land uses and identified likely exposure pathways; at the time
of this review, the descriptions of land use remain accurate for the Site conditions, and there are
no actual or potential changes in exposure pathways that have occurred.
There have been no changes in the toxicity standards for the COCs that affect the protectiveness
of the remedy. The Apparent Effects Threshold (AET) approach was used to establish both the
ROD SQOs and the State SMS. It is acknowledged that for non-polar organic compounds, the
ROD SQO values are in dry weight units (mg/kg) and the State SMS values (promulgated after
the ROD) are in organic normalized dry weight units (mg/kg-organic carbon (oc)). However,
when the State standards were developed using the AET approach, both total organic carbon
(TOC)-normalized AET values and dry weight-normalized AET values were generated using the
same data set of paired sediment chemistry and sediment toxicity test results. Unit conversions
between dry weight and oc-normalized data are common in sediment evaluations.
It should be noted that since the ROD, the DMMP has listed both chlordane and dioxins/furans
as bioaccumulative chemicals. Neither chemical was evaluated for human health risks in the
RI/FS.
The US ACE shoal sediment characterization study in 2013 identified dioxins/furans at
concentrations of several hundred ppt TEQ. Almost all previous sediment quality investigations
excluded analysis of dioxin/furan compounds, and the ROD does not have an SQO for
dioxins/furans. Additional data, focused on surface sediment quality, would be needed to
determine whether the contamination is site-related and action is warranted due to newly
identified contamination.
Sediment sampling at the Head of Hylebos has identified that concentrations of some
contaminants (e.g., PCBs and zinc) are trending upward. If these trends were to continue over
time, and SQOs were exceeded more broadly in the area, then additional actions may be needed
to ensure protectiveness. Ongoing sediment sampling will be used to monitor this trend.
Changes in Land Use. There have been no changes in the physical conditions of the site that
would affect the protectiveness of the remedy.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Remedial Action Objectives. The RAOs from the ROD are still valid and protective for the
site.
Question C: Has any other information come to light that could call into question the
protectiveness of the remedy?
Answer: No.
No other information is known that calls into question the protectiveness of the remedy.
4.2.6.1 Technical Assessment Summary
According to the data reviewed and information obtained, the remedy is incomplete but is
functioning as intended where implemented; there is no information which definitively calls into
question the anticipated protectiveness of the remedy once fully implemented. The most
important actions that remain to be completed include source control efforts, with a particular
focus on the Arkema and Occidental sites, and implementation of legally enforceable
Institutional Controls to protect against future actions that could adversely impact areas of the
waterway where sediment has been remediated. No other information is known that calls into
question the protectiveness of the remedy. A meaningful long-term evaluation of remedy
functionality will require all aspects of the remedy to be completed and sediment monitoring
trends to remain favorable for some time.
4.2.7. Issues and Recommendations/Follow-up Actions
Issues and recommendations/follow-up actions that affect protectiveness for the Hylebos
Waterway are provided in Section 7, Table 7-1.
Action items for the Hylebos Waterway that do not affect remedy protectiveness, but are
expected to require future action, are presented in Table 7-2.
4.2.8. Protectiveness Statement
The protectiveness statement is provided in Section 8.
4.3. Sitcum Waterway
4.3.1. Background
The Sitcum Waterway is located between the Blair Waterway to the northeast and the former
Milwaukee Waterway and Milwaukee Habitat Area to the southwest (see Figure 4-1). Sitcum
Waterway is a deep navigational waterway that was created by dredging and filling native
mudflats since 1910. The Port of Tacoma owns the submerged land and bottom sediment in the
waterway and the land adjacent to the waterway. The Port operates Terminal 7 as a container
handling and bulk unloading facility.
The Sitcum Waterway Problem Area comprised a 55-acre area of contaminated marine
sediments in the main navigational channel and berth areas. Sediments were contaminated with
metals (arsenic, cadmium, copper, lead, nickel, and zinc) and PAHs at concentrations above the
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
SQOs identified in the CB/NT ROD. Primary contaminant sources included historical releases
of metal ores handled at Terminal 7, and releases from a stormwater outfall (SI-172) that
discharges runoff from an industrial and commercial area covering approximately 170 acres.
Contaminated sediments were dredged and disposed of in the Milwaukee Waterway NCDF. The
Milwaukee Waterway Habitat Area and the Clear Creek Habitat Improvement Project (also
known as the Clear Creek Phase 1 Area) are the mitigation sites for the Sitcum Waterway
Remediation Project.
4.3.2. Site Chronology
Information for this section is in the third FYR (EPA 2009), which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.3.3. Remedial Actions
4.3.3.1 Remedy Selection
Remedy selection for the CB/NT Sediments OU 01 is described in Section 4.1.
4.3.3.2 Remedy Implementation (Sources)
The major sources of contaminants to the waterway were addressed by the cessation of black ore
off-loading at Terminal 7 and implementation of source control efforts (including storm drain
sediment clean out) associated with the storm drain SI-172.
4.3.3.3 Remedial Action (Sediments)
Subsequent to EPA's issuance of the 1989 CB/NT ROD, the remedial action for addressing
contaminated sediments in the Sitcum Waterway Problem Area was approved in a 1993
Explanation of Significant Differences (ESD). Based on these documents and the EPA-approved
Remedial Design, the Sitcum Waterway Remediation Project included the following:
• Dredging approximately 428,000 cy of contaminated sediments from Sitcum Waterway for
disposal in the Milwaukee Waterway NCDF8.
• Dredging approximately 2.1 million cy of sediment from the Blair Waterway for
construction of, and disposal in, the Milwaukee Waterway NCDF. Of the 2.1 million cy,
1,225,400 cy were designated as "clean" (appropriate for in-water disposal under DMMP)
and targeted for construction of the Milwaukee Waterway nearshore fill berm. The
remainder of the Blair Waterway sediment was targeted for disposal in the Milwaukee
NCDF.
8 The bulk of this volume, approximately 396,000 cy, was to be removed from the "Phase 1 Area," or bottom
sediments from Sitcum Waterway, the extent of which was limited by riprap and Pier 7 along the northern shoreline.
The "Phase 2 Area," or areas of sediment over existing riprap and slopes under Pier 7, was to be removed to the
extent technically feasible. The ESD estimated approximately 32,300 yards would be removed in the Phase 2 Area.
After construction, Phase 2 was to be evaluated for potential future action. In the EPA-approved memorandum from
the Port, dated October 1, 1995, it was determined that no further action would be required in the Phase 2 Area, and
that the area beneath Pier 7 would continue to be evaluated for monitored natural recovery as specified in the
OMMP. The area beneath Pier 7 is now known as Area B, while the original Phase 1 Area is now known as Area A.
Area B is a 4.5-acre monitored natural recovery area.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
• Construction of a NCDF utilizing approximately 72 percent of the Milwaukee Waterway.
To compensate for the fill of the Milwaukee Waterway, construction of habitat mitigation
occurred at two locations: 1) at the Milwaukee Habitat Area located in front of the nearshore fill
closure berm in the Mouth of the Milwaukee Waterway, consisting of approximately 20 acres of
intertidal habitat; and 2) at an "additional mitigation area" consisting of approximately 9.5 acres
of restored, off-site, refuge habitat for salmon and other fish from the Puyallup River.
Subsequent to the ESD, the Clear Creek Habitat Improvement Project9 was selected as the
"additional mitigation area."
Final dredging and fill volumes were adjusted slightly during construction. EPA approved the
Construction Completion Report for the dredging of Sitcum and Blair Waterways, for the
Milwaukee NCDF, and for the Milwaukee Habitat Mitigation Area on July 25, 1995. EPA
approved the Construction Completion Report for the Clear Creek Habitat Area on December 17,
1998.
As discussed above, the ESD was issued and a consent decree for implementation of the Sitcum
Waterway Remediation Project was finalized in 1993. In the consent decree, the Port committed
to operate and maintain the NCDF and habitat restoration areas in the long term.
4.3.3.4 Post-Construction Monitoring/Operation and Maintenance
The long-term monitoring efforts associated with the Sitcum Waterway Remediation Project are
documented in the OMMP for the Sitcum Waterway Remediation Project (1994, updated 1995).
Long-term monitoring efforts have been completed for the sediments in Sitcum Waterway and
for the mitigation sites associated with the Sitcum Waterway Remediation Project (i.e.,
Milwaukee Habitat Mitigation Area, Clear Creek Habitat Improvement Project). Results of
those long-term monitoring efforts are described in previous FYRs. The only remaining long-
term monitoring effort is for the Milwaukee NCDF.
4.3.3.5 Groundwater Quality Monitoring Associated with the Milwaukee
Nearshore Confined Disposal Facility
Groundwater quality monitoring is associated with the Milwaukee NCDF, which was filled with
contaminated sediment and completed in 1995. The groundwater monitoring program was
designed to detect and evaluate possible long-term changes in groundwater quality in the areas
surrounding the containment facility to ensure compliance with the performance standards
(marine chronic criteria or ambient surface water quality in adjacent surface water, whichever is
greater) at the point of compliance. The monitoring results provide information to determine
whether certain constituents are being leached from the fill material and horizontally transported
outside the fill area by groundwater. The point of compliance is the sediment/surface water
9 Attachment A to the CD (1993) detailed a conceptual design for the "Clear Creek" Habitat Improvement Project
(sometimes referred to as the Clear Creek Phase 1 Project) proposed for the "additional mitigation" required in the
ESD. The Clear Creek site is located near the mouth of Clear Creek, a left bank tributary of the Puyallup River near
River Mile 2.9. The project was designed to provide refuge, feeding, and rearing habitat for juvenile salmonids and
other wildlife in the lower reaches of the Puyallup River system. Project components included development of a
pond/wetland habitat complex, excavation of a refuge bay, excavation of a tidal mudflat, improvement of upland
habitat, and modification of the flood gate to facilitate passage of juvenile and adult salmonids and other fish.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
interface outside of the berm and peninsulas. Stage 1 monitoring compares groundwater quality
to baseline conditions.
Groundwater sampling and analysis is consistent with the Groundwater Sampling Operations
Manual (Appendix A) included in the 1994 OMMP (Port of Tacoma 1994), with some
modifications agreed to by the Port and EPA (see Hart Crowser 2013). In its transmittal letter
for Round 2 monitoring (Port of Tacoma 2008), the Port proposed to add zinc as an additional
indicator metal to the analyte list, since zinc has increasingly been identified as a metal of
concern at a number of sites in Commencement Bay. EPA concurred with these
recommendations and zinc was added to the analysis regime in 2013.
The first round of groundwater quality monitoring was completed in 2003, the second round was
completed in 2008, and the third round was completed in 2013 (Hart Crowser 2013) with
reported results that were approved by EPA in July 2013. Samples were collected in March and
April 2013, and were analyzed for dissolved arsenic, copper, lead, nickel, zinc, salinity, and total
organic carbon.
Based on Stage 1 monitoring results (2003, 2008, 2013), the monitoring program indicates that
the performance standard at the point of compliance has not been exceeded. There have been no
increases above baseline conditions, and thus no statistically significant increases, at any given
well for any of the indicator metals. Based on analysis of indicator metals and conventional
parameters, there appears to have been little to no change in containment facility fill conditions
in MW-14 since post-construction baseline sampling in 1996. As Stage 1 monitoring indicated,
there were no statistically significant increases at any given well in any of the rounds of
monitoring, and concentrations were well below marine chronic water quality criteria; therefore,
Stage 2 monitoring is not proposed.
These results indicate that the NCDF is functioning as intended, and that constituents are not
being leached from the sediment fill.
All groundwater data have been input to the Washington State Department of Ecology
Environmental Information Management (EIM) database, under the EIM Study ID "Sitcum
Waterway".
The next monitoring event is scheduled for March 2018.
4.3.4. Progress since the Last Five-Year Review
Since the third FYR, the 2013 groundwater monitoring effort associated with the Milwaukee
NCDF was completed.
4.3.4.1 Previous Protectiveness Statement
The protectiveness statement in the third FYR (2009) stated:
"The remedy at the Sitcum Waterway Problem Area is protective of human health and
the environment, and exposure pathways that could result in unacceptable risks are being
controlled."
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
4.3.4.2 Status of Recommendations
There were no issues or recommendations/follow-up actions made for Sitcum Waterway in the
third FYR (2009).
4.3.5. Five-Year Review Process
4.3.5.1 Administrative Components
The Sitcum Waterway FYR team was led by Karen Keeley, EPA RPM, Region 10.
By December 2013, the review team had been formed and the review schedule had been
established for the following activities:
• Document collection and review;
• Data assessment and analysis;
• Interviews and community notification and involvement; and
• FYR report development and review.
The FYR has a statutory completion date of December 23, 2014.
4.3.5.2 Community Involvement
On January 17, 2014, a display advertisement ran in the Tacoma News Tribune newspaper
providing notification and contact information for the FYR. In addition, on January 21, 2014,
EPA Community Relations staff sent postcards to stakeholders and neighbors included on the
CB/NT project mailing list (approximately 1,150 addressees), providing notification about the
five-year review process. Both notifications requested that any information that people would
like EPA to consider during the review be provided to EPA before April 15, 2014. A telephone
interview was completed with Citizens for a Healthy Bay.
On February 19, 2014, Kevin Rochlin, Bill Ryan, and Jonathan Williams (all with EPA Region
10) met with Bill Andersen, the Executive Director of Citizens for a Healthy Bay (CHB), at
which time EPA provided information on CB/NT activities and preparation of the fourth FYR.
No input was received from the public for the overall CB/NT site Sediment OU or for the Sitcum
Waterway.
4.3.5.3 Document Review
The types of documents reviewed included documents related to the analysis of institutional
controls. Results of long-term monitoring efforts were discussed in a previous section.
With regards to institutional controls, documents reviewed include:
• The Notice of Consent Decree for the Sitcum Waterway Remediation Project Consent
Decree (No. 93-5462 RJB) was recorded in Pierce County on December 23, 2009.
• The Port of Tacoma finalized and recorded four Environmental Covenants pursuant to the
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Uniform Environmental Covenants Act (UECA)10:
o Second Amended and Restated Environmental Covenant for the Milwaukee Nearshore
Confined Disposal Facility and Closure Berm, Sitcum Waterway Remediation
Project, recorded in Pierce County on November 22, 2011.
o Amended and Restated Environmental Covenant for the Milwaukee Habitat Area - Port
of Tacoma-Owned, Sitcum Waterway Remediation Project, recorded in Pierce
County on November 22, 2011.
o Environmental Covenant for the Milwaukee Habitat Area - State-Owned within Port
Aquatic Lands Management Area, recorded in Pierce County on December 14, 2011.
o Clear Creek Habitat Improvement Project (Phase 1), recorded in Pierce County on May
6, 2010.
• For each of the properties subject to an Environmental Covenant related to the Sitcum
Waterway Remediation Project, the Port of Tacoma provided institutional control
information to the City of Tacoma for incorporation into the City's "govME" website,
which is available at the link:
http://wspwit01.ci.tacoma.wa.us/govME/Admin/Inter/StartPage/default.aspx
This website allows users to see locations of cleanup projects in relation to tax parcel
numbers, as well as many other layers. In February 2012, EPA confirmed that the
information was accurately entered on the website.
To be consistent with other document mapping, the City of Tacoma named the Sitcum
Waterway documents as follows:
o COV-0003 201111220132 (Milwaukee Nearshore Confined Disposal Facility and
Closure Berm)
o COV-0004 201111220414 (Milwaukee Habitat Area - Port of Tacoma Owned)11
o COV-0005 201112140597 (Milwaukee Habitat Area - State-Owned within Port Aquatic
Lands Management Area)
o COV-0006 201112140598 (Aquatic Lands Easement for Conservation Uses).
• The Port of Tacoma provided Ecology with the Environmental Covenants for input into
Ecology's UECA registry in the ISIS database12. In February 2012, EPA confirmed that
10 The Uniform Environmental Covenants Act (UECA) was passed by the State of Washington in 2007. RCW
64.70.
11 UECA includes a requirement for consultation with the local land use planning authority. EPA formally
consulted with the City of Tacoma for the two Milwaukee Habitat Area ECs, as documented in correspondence
dated July 19, 2011.
12 Ecology's UECA registry is a download from Ecology's ISIS (contaminated sites) database. All environmental
covenants are input to the ISIS database and the UECA web site searches the ISIS database to provide the report for
a given geographical area. To access the UECA registry, start from Ecology's internet site: http://www.ecy.wa.gov/.
In the green bar at the top click "databases." The fourth link is for Contaminated Site Cleanup, which is a direct link
to the database https://fortress.wa.gov/ecy/tcpwebreporting/Default.aspx . Click "Create a Report" and select
"Environmental Covenant Registry" report type. Click Environmental Covenants Registry Report, and select your
filter criteria (i.e., zip code, county, site name). Click "show report." Scroll to the 13th column to see the county
filing number. To see the actual document, use the County Auditor or Assessor Web site for the appropriate county.
Specific instructions may change as the database may be revised in the future.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
the information was accurately entered on the website.
• The State of Washington and the Port of Tacoma entered into an Aquatic Lands Easement
for Conservation Uses (Easement No. 51-087166) related to the Sitcum Waterway
Remediation Project, Milwaukee Habitat Area. The easement was recorded in Pierce
County on December 14, 2011.
The CD for the Sitcum Waterway Remediation Project remains an effective Enforcement Tool
and IC for requiring certain administrative duties in support of the remedy. With the additional
covenant restrictions and general deed notices completed as part of the Port's IC analysis efforts,
proprietary and informational controls should provide adequate and appropriate protectiveness
and effectiveness. The proprietary controls will be properly executed, run with the land, and are
effective for binding future interest holders.
4.3.5.4 Data Review and Evaluation
Results from the long-term monitoring activities are discussed in the previous section on Post-
Construction Monitoring/O&M.
4.3.5.5 Site inspection
EPA did not conduct any site inspections.
4.3.5.6 Interviews
An interview was performed by telephone with CHB for the overall CB/NT site. No comments
were provided.
4.3.6. Technical Assessment
Question A: Is the remedy functioning as intended by the decision documents?
Answer: Yes.
The remedial action is complete, long-term monitoring is complete, and all results show that
performance standards were met. Institutional controls are in place to address all areas of site-
related contaminants that are at levels that do not allow for unrestricted use/unrestricted
exposure. Institutional controls are properly implemented and effective in preventing exposure
and protecting the remedy, and mitigation habitat areas are also protected by Environmental
Covenants.
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy still valid?
Answer: Yes.
Changes in Standards and To Be Considered. See Section 4.2.6 (Question B).
Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics. See
Section 4.2.6 (Question B).
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Changes in Land Use. There have been no changes in the physical conditions of the site that
would affect the protectiveness of the remedy.
Remedial Action Objectives. The RAOs from the ROD are still valid and protective for the
site.
Question C: Has any other information come to light that could call into question the
protectiveness of the remedy?
Answer: No.
No other information is known that calls into question the protectiveness of the remedy.
4.3.6.1 Technical Assessment Summary
According to the data reviewed, the remedy is functioning as intended by the ROD as amended
by the ESD. There have been no changes in the ARARs, standards, or To Be Considered that
could affect the protectiveness of the remedy. The remedy is still protective of human health and
the environment. No other information is known that calls into question the protectiveness of the
remedy
4.3.7. Issues and Recommendations/Follow-up Actions
No issues or recommendations/follow-up actions were identified during this fourth FYR for the
Sitcum Waterway.
4.3.8. Protectiveness Statement
The protectiveness statement is provided in Section 8.
4.4. St. Paul Waterway
4.4.1. Background
The St. Paul Waterway is located between the Puyallup River to the north and the Middle
Waterway to the south (see Figure 4-1). The St. Paul Waterway Problem Area is a 17-acre area
of contaminated marine sediments adjacent to the Simpson Tacoma Kraft Mill (former owners
include Champion International and St. Regis). Due to releases from the pulp and paper mill,
sediments were contaminated with VOCs, SVOCs, PAHs, and organic debris.
4.4.2. Site Chronology
Information for this section is in the third FYR (EPA 2009), which is available online at
http://yosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.4.3. Remedial Actions
4.4.3.1 Remedy Selection
Remedy selection for the CB/NT Sediments OU 01 is described in Section 4.1.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
4.4.3.2 Remedy Implementation (Sources)
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.4.3.3 Remedial Action (Sediments)
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.4.3.4 Post-Construction Monitoring/Operation and Maintenance
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
The remedial actions initiated for the St. Paul Waterway Problem Area of the CB/NT site have
been successfully completed, long-term monitoring efforts have been completed, and the remedy
implemented remains protective of human health and the environment.
4.4.4. Progress since the Last Five-Year Review
Between December 2004 and December 2009, EPA completed an IC analysis to ensure that ICs
are consistent with recent EPA guidance and recommendations. Since 2009, EPA evaluated
whether additional ICS are needed, and whether a decision document modification is
appropriate. EPA determined that the ICs in place are protective for the long term.
4.4.4.1 Previous Protectiveness Statement
The protectiveness statement in the third FYR (2009) stated:
"The remedial actions at the St. Paul Waterway Problem Area of the CB/NT Site have
been successfully completed, all required long-term monitoring efforts have been
completed, and the remedy remains protective of human health and the environment."
4.4.4.2 Status of Recommendations
There were no issues or recommendations/follow-up actions identified for St. Paul Waterway in
the third FYR (2009).
4.4.5. Five-Year Review Process
4.4.5.1 Administrative Components
The St. Paul Waterway FYR team was led by Karen Keeley, EPA RPM, Region 10.
By December 2013, the review team had been formed and the review schedule had been
established for the following activities:
• Document collection and review;
• Data assessment and analysis;
• Interviews and community notification and involvement; and
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
• FYR report development and review.
The FYR has a statutory completion date of December 23, 2014.
4.4.5.2 Community Involvement
On January 17, 2014, a display advertisement ran in the Tacoma News Tribune newspaper
providing notification and contact information for the FYR. In addition, on January 21, 2014,
EPA Community Relations staff sent postcards to stakeholders and neighbors included on the
CB/NT project mailing list (approximately 1,150 addressees), providing notification about the
five-year review process. Both notifications requested that any information that people would
like EPA to consider during the review be provided to EPA before April 15, 2014. A telephone
interview was completed with Citizens for a Healthy Bay.
On February 19, 2014, Kevin Rochlin, Bill Ryan, and Jonathan Williams (all with EPA Region
10) met with Bill Andersen, the Executive Director of Citizens for a Healthy Bay (CHB), at
which time EPA provided information on CB/NT activities and preparation of the fourth FYR.
No input was received from the public for the overall CB/NT site Sediment OU or for the Sitcum
Waterway.
4.4.5.3 Document Review
The only documents reviewed for this FYR were those reviewed as part of the institutional
control analysis, as described below.
The third FYR (2009) for the CB/NT site included this text for the St. Paul Waterway:
"The Washington Department of Natural Resources indicated that a Notice of Consent
Decree, pursuant to the 1991 Consent Decree, could not be found, and that a notice
would be recorded in December 2009. The actual recording date for the notice will be
provided in the next five-year review. "
The Washington Department of Natural Resources (DNR) recorded a Notice of Consent Decree,
pursuant to the 1991 Consent Decree, with the Pierce County Auditor's Office on December 14,
2009. This action satisfies the requirement in the 1991 Consent Decree to record notice of the
Consent Decree on the property DNR manages that is a part of the St. Paul Waterway
remediation at the CB/NT site. Copies of the documents are in the EPA Site File.
In addition, the third FYR (2009) included this text:
"The evaluation of institutional controls concludes that ICs in place are satisfactory
given circumstances of the St. Paul Waterway Problem Area cleanup and CD. However,
the IC evaluation raises some questions about whether the existing decision document
and/or ICs would be protective under potential future scenarios where there may be
changes in land use either through lease agreements by Washington DNR, a subsequent
owner of the Simpson Property, or property transfer from DNR. Over the next year, EPA
will evaluate if additional ICS are needed, and whether a decision document modification
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
is appropriate."
For the St. Paul Waterway, EPA has evaluated whether the existing decision document and/or
ICs would be protective under potential future scenarios where there may be changes in land use
either through lease agreements by Washington DNR, a subsequent owner of the Simpson
Property, or property transfer from DNR.
In evaluating this issue, EPA has considered the terms and conditions of the St. Paul Waterway
Consent Decree:
• The 1991 CD, Section VI, states, in part:
"The obligations of each Settling Defendant who owns any interest in the Mill or
property included in the St. Paul Waterway Problem Area, with respect to undertaking
and maintaining the Work set forth in this Consent Decree and the attached Monitoring
Plan, or developed there under, shall run with the land and shall be binding upon any and
all persons who acquire any interest in the Mill or any property included in the St. Paul
Waterway Problem Area. Within thirty (30) calendar days of the effective day of this
Consent Decree, the Settling Defendants shall record a copy of this Decree with the
Recorder's Office, Pierce County, Washington. A copy of the recorded notice shall be
sent to EPA." [Paragraph 40]
Paragraph 41 of the Consent Decree permits free alienation of the property within the
Problem Area with 60 days notice to EPA of such alienation.
Paragraph 42 of the Consent Decree requires that any deed, title, or other instrument of
conveyance regarding the Mill or St. Paul Waterway Problem Area shall contain a notice
that such property is the subject of this Consent Decree.
Additionally, DNR and Simpson entered into a lease and a Material Deposition Agreement that
includes all of the 17 acres included in the cleanup area. The lease references the obligations of
the parties to maintain the remedy under the 1991 CD. EPA confirmed that Simpson and the
State complied with the requirements of the CD, and copies of the documents are in the EPA Site
File.
As described in earlier FYRs, EPA conducted an analysis of the institutional controls to ensure
that they are consistent with EPA's September 2004 "Strategy to Ensure Institutional Control
Implementation at Superfund Sites." ICs were determined to be complete for St. Paul Waterway,
and a "Notice of Consent Decree" has been recorded for the relevant properties.
Given site-specific information described above, including obligations as set forth in the CD and
DNR Lease Agreements, EPA evaluated whether additional ICs were necessary and determined
that the ICs in place are protective for the long term. No further work is required.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
4.4.5.4 Data Review and Evaluation
Long-term monitoring has been completed for this site. No new data were made available for
review.
4.4.5.5 Site Inspection
No site inspection was conducted.
4.4.5.6 Interviews
No interviews were performed.
4.4.6. Technical Assessment
Question A: Is the remedy functioning as intended by the decision documents?
Answer: Yes.
The remedial action and long-term monitoring efforts are completed, and performance standards
have been met. Institutional controls are in place to address all areas of site-related constituents
that are at levels that do not allow for unrestricted use/unrestricted exposure. Institutional
controls are properly implemented and effective in preventing exposure and protecting the
remedy. Future long-term monitoring efforts associated with the sediment cap will occur if there
is a significant earthquake or wind storm.
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy still valid?
Answer: Yes.
Changes in Standards and To Be Considered. See Section 4.2.6 (Question B).
Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics. See
Section 4.2.6 (Question B).
Changes in Land Use. There have been no changes in the physical conditions of the site that
would affect the protectiveness of the remedy.
Remedial Action Objectives. The RAOs from the ROD are still valid and protective for the
site.
Question C: Has any other information come to light that could call into question the
protectiveness of the remedy?
Answer: No.
No other information is known that calls into question the protectiveness of the remedy.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
4.4.6.1 Technical Assessment Summary
According to the data reviewed and information obtained from the site inspection, the remedy is
functioning as intended by the ROD, as amended by the ESD. There have been no changes in
the ARARs, standards, or To Be Considered that could affect the protectiveness of the remedy.
The remedy is still protective of human health and the environment. No other information is
known that calls into question the protectiveness of the remedy.
4.4.7. Issues and Recommendations/Follow-up Actions
No issues or recommendations/follow-up actions were identified during this fourth FYR for the
St. Paul Waterway.
4.4.8. Protectiveness Statement
The protectiveness statement is provided in Section 8.
4.5. Middle Waterway
4.5.1. Background
The Middle Waterway is bordered by the Thea Foss Waterway on the southwest and the St. Paul
Waterway on the northeast. The Middle Waterway is approximately 3,500 feet long and 300 feet
wide. The total area of the Middle Waterway is approximately 49 acres. The head of the Middle
Waterway consists of one of the few remaining natural intertidal mudflats in Commencement
Bay.
Additional background information is in the third FYR (EPA 2009), which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.5.2. Site Chronology
Information through 2009 for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
Key Middle Waterway actions that have been completed by the Middle Waterway Action
Committee (MWAC) and the Washington Department of Natural Resources (DNR) since 2009
are presented below:
June 2009 MWAC completes Year 5 monitoring in Areas A and B
Summer 2009 DNR completes Year 5 monitoring in Area C
Summer 2010 DNR completes Year 6 monitoring in Area C
July 2012 MWAC completes Year 8 monitoring in Areas A and B
February 2013 MWAC completes Additional Response Action in Area A
June 2013 DNR completes Year 10 monitoring in Area C
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
4.5.3. Remedial Actions
4.5.3.1 Remedy Selection
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.5.3.2 Remedy Implementation (Sources)
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.5.3.3 Remedial Action (Sediments)
Since the third FYR, remedial activities in the Middle Waterway for Areas A and B, and Area C,
have been completed as described below.
4.5.3.3.1 Remedial Action - Areas A and B
After evaluating the increasing sediment mercury concentrations reported in the third FYR, EPA
determined that an additional response action (ARA) was required in Area A of the Middle
Waterway. No additional remediation was conducted in Area B.
The EPA-approved Final Additional Response Action Completion Report (Anchor QEA 2013 a)
provides details of the ARA that was completed to address mercury concentrations near the
Natural Recovery areas (sediment management units [SMUs] 4c and 25) of Area A (see Figure
4-3). The ARA included placement of Enhanced Natural Recovery (ENR) and shore protection
material within and immediately adjacent to SMUs 4c and 25 and in portions of SMUs 19a, 19b,
and 20 (location of SMUs are shown in Figures 4-3 and 4-4); removal of large broken concrete
and debris that had been used as slope protection along the bank of SMU 25 to allow for
placement of the material; and improvements to the uplands to allow access for placement of the
ENR and shore protection materials. Locations of these actions are shown on Figure 4-4.
ARA construction occurred between January 23 and February 14, 2013. MWAC selected RV
Associates, Inc. (RV Associates) to perform the construction activities, and Anchor QEA
provided construction oversight. The construction activities included mobilization and upland
property preparation, debris removal and disposal, placement of ENR material, placement of
shore protection material, and property cleanup and demobilization. Before and after
construction photographs of the ARA in Area A are shown on Figure 4-5.
The Year 10 Monitoring Event, which consists of a sediment sampling effort, is planned for
summer 2014. This sampling event will also verify if the remedial action is working as designed.
Figure 4-6 shows the final EPA-Approved Remedies Applied to Areas A and B before the ARA
was completed.
4.5.3.3.2 Remedial Action - Area C
No additional remediation has been conducted since the third FYR in Area C. Figure 4-7 shows
the prior remedial actions completed in Area C (Hart Crowser 2013b).
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
4.5.3.3.3 Post-Construction Monitoring/O&M - Areas A and B
Long-term monitoring in Middle Waterway Areas A and B is being conducted in accordance
with the Final Revised Operations, Monitoring, and Maintenance Plan - Areas A and B (Anchor
2005). The Year 0 monitoring occurred in two phases, in 2004 (Phase I) and 2005 (Phase II).
Although the Year 0 monitoring occurred over 2 years, EPA and MWAC agreed that the Year 3
monitoring would occur in one phase in 2007. Per the requirement of EPA, Year 4 monitoring
activities were conducted in 2008. The purpose of the Year 4 monitoring was to further evaluate
surface sediment mercury concentrations within the areas treated with ENR, with Dredged with
ENR, and with natural recovery (NR), and to perform the same analyses as those conducted in
Year 3. The results of Year 3 and Year 4 were combined into one report. A summary of these
previous years of sampling is available in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
Year 5 monitoring was conducted in the summer of 2009, and Year 8 monitoring was conducted
in July 2012. Monitoring activities are discussed immediately below. Data review and
evaluation is discussed in Section 4.5.5.4. Based on results of Year 5 monitoring efforts, EPA
and MWAC determined that an ARA was necessary to address increasing mercury
concentrations in sediment in the NR area of Area A (as described above). Figure 4-8 shows the
location of surface sediment samples and dive transects for Year 8 (2012) sampling events.
Monitoring of Areas A and B -Year 5 (2009)
Surface Sediment Chemical Monitoring
Sediment samples were collected in areas identified as ENR, Dredged with ENR, and natural
recovery remedies.
ENR and Dredged with ENR Monitoring
Year 5 monitoring activities were performed in areas with ENR (SMUs 8, 10, and 11) and
Dredged with ENR remedies (Dredge Areas D-l, D-3, D-4 and portions of D-5 and D-6) to
confirm that the RA work is achieving performance standards specified in the ROD. As part of
Year 5 monitoring activities, surface sediment grabs were collected in June 2009 and submitted
to the laboratory for chemical analysis of the COCs. Results from this sampling effort are
provided in Section 4.5.5.
Natural Recovery Monitoring
Monitoring was performed in the NR areas, including SMUs 4c and 25, to confirm that the RA
work is achieving performance standards specified in the ROD. In June 2009, a composite
intertidal sample (0-10 cm) was collected by hand from the base of the slope representing the
MWW-316 sample location (see Figure 4-3), and the sample was analyzed for COCs. A subtidal
surface sediment discrete sample (0-10 cm) was also collected by boat, and the sample was
analyzed for COCs. Results of the surface sediment chemistry analyses for this area are
discussed in Section 4.5.5.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Visual Observations
Visual inspections were performed in ENR areas with surficial sediment cap monitoring and in
dredged areas with backfill.
ENR with Surficial Cap Monitoring
Monitoring during Year 5 was performed in SMU 5a to confirm that the RA work is achieving
performance standards specified in the ROD. The monitoring objective was achieved by
conducting a visual inspection at low tide to assess the coverage of surficial cap material. Visual
observations were collected on June 22, 2009, and the tidal elevation was between approximately
-2.5 feet and -3.7 feet.
The inspection confirmed that surficial cap material was present in all areas, and no areas of
concern were identified. Based on the visual survey and associated photographs from Year 5 and
the previous monitoring events, the ENR with surficial cap remedy is achieving performance
standards and no additional visual monitoring activities are recommended.
Dredged Areas with Backfill Monitoring
Monitoring was performed in Dredge Area D-2 to confirm that the RA work is achieving
performance standards specified in the ROD. The monitoring objective was achieved by
conducting a visual survey of the dredged areas with backfill to confirm the presence of the 2-
inch layer of backfill material. Two locations (MWW-308 and MWW-309) were selected for the
visual survey.
Based on the presence of habitat mix material on the surface of the area identified during Year 5
and previous monitoring events, the dredged areas with backfill remedy has achieved
performance standards and is expected to continue to achieve performance standards.
Hydrographic/land Surveys and Visual Dive Inspections for Thick-Layer Caps
Hydrographic/land surveys and visual dive inspections were conducted for the thick-layer cap
areas. Monitoring was performed during Year 5 in the thick-layer cap areas (Dredge Areas D-l
[east slope], portions of D-6, D-9, the Marine Railway, and Area B [SMU 53]) to confirm that
RA work is achieving performance standards specified in the ROD. Monitoring activities that
were implemented to achieve the monitoring objective included bathymetric/topographic surveys
of the thick-layer cap areas, as well as dive/visual surveys with video or pictures of each thick-
layer cap area.
In areas that had a silt layer depth greater than 2 cm that was covering the cap material, surface
samples were collected using hand cores. Samples were analyzed for metals, PAHs, grain size,
TOC, and total solids. Results from the samples are discussed in Section 4.5.5.
Bathymetric surveys conducted in the thick-layer cap areas in 2009 were compared to results
from Year 3 (2007) monitoring results, and results indicate that the cap material is stable.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Monitoring of Areas A and B -Year 8 (2012)
Surface Sediment Chemical Monitoring
Samples were collected in areas identified as ENR and Dredged with ENR. Year 8 monitoring
activities were performed in areas with ENR (SMUs 8, 10 and 11) and Dredged with ENR
remedies (Dredge Areas D-l, D-3, and D-4, and portions of D-5 and D-6) to confirm that the RA
work is achieving performance standards specified in the ROD. The monitoring objectives for
Year 8 were achieved through sediment chemistry testing on surface material collected at various
locations within ENR and Dredged with ENR areas.
As part of Year 8 monitoring activities, surface sediment grabs were collected in July and August
2012 and submitted to the laboratory for chemical analysis of the COCs to provide information
about surface sediment chemistry. Results for Year 8 monitoring are discussed in Section 4.5.5.
Visual Observations
Visual inspections were performed in ENR areas with surficial cap monitoring and in dredged
areas with backfill.
ENR with Surficial Cap Monitoring
Monitoring during Year 8 was performed in SMU 5a to confirm that the RA work is achieving
performance standards specified in the ROD. The monitoring objective was achieved by
conducting a visual inspection at low tide to assess the coverage of surficial cap material. Visual
observations were collected on July 31, 2012, and the tidal elevation was between approximately
-1.3 feet and -2.2 feet.
The inspection confirmed that surficial cap material was present in all areas, and no areas of
concern were identified. Based on the visual survey and associated photographs from Year 8 and
the previous monitoring events, the ENR with surficial cap remedy is achieving performance
standards, and no additional visual monitoring activities are recommended.
Dredged Areas with Backfill Monitoring
Monitoring was performed in Dredge Area D-2 to confirm that the RA work is achieving
performance standards specified in the ROD. The monitoring objective was achieved by
conducting a visual survey of the dredged areas with backfill to confirm the presence of the 2-
inch layer of backfill material. Two locations (MWW-308 and MWW-309) were selected for the
visual survey.
Based on the presence of habitat mix material on the surface of the area identified during Year 8
and previous monitoring events, the dredged areas with backfill remedy has achieved
performance standards and is expected to continue to achieve performance standards.
Hydrographic/Land Surveys and Visual Dive Inspections for Thick-Layer Caps
Hydrographic/land surveys and visual dive inspections were conducted for the thick-layer cap
areas. Monitoring was performed during Year 8 in the thick-layer cap areas (Dredge Areas D-l
[east slope], portions of D-6, D-9, the Marine Railway, and Area B [SMU 53]) to confirm that
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
RA work is achieving performance standards specified in the ROD. Monitoring activities that
were implemented to achieve the monitoring objective included bathymetric/topographic surveys
of the thick-layer cap areas, as well as dive/visual surveys with video or pictures of each thick-
layer area.
In areas that had a silt layer depth greater than 2 cm that was covering the cap material, surface
samples were collected using hand cores. Samples were analyzed for metals, PAHs, grain size,
TOC, and total solids. Results from the samples are discussed in Section 4.5.5.
Bathymetric surveys conducted in the thick-layer cap areas in 2012 were compared to results
from 2009 surveys. Results indicate that the cap material is stable.
4.5.3.3.4 Post-Construction Monitoring/O&M - Area C
Monitoring activities in Middle Waterway Area C are being conducted in accordance with the
Operations, Monitoring, and Maintenance Plan, Middle Waterway Problem Area C, Sediment
Management Units 51a and 51b, Commencement Bay Nearshore/Tideflats Superfund Site (Hart
Crowser 2006).
In Area C, the remedial action was completed by October 2004. Monitoring was conducted in
2004 for Year 0, in 2005 for Year 1, in 2007 for Year 3, and in 2008 for Year 4. A summary for
these previous years of sampling is in the third FYR (EPA 2009), which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
Monitoring results described in this FYR were conducted in summer 2009 for Year 5, summer
2010 for Year 6, and June 2013 for Year 10. Monitoring activities are discussed below. Data
review and evaluation is discussed in Section 4.5.5.4.
Monitoring of Area C -Year 5 (2009)
Physical Monitoring
Observations were made regarding the overall tideflat condition and sediment characteristics at
long-term monitoring locations as part of the physical assessment of the restored tideflat surface
in SMU 51a and SMU 51b. The visual inspection for Year 5 (2009) was completed on August 18
and 19, 2009, during an approximately -2 foot elevation daytime tide. Survey efforts in Year 5
included a channel location survey of the City Outfall No. 200, a topographic survey of the SMU
51a and SMU 51b tideflat surface, and a baseline channel location/elevation survey of the
northern Mylet stormwater drainage channel. The grade stake survey that had been conducted in
previous years was discontinued for the Year 5 monitoring event following discussions with
DNR and EPA, given the difficulty of maintaining reliable rebar survey stations. Alternatively,
the broader topographic survey provides more representative data on tideflat elevation changes
over a larger area.
No major areas of erosion or adverse backfill and thin-layer cap performance have been noted
since completion of construction in 2004. Overall tideflat capping, restoration, and City Outfall
No. 200 channel stabilization appear to be "self-maintaining" with no additional corrective
actions needed, aside from the recommended replenishment of thin-layer capping material in the
Mylet drainage channels.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Sediment Chemical Monitoring
Year 5 sampling of the backfilled surface of SMU 51a and capped surface of SMU 51b was
conducted in August 2009. The Year 5 sampling grid was the same as for Year 3. In total, 25
discrete samples were collected from the upper 10 cm of the tideflat surface by hand during low-
tide periods for the Year 5 event. Sampling also included three blind field duplicates of SMU
51a Grid G sample, SMU 51b Grid P sample, and sediment from crab and other invertebrate
burrows to assess the potential effect of bioturbation from SMU 51b Grid O (O-Crab-2009 and
O-Burrow-2009) and Grid P (P-Burrow-2009).
Sediment sample testing data to date indicate that the backfill and cap components of the remedy
are performing as intended. Results from Year 5 monitoring are discussed in Section 4.5.5.
Figure 4-9 (for SMU 51a) and Figure 4-10 (for SMU 51b) show the locations of samples and
SQO exceedances for Year 5 monitoring.
Monitoring of Area C -Year 6 (2010)
Physical Monitoring
The Year 6 monitoring activities were focused on observing the physical condition of the project
area, measuring the tideflat elevation to assess cap integrity, and assessing upland and tideflat
habitat conditions. Additional activities included the repair of the northern Mylet drainage
channel and completion of elevation surveys for the City Outfall No. 200 and northern Mylet
drainage channels.
Overall, the physical characteristics of the remedy in Area C exhibit long-term integrity, with
repair of the downcut area completed on September 8, 2010. The repair work involved placing
one cubic yard of habitat mix in the eroded area of the Mylet channel. The performance of the
repair appeared satisfactory about one month after placement.
Overall, the backfill and thin-layer caps in SMUs 51a and 51b, respectively, have maintained
similar physical features over the past 6 years. The survey results for City Outfall No. 200
showed that there was no significant channel migration, erosion, or change in channel bottom
elevations. Changes in elevation were within 0.1 foot of Year 5 (2009) elevations. Visual
observations indicate that the channel migration is not compromising the integrity of SMU 51a
backfill or downstream portions of the tideflat.
The maximum elevation loss at any point in SMU 51a and SMU 51b was 0.34 foot and the
maximum gain was 0.44 foot. No measurement locations exceeded the threshold of 0.5 foot
elevation loss in SMU 51b thin-layer cap.
Monitoring of Area C - Year 10 (2013)
Physical Monitoring
Observations were made regarding the overall tideflat condition and sediment characteristics at
long-term monitoring locations as part of the physical assessment in Middle Waterway. The
visual inspection for Year 10 was completed on August 29, 2013, during an approximately -2
foot elevation daytime tide. Visual inspections included observations of the physical appearance
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
and integrity of the restored tideflat surface in SMU 51a and SMU 51b. Survey efforts in Year
10 included completion of a topographic survey to evaluate tideflat elevation, grade changes,
channel migration, elevation near the City Outfall No. 200, and included completion of a
topographic survey of the northern Mylet drainage channel.
Overall, the physical characteristics of the remedy in Middle Waterway Area C exhibit long-term
integrity, as demonstrated from 10 years of post-construction monitoring. The backfill and thin-
layer caps in SMUs 51a and 51b, respectively, have maintained similar physical features over the
past 10 years. The only exception to this finding is localized erosion observed along the northern
and central Mylet runoff drainage channels in SMU 51b sampling Grids O and P. This minor
downcutting has locally affected the conditions on the thin layer cap, but does not appear to
threaten overall performance. Following repairs to the northern Mylet drainage channel in 2010,
an elevation survey conducted in 2013 showed no evidence of additional downcutting.
The topographic survey results concluded that there has been no significant channel migration
erosion or change in the channel bottom elevations of City Outfall No. 200. The elevation
survey concluded that one location in Grid O had an elevation loss of 0.51 foot and in Grid L an
elevation loss of 0.99 foot. These two locations exceeded the early warning trigger of a 0.5-foot
elevation loss on the SMU 51b thin-layer cap, but no locations exceeded the performance
standard of greater than 1.0 elevation loss. A location and elevation survey of Mylet channel in
Year 10 showed that the habitat mix remained on the channel floor at the area that had
previously had the greatest downcutting.
Sediment Chemical Monitoring
Year 10 sampling of the backfilled surface of SMU 51a and capped surface of SMU 51b was
conducted in April 2013. The Year 10 sampling grid was the same as for Years 3 and 5. In total,
20 discrete samples were collected from the upper 10 cm of the tideflat surface by hand during
low-tide periods for the Year 10 event. Sampling also included two blind field duplicates of
SMU 51a Grid CD sample and SMU 51b Grid O sample. One burrow sample (O-Crab-2013)
was collected as a composite of excavated sediment material at the site of burrows located along
the northern Mylet channel, in Grid P.
Sediment sample testing data to date indicate that the backfill and cap components of the remedy
are performing as intended. As a result of elevated concentrations in the burrow sample, habitat
mix and quarry spall was placed in the northern Mylet drainage channel to reduce potential
transport of contaminated sediment caused by erosion and bioturbation. Results from Year 10
monitoring are discussed in Section 4.5.5. Figure 4-11 (for SMU 51a) and Figure 4-12 (for SMU
51b) show the locations of samples and SQO exceedances for Year 10 monitoring.
4.5.4. Progress since the Last Five-Year Review
Results from the OMMP activities are discussed in the previous Section 4.5.3, Post-Construction
Monitoring/O&M.
4.5.4.1 Previous Protectiveness Statement
The protectiveness statement in the third FYR (2009) stated:
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
"The remedial action in Middle Waterway has been completed, the remedy is
currently protective of human health and the environment, and exposure pathways
that could result in unacceptable risks are being controlled. In order for the
remedy to remain protective in the long-term, the Sediment Quality Objectives
need to be met according to the timeframes established in the Middle Waterway
ESDs, or any exceedances need to be shown to be biologically insignificant in all
ENR and natural recovery areas, and ICs must be fully implemented."
4.5.4.1.1 Status of Recommendations
Table 4-2 below presents the issues and recommendations made for the Middle Waterway in the
third FYR and provides a progress evaluation.
Table 4-2. Recommendations for Middle Waterway from the Third FYR and Progress
Issue
Rcco mmc ndat ions/Fol low-up
Actions
Progress
Year of
Completion
Possible recontamination of
surface sediments due to
erosion and large burrowing
organisms bringing the
underlying, native sediments
to the surface in Area C.
Drainage from the Mylet
property down-cutting such
that the underlying tideflat
and wood debris are exposed
in Area C.
Chemical monitoring of burrows
within drainage channels or
other erosion features should be
included in future monitoring
events. Evaluate options to
prevent further erosion.
Chemical monitoring of
invertebrate burrows was
completed in 2009 and 2013.
Composite samples were
collected in Grids 0 and P and in
the Central and Northern Mylet
Drainage channels. The results
are documented in the DNR Year
5 (2009) monitoring report,
Section 3.1 (Hart Crowser 2010)
and Year 10 (2013) monitoring
report, Section 3.2 and Section
5.1 (Hart Crowser 2013b).
2013
Ineffectiveness of grade stake
survey due to stakes missing
during survey monitoring in
Area C.
Replace with periodic
topographic surveys to map the
long-term effects of the outfall
on the tideflat and remedy
performance.
Completed and documented in
the DNR Year 10(2013)
monitoring report, Section 2.2.4
(Hart Crowser 2013b).
2013
SQO exceedances for
mercury in Areas A and B in
NR areas where SQOs are
expected to be met within a
ten year timeframe.
Continue monitoring and
evaluate Year 5 data to evaluate
potential causes of SQO
exceedances in Areas A and B.
ARA was completed in February
2013 to address mercury
exceedances. See Section4.5.3
for additional information.
2013
SQO exceedance of bis (2-
ethylhexyl) phthalate, with
elevated (but below SQO)
concentrations of mercury
and PAH found in Area C
sediments near the Mylet roof
drain.
Include chemical monitoring of
burrows within drainage
channels or other erosion
features in future monitoring
events. Evaluate options to
prevent further erosion.
Monitoring was completed and
documented in DNR Year 10
(2013) monitoring report (Hart
Crowser 2013b), and
supplemental work to prevent
erosion and biotuibation was also
completed in summer 2013.
2013
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Table 4-2. Recommendations for Middle Waterway from the Third FYR and Progress
(continued)
Issue
Recommendations/Follow-up
Actions
Progress
Year of
Completion
Beached logs have been a
problem primarily for the
recovering pickleweed and
other vegetation at the upper
tidal levels at the head of the
waterway due to smothering
or sediment gouging.
Develop a Memorandum of
Understanding (MOU) with
Simpson. Also evaluate the
possibility of installing a
breakwater to replace the
protective function of the former
piling field.
No actions have been
implemented. DNR attempted to
work with Simpson but Simpson
determined the logs are not their
responsibility. In the past few
years, DNR noted that the impact
of the logs is less severe, and
DNR does not intend to pursue
the MOU at this time.
Agencies
now agree
that beached
logs are not
a CERCLA
issue.
Institutional controls have not
been fully implemented.
Conduct an IC study; follow up
with the USCG about status of
final regulated navigation area
(RNA); verify that easements
have been executed and
recorded with Pierce County.
The Coast Guard was provided
accurate coordinates in 2014 and
is in the process of establishing an
RNA in which certain activities
that could damage the cap will be
prohibited. An IC study has not
been completed and it has not
been documented that easements
and/or environmental covenants
have been executed and entered
into Ecology's UECA registry in
the ISIS database and the City of
Tacoma govMe database.
Ongoing.
Year 5 monitoring results
from summer of 2009 have
not been included in this
review and need to be
evaluated to further assess
status of sediments in the
waterway.
Evaluate Year 5 data; discuss
options and potential need for
additional remedial action.
Based on evaluation of the Year 5
monitoring results, an ARA was
completed in Area A. Results
are discussed in Section 4.5.5.
No farther action is needed.
2013
4.5.5. Five-Year Review Process
4.5.5.1 Administrative Components
The Middle Waterway FYR team was led by Nancy Harney, the EPA RPM, Region 10. Karah
Haskins (physical scientist) with the USACE, Seattle District, assisted with the review as a
representative of the support agency.
By December 2013, the review team had been formed and the review schedule had been
established for the following activities:
• Document collection and review;
• Data assessment and analysis;
• Interviews and community notification and involvement; and
• FYR report development and review.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
The FYR has a statutory completion date of December 23, 2014.
4.5.5.2 Community Involvement
On January 17, 2014, a display advertisement ran in the Tacoma News Tribune newspaper
providing notification and contact information for the FYR. In addition, on January 21, 2014,
EPA Community Relations staff sent postcards to stakeholders and neighbors included on the
CB/NT project mailing list (approximately 1,150 addressees), providing notification about the
five-year review process. Both notifications requested that any information that people would
like EPA to consider during the review be provided to EPA before April 15, 2014.
On February 19, 2014, Kevin Rochlin, Bill Ryan, and Jonathan Williams (all with EPA Region
10) met with Bill Andersen, the Executive Director of Citizens for a Healthy Bay (CHB), at
which time EPA provided information on CB/NT activities and preparation of the fourth FYR. A
telephone interview was completed with CHB.
No input was received from the public for the overall CB/NT site Sediment OU or for the Middle
Waterway.
4.5.5.3 Document Review
A review of reports pertinent to this FYR was conducted by the review team. The types of
documents reviewed included decision documents, risk assessment documents, annual data
reports, technical memoranda, and other supporting materials. OU 01 Attachment 1 is a
complete list of documents reviewed during this FYR.
An institutional control study has not been performed to date. A regulated navigation area (RNA)
request was prepared for the thick-layer sediment cap areas in Middle Waterway and submitted
to the USCG in the spring of 2005. The RNA will prohibit activities such as anchoring, dragging,
trawling, or other activities that involve disrupting the function of the thick-layer caps. The
USCG issued a Notice of Proposed Rulemaking for the Establishment of an RNA for the Middle
Waterway cap areas. Final rule making had been delayed due to issues regarding the coordinates
for the RNA. In January 2014, the coordinate issue was resolved and MWAC submitted updated
coordinates to the Coast Guard. In February 2014, the Coast Guard indicated that the
coordinates now match, and that they will move ahead with the notice of proposed rulemaking to
establish the RNA.
4.5.5.4 Data Review and Evaluation
4.5.5.4.1 Middle Waterway Areas A andB
Results for Areas A and B - Year 5 (2009)
Results from Year 5 (2009) surface sediment sampling in the ENR areas and the Dredged with
ENR areas are summarized below:
• One mercury exceedance (1.27 times the SQO) was observed at station MWW-324
(Dredged with ENR area).
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
• One exceedance of lead (1.60 times the SQO) was observed at station MWW-320
(Dredged with ENR area).
According to the Final Year 5 Monitoring Report (Anchor QEA 2011), the mercury
concentrations in surface sediments were consistent with or below concentrations that were
previously determined not to warrant cleanup action due to lack of biological impacts identified
during bioassay testing in Area B. In the ENR and Dredged with ENR areas, average mercury
concentrations in sediments for Years 3, 4, and 5 were well below the mercury SQO of 0.59
mg/kg. These findings support the assertion that the post-RA mercury concentrations within
these areas are equilibrating with the surrounding sediment concentrations and that there is no
increasing trend. The lead exceedance at Station MWW-320 was an isolated exceedance, and
there was no trend from the previous sampling activities to indicate an increasing concentration
of lead in this location.
Results from Year 5 of monitoring in the NR areas are summarized below:
• The results from the composite intertidal sample collected from the base of the slope from
the top 10 cm representing the MWW-316 sample location detected a mercury exceedance
(1.86 times the SQO). This result was unchanged from Year 4 monitoring.
• A subtidal surface sediment discrete sample (MWW-315) was collected by boat. Results
for the analyses for this area indicated exceedance of mercury and zinc (12.7 and 1.78
times the SQO, respectively). This mercury concentration is greater than the
concentrations identified in Area B that passed biological testing during the pre-RA
sediment investigation (Anchor 2001).
Results from Year 5 monitoring in the thick-layer cap areas are summarized below:
• Samples MWW-507 and 508 collected within the Marine Railway area indicated mercury
exceedances (2.7 and 1.05 times the SQO, respectively). A low-level copper exceedance
(1.2 times the SQO) was also observed at MWW-508.
• A mercury exceedance was detected in sample MWW-503 (1.05 times the SQO) within
Area D-6 underneath the dry dock.
• In area D-9 there was a minor exceedance of phenanthrene (1.2 times the SQO) at station
MWW-502.
Similar to the mercury exceedances in the ENR and Dredged with ENR remedy areas, the
mercury concentrations identified in these samples are consistent with or below concentrations
that have been previously determined not to warrant cleanup action due to lack of biological
impacts identified during bioassay testing in Area B.
Results for Areas A and B - Year 8 (2012)
Results from Year 8 (2012) surface sediment sampling in ENR and Dredged with ENR areas (no
monitoring of NR areas occurred during Year 8 because of planned ARA) are summarized
below:
• Three minor exceedances of the mercury SQO (between 1.05 and 1.1 times the SQO) were
observed at stations MWW-313, MWW-320 and MWW-322, all within the Dredged with
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
ENR area.
• No SQO exceedances of any other analytes were observed.
According to the Year 8 Monitoring Report, the mercury concentrations are consistent with or
below concentrations that have been previously determined not to warrant cleanup action due to
the lack of biological impacts identified during bioassay testing in Area B. Average mercury
concentrations within Dredged with ENR and ENR areas for Years 3, 4, 5, and 8 were well
below the mercury SQO of 0.59 mg/kg. Average Year 8 mercury concentrations of 0.332 mg/kg
within the Dredged with ENR and ENR areas remained consistent among those reported for
Years 3, 4 and 5 (0.342, 0.249, and 0.276 mg/kg mercury, respectively).
Results from Year 8 (2012) surface sediment sampling from the thick-layer cap area are
summarized below:
• One mercury exceedance (3.2 times the SQO) was observed at station MWW-803 in the
thick-layer cap area of Marine Railway.
• One low-level copper exceedance (1.26 times the SQO) was observed at station MWW-
803 in the thick-layer cap area of Marine Railway.
Similar to the mercury exceedances in the ENR and Dredged with ENR remedy areas, the
mercury concentrations identified in these samples are consistent with or below concentrations
that have been previously determined not to warrant cleanup action due to the lack of biological
impacts identified during bioassay testing in Area B. A similar exceedance of the copper SQO
within material that had accumulated on top of the thick-layer cap in the Marine Railway was
observed during the Year 5 monitoring event. Overall, copper concentrations in the waterway are
approximately 78 percent less than the concentrations that existed before the RA. Table 4-3
summarizes the post-remediation chemical exceedances in sediments for Areas A and B for 2007
through 2012.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Table 4-3. Areas A and B Post-Remediation Chemical Exceedances for 2007 through 2012
Chemical
Unit
SQOl
No. Results
Min
Max
Average
No. of
Exceedances"
Min EF3
Max EF
Year 3 (2007)
Lead
mg/kg
450
25
5.2
530
70.3
1
1.18
1.18
Mercury
mg/kg
0.59
25
0.013
0.9
0.386
5
1.07
1.53
Benzo(a)anthracene
mg/kg
1600
25
3
1700
133
1
1.06
1.06
Benzo(g,h,i)perylene
mg/kg
720
25
2.3
1100
79.4
1
1.53
1.53
Fluoranthene
mg/kg
2500
25
6.8
3800
297
1
1.52
1.52
Year 4 (2008)
Mercury
mg/kg
0.59
21
0.034
3.6
0.45
2
1.86
6.1
Year 5 (2009)
Copper
mg/kg
390
29
18
480
130
1
1.23
1.23
Lead
mg/kg
450
29
4.4
720
65.2
1
1.6
1.6
Mercury
mg/kg
0.59
29
0.019
7.5
0.62
6
1.05
12.7
Zinc
mg/kg
410
29
23
730
119
1
1.78
1.78
Phenanthrene
mg/kg
1500
29
2
1800
178
1
1.2
1.2
Year 8 (2012)
Copper
mg/kg
390
25
20
490
104
1
1.26
1.26
Mercury
mg/kg
0.59
25
0.052
1.9
0.394
4
1.05
3.22
1. SQO= Commencement Bay Sediment Quality Objectives
2. Exceedance= Result greater than SQO
3. EF= Exceedance Factor= Chemical Concentration/SQO
4.5.5.4.2 Middle Waterway - Area C
Results for Area C - Year 5 (2009)
Monitoring concluded that there was one SQO exceedance and three exceedances of early
warning triggers13 (one of these exceedances was in a field duplicate) in the Year 5 surface
sediment samples.
• B-2-M-2009, benzyl alcohol exceeded the SQO. Also in sample B-2-M-2009, BEHP
exceeded its early warning trigger.
• O-CRAB-COMP-2009 and field duplicate OD-CRAB-COMP-2009, composite samples
collected from invertebrate burrow mounds along the Mylet central drainage channel, had
mercury concentrations that exceeded the early warning trigger. The latter sample was
composited from the excavated mound material at the burrow site.
Results for Area C - Year 6 (2010)
No surface sediment sampling occurred. Only visual monitoring was performed.
13 An early warning trigger occurred when the detected concentration exceeded one-half of the respective SQO.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Results for Area C - Year 10 (2013)
Monitoring concluded that there were two SQO exceedances and eleven exceedances of early
warning triggers in the Year 10 surface sediment samples. The exceedances were observed in
four samples:
• A-2-M-2013: Benzyl alcohol exceeded the SQO. Mercury, BEHP, benzoic acid, and
phenol exceeded their early warning triggers.
• AB-M-2013: Nickel exceeded the early warning trigger.
• B-2-M-2013: BEHP and benzyl alcohol exceeded the early warning triggers.
• O-Crab-2013: The analyte 2,4-dimethylphenol exceeded the SQO. Mercury, naphthalene,
phenanthrene, and total low molecular weight PAHs (LPAHs) exceeded their early
warning triggers. This sample was composited from the invertebrate burrow mound
material along the northern Mylet channel walls in Grid P.
Table 4-4 summarizes the post-remediation chemical exceedances in sediments for Area C for
2007 through 2013.
Table 4-4. Area C Post-Remediation (Sediment SQO
Cxceedances Only)
Chemical
Unit
SQOl
Max
No. of
E.\cccdanccs2
Max EF3
Year 3 (2007)
Bis(2-ethylexyl)phthalate
lig/kg
1300
1400
1
1.08
Year 5 (2009)
Benzyl alcohol
lig/kg
73
140
1
1.92
Year 10 (2013)
Benzyl alcohol
lig/kg
73
150
1
2.05
2,4-Dimethylphenol
lig/kg
29
42
1
1.45
1. SQO = Commencement Bay Sediment Quality Objectives
2. Exceedance = Result greater than SQO
3. EF = Exceedance Factor = Chemical Concentration/SQO
4.5.5.4.3 Interviews
An interview was performed by telephone with Citizens for a Healthy Bay for the overall CB/NT
site. No comments were provided.
4.5.6. Technical Assessment
Question A: Is the remedy functioning as intended by the decision documents?
Answer: Yes.
The current remedy for the Middle Waterway is functioning as intended by the ROD. The
current state of each ROD cleanup objective and any indicators of remedy problems are
described below:
• Sediment Quality Goal: the sediment quality goal is a conceptual target condition
for Puget Sound defined by element P-2 of the 1989 Puget Sound Water Quality
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Management (PSWQA) Plan as the absence of acute or chronic adverse effects on
biological resources or significant human health risk.
Overall, the sediment concentrations have decreased since pre-remedial action.
Quantitative data has not been collected to show an absence of acute or chronic adverse
effects on biological resources or significant human health risk. In Areas A and B,
surficial ENR material has remained in the general area in which it was placed, and the
remedy is performing as designed. In Area C, there are finely structured, hair-like algae
and various ulvoid algal species that have formed an almost continuous cover over the
tideflat. These algal mats tend to trap fine silts and provide substrate for other plants and
invertebrates.
• Sediment Quality Objective: the sediment quality objective is a discrete and
measurable target for project cleanup related to the Puget Sound goal. The
objective is measurable in terms of specific human health risk assessments and
environmental effects tests, and associated interpretive guidelines. The resulting
biological effect levels or chemical concentrations are scientifically acceptable
definitions of the sediment quality goal using available information.
Sediment Quality Objectives were generally met throughout the site immediately
following the remedial action. As stated in the ROD, the results of the risk assessments
during the remedial investigation were used in the FS to develop sediment cleanup
guidelines to protect human health and the environment.
To date, in Areas A and B, there are still some mercury concentrations that exceed the
SQO. The mercury concentrations identified in these samples are consistent with or
below concentrations that have been previously determined not to warrant cleanup action
due to the lack of biological impacts identified during bioassay testing in Area B.
In Area C, drainage from the Mylet property has caused two channels to form in the thin-
layer cap (enhanced natural recovery area). Following repairs to the northern Mylet
drainage channel in 2010, an elevation survey conducted in 2013 showed no evidence of
additional downcutting. Bioturbation (invertebrate burrowing) was noted in the Mylet
drainage channel and chemical monitoring results show an SQO exceedance of 2,4-
dimethylphenol in sample O-Crab-2013 collected from the northern Mylet drainage
channel. Also in Area C is the City Outfall No. 200 channel, which could potentially be
affecting concentrations in this area. There is no indication that the detections in this area
are related to the performance of the SMU 51a backfill, or the restored outfall channel.
To date, sediment concentrations remain below the SQO, with the exception of benzyl
alcohol and 2,4-dimethylphenol.
• Sediment Remedial Action Level (SRAL): the sediment remedial action level
differentiates areas that exceed the sediment quality objective, but are predicted to
recover naturally, from those that are more significantly contaminated and
therefore require active remediation to achieve the SQO. The intent of any active
remediation of sediments is to achieve a net environmental and public health
benefit, and therefore requires consideration of habitat issues.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
The SRAL is used to evaluate natural recovery areas. In Areas A and B there were two
sample locations (MWW-315 [subtidal discrete] and MWW-316 [intertidal composite])
that showed mercury exceedances in Year 5 (2009). Sample results from these locations
were similar compared to the previous year's mercury results, which were greater than
the concentrations identified in Area B that passed biological testing during the pre-RA
sediment investigations. An ARA was completed to address the mercury concentrations,
and sampling of this area will be conducted in summer 2014.
• Source Control Level: the goals and objectives of source control are defined as
targets that will achieve respective sediment goals and objectives. Source control
will be implemented according to ARARs and All Known, Available, and
Reasonable Treatment (AKART) Systems. Compliance with the sediment quality
objective will be confirmed through monitoring.
Data indicate that there may be source control issues in Middle Waterway. In Area A
and B, the elevated mercury concentrations in the ENR areas could be attributed to site
activities not yet identified such as prop wash, dry dock activities, and releases permitted
under the National Pollutant Discharge Elimination System (NPDES). There is also the
possibility that increases in mercury concentrations compared to Year 0 may be attributed
to the natural redistribution of sediments that had concentrations that were above the
SQO. Although exceedances were observed, the concentrations are generally below the
levels found to have impacts from biological testing conducted during pre-remedial
design. Ongoing evaluation is required to determine the impacts of this recontamination
and the need to address it.
There is no site-specific habitat mitigation objective outlined in the ROD. Habitat function and
enhancement of fisheries resources are incorporated as part of the overall project cleanup
objective. Habitat mitigation objectives and goals are site-specific and were developed for the
site prior to construction. Generally, the mitigation sites are performing in accordance with the
project goals.
Institutional controls are related to the long-term integrity of the thick-layer cap areas. A
regulated navigation area (RNA) request has been prepared for the thick-layer cap areas and was
submitted to the USCG in the spring of 2005. In January 2014, discrepancies were resolved, and
the Coast Guard is moving forward with establishing the RNA. Within the RNA, activities such
as anchoring, dragging, trawling, or other activities that could disrupt the function of the thick-
layer caps will be prohibited. An Institutional Control Implementation Plan should be prepared
by the Respondents to ensure that all required institutional controls are in place, and that
environmental covenants have been prepared for areas with capped remedies. Environmental
covenants should be recorded, and submitted to Ecology for the ISIS database and to the City of
Tacoma for the govMe website.
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy still valid?
Answer: Yes.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Changes in Standards and To Be Considered. See Section 4.2.6 (Question B).
Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics. See
Section 4.2.6 (Question B).
Changes in Land Use. There have been no changes in the physical conditions of the site that
would affect the protectiveness of the remedy.
Remedial Action Objectives. The RAOs from the ROD are still valid and protective for the
site.
Question C: Has any other information come to light that could call into question the
protectiveness of the remedy?
Answer: No.
No other information is known that calls into question the protectiveness of the remedy.
4.5.6.1 Technical Assessment Summary
According to the data reviewed and information obtained from the visual observations, the
remedy is functioning as intended by the ROD, as amended by the ESD, because the remedial
action was successful in significantly decreasing PAH and metals concentrations in Middle
Waterway sediments.
In Areas A and B, exceedances of mercury have been identified during the course of two
monitoring events (Years 5 (2009) and Year 8 (2012) post-construction) in both the Dredged
with ENR area and NR area. To address the mercury concentrations in the NR area from Year 5
monitoring, an ARA was completed in February 2013. During Year 8 monitoring there were
only 4 locations that exceeded the mercury SQO. This change represents considerable
improvement from Year 1, when 45 locations exceeded the SQO. According to the ESD, there is
a 10-year timeframe to meet the overall sediment cleanup objectives, and there is approximately
1 year remaining to determine if the remedy has been successful. In the interim, sediment
concentrations will continue to be monitored, and the need for further remedial action will be
assessed.
In Area C, the SMU 51a backfill and the SMU 51b thin-layer capping are performing as
anticipated. There were two exceedances of SQO levels. One exceedance was near the City
Outfall No. 200 channel and could potentially be due to off-site sources from runoff discharge.
The other location was a composite sample of invertebrate burrow mound material in the
northern Mylet channel walls. Supplemental construction work was completed in summer 2013
to reduce erosion and bioturbation in the northern Mylet drainage channel. Further physical and
chemical monitoring of the northern Mylet channel will determine if bioturbation is transporting
contaminated sediment to the surface.
There have been no promulgated changes in the ARARs, standards or To Be Considered, only
non-promulgated changes to the AET database from which the SQOs were derived. No other
information is known that calls into question the protectiveness of the remedy.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
4.5.7. Issues and Recommendations/Follow-up Actions
No issues or recommendations/follow-up actions were identified during this fourth FYR for
Middle Waterway.
Action items that do not affect protectiveness, but are expected to require future action, are listed
in Table 7-2.
4.5.8. Protectiveness Statement
The protectiveness statement is provided in Section 8.
4.6. Olympic View Resource Area
4.6.1. Background
The Olympic View Resource Area (OVRA) is offshore of the peninsula between the Thea Foss
and Middle Waterways (Figure 4-13). The OVRA site was not identified as a problem area in
the CB/NT ROD, but sediment contamination was identified in 1998. Pursuant to an EPA AOC,
the City performed a non-time-critical removal action to address approximately 3 acres of
contaminated marine sediments at OVRA. EPA's Action Memorandum was signed in July
2001.
The primary COC found in sediments at the OVRA site was dioxins. Sediments contaminated
with certain metals (arsenic, copper, mercury, and zinc), PCBs, and PAHs were more localized
and did not exhibit the broader distribution shown for dioxin-contaminated sediments. The
CB/NT SQOs were used as cleanup standards for OVRA, as well as a site-specific sediment
quality criterion of 20 parts per trillion (ppt) Toxicity Equivalent Quotient (TEQ) dioxins.14 TEQ
is the expression of toxicity based on the overall toxicity of specific congeners of a compound
containing multiple congeners.
4.6.2. Site Chronology
Information for this section is in the third FYR (EPA 2009), which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.6.3. Removal Actions
4.6.3.1 Remedy Selection
Remedy selection for the OVRA non-time-critical removal action is described in Section 4.1.8.
4.6.3.2 Remedy Implementation (Sources)
Information for this section is in the third FYR, which is available online at
http://yosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
14 As set forth in the Action Memorandum for OVRA, the sediment quality criterion of 20 ppt TEQ dioxins will ensure that the
average remaining concentration at the OVRA will not exceed the site-specific background concentration of 7.4 ppt TEQ dioxins.
This SQO and the background approach used to derive it are not necessarily applicable to other Superfund sites or problem areas
identified in the CB/NT ROD.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
4.6.3.3 Removal Action (Sediments)
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
4.6.3.4 Post-Construction Monitoring/Operation and Maintenance
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
All long-term monitoring efforts for the sediment remedy at OVRA have been completed. Since
the third FYR, no long-term monitoring or operation and maintenance activities have been
completed.
4.6.4. Progress since the Last Five-Year Review
Since the third FYR, no long-term monitoring or operation and maintenance activities have been
completed.
4.6.4.1 Previous Protectiveness Statement
The protectiveness statement in the third FYR (2009) stated:
"The remedy at the Olympic View Resource Area is protective of human health and the
environment, and exposure pathways that could result in unacceptable risks are being
controlled."
4.6.4.2 Status of Recommendations
There were no issues or recommendations/follow-up actions made for Olympic View Resource
Area in the third FYR (2009).
4.6.5. Five-Year Review Process
4.6.5.1 Administrative Components
The OVRA FYR team was led by Karen Keeley, EPA RPM, Region 10.
By December 2013, the review team had been formed and the review schedule had been
established for the following activities:
• Document collection and review;
• Data assessment and analysis;
• Site inspection;
• Interviews and community notification and involvement; and
• FYR report development and review.
The FYR has a statutory completion date of December 23, 2014.
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4.6.5.2 Community Involvement
On January 17, 2014, a display advertisement ran in the Tacoma News Tribune newspaper
providing notification and contact information for the FYR. In addition, on January 21, 2014,
EPA Community Relations staff sent postcards to stakeholders and neighbors included on the
CB/NT project mailing list (approximately 1,150 addressees), providing notification about the
FYR process. Both notifications requested that any information that people would like EPA to
consider during the review be provided to EPA before April 15, 2014. A telephone interview
was completed with Citizens for a Healthy Bay.
On February 19, 2014, Kevin Rochlin, Bill Ryan, and Jonathan Williams (all with EPA Region
10) met with Bill Andersen, the Executive Director of Citizens for a Healthy Bay (CHB), at
which time EPA provided information on CB/NT activities and preparation of the fourth FYR.
No input was received from the public for the overall CB/NT site Sediment OU or for the
OVRA.
4.6.5.3 Document Review
For this FYR, there were no long-term monitoring reports for the sediment cleanup project.
With regard to institutional controls, EPA confirmed that the boundaries of the sediment cap at
the OVRA site are accurately documented in the City of Tacoma, Government Made Easy
(govME) website (Figure 4-14).
The City of Tacoma added information about the OVRA site to its govME website
http://wspwit01.ci.tacoma.wa.us/govME/Admin/Inter/StartPage/default.aspx), which allows
users to see locations of cleanup projects in relation to tax parcel numbers, as well as many other
map layers.
Public access, signage, and marker buoys remain in effect at the site. Desiree Pooley (City of
Tacoma) has confirmed that the signage at OVRA is still in place, and that two of three marine
buoys are in place (Pooley, D., personal communication, 8 January 2014, email to Karen Keeley,
EPA). A replacement third buoy was ordered and was installed on February 17, 2014, and new
No Anchor labels were placed on each of the three buoys on the same date. Figure 4-15 shows
the current flyer that is distributed by the City of Tacoma to inform boaters of the Regulated
Navigation Area at the site. Desiree Pooley, City of Tacoma Project Manager, contacted CHB
and City of Tacoma police and fire boats to confirm that parties had adequate flyers for
distribution to boaters.
4.6.5.4 Data Review and Evaluation
No long-term sediment monitoring activities were conducted during the period of this FYR. The
City of Tacoma continues to maintain site access and related institutional controls.
Since the OVRA project was also a restoration project for the Natural Resource Trustees, the
City of Tacoma performs an "Environmental Stewardship Project, Qualitative Ground Survey" at
OVRA during the winter (generally February) and the summer (generally August). These twice-
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yearly surveys include photo documentation of the project area and qualitative observations of
habitat, including plantings and wildlife.
4.6.5.5 Site Inspection
Site inspections by the City of Tacoma have occurred annually. No issues were identified.
4.6.5.6 Interviews
Interviews were performed by telephone with Desiree Pooley, City of Tacoma, for the OVRA.
4.6.6. Technical Assessment
Question A: Is the remedy functioning as intended by the decision documents?
Answer: Yes.
The remedial action is complete, five years of long-term monitoring is complete, and all results
show that performance standards were met. Institutional controls are in place to address all areas
of site-related constituents that are at levels that do not allow for unrestricted use/unrestricted
exposure. Institutional controls are properly implemented and effective in preventing exposure
and protecting the remedy.
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy still valid?
Answer: Yes.
Changes in Standards and To Be Considered. See Section 4.2.6 (Question B).
Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics. The
Action Memorandum described current and future land uses and identified likely exposure
pathways; the descriptions are accurate for the site conditions at the time of this review.
Changes in Land Use. There have been no changes in the physical conditions of the site that
would affect the protectiveness of the remedy.
Remedial Action Objectives. The RAOs from the Action Memorandum are still valid for the
site.
Question C: Has any other information come to light that could call into question the
protectiveness of the remedy?
Answer: No.
No other information is known that calls into question the protectiveness of the remedy.
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4.6.6.1 Technical Assessment Summary
According to the data reviewed and information obtained from the site inspection, the remedy is
functioning as intended by the Action Memorandum. There have been no changes in the
ARARs, standards, or To Be Considered that could affect the protectiveness of the remedy. The
remedy is still protective of human health and the environment. No other information is known
that calls into question the protectiveness of the remedy.
4.6.7. Issues and Recommendations/Follow-up Actions
No issues or recommendations/follow-up actions were identified during this fourth FYR for the
OVRA.
4.6.8. Protectiveness Statement
The protectiveness statement is provided in Section 8.
4.7. Thea Foss and Wheeler-Osgood Waterways
4.7.1. Background
The Thea Foss Waterway is the western-most waterway in Commencement Bay, and is adjacent
to the downtown core of the city of Tacoma. The waterway runs north-south and makes up
about 1.5 miles of downtown shoreline (110 acres) for the City. The Wheeler-Osgood Waterway
is approximately 0.3 miles long, runs east-west, and enters the Thea Foss Waterway
approximately halfway down the east shoreline, just south of the 11th Avenue Bridge and north
of J.M. Martinac Shipbuilding. See Figure 4-16 for waterway locations. The land use along the
waterways was primarily industrial from the early 1890s until the 1980s.
In the past 25 years, the City of Tacoma and other entities have worked to enhance public access
and create green spaces along the Thea Foss Waterway. A significant urban renewal project is
underway along the waterway. Marinas have been upgraded and new development has occurred,
such as the Tacoma Glass Museum, a renovated Albers Mill, and Thea's Landing
condominiums. Active commercial businesses remain along the waterway such as marinas, J.M.
Martinac, and Johnny's Restaurant and Johnny's Seafood. The majority of the submerged lands
of the Thea Foss Waterway are state-owned aquatic lands, managed by DNR. The Wheeler-
Osgood Waterway is privately owned.
Contaminants found at elevated levels in the Thea Foss and Wheeler-Osgood Waterways include
zinc, lead, mercury, cadmium, copper, nickel, PAHs, 2-methylphenol, 4-methylphenol, BEHP,
BBP, and PCBs. In addition to these contaminants, non-aqueous phase liquid (NAPL) seeps
have been found at the head of the Thea Foss Waterway. Two responsible parties are
implementing the remedy: the Utilities party is responsible for cleaning up the head of the Thea
Foss waterway, and the City is responsible for the remaining areas.
4.7.2. Site Chronology
Information through 2009 is in the third FYR (EPA 2009), which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
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Key activities for the waterways since 2009 are presented below:
October 2009-2013 Annual Qualitative Ground Surveys completed (both
City and Utilities work areas)
November 2009 Additional planting area constructed in Puyallup River
Channel Side Channel Habitat Area
February 2010
December 2010
January 2011
February 2011
October 2011
December 2011
December 2012
December 2012
November 2013
Additional planting area constructed in North Beach
Habitat Area
City's Year 4 Annual Operations, Maintenance, and
Monitoring Plan (OMMP) Report completed
Coast Guard rule establishing regulated navigation area
in Thea Foss Waterway finalized
Technical Memorandum documenting changes to
City's 2006 OMMP
Utilities' Year 7 OMMP Head of Thea Foss Report
completed
Additional planting area constructed in the Middle
Waterway Tideflat Habitat Area
Technical Memorandum documenting changes to
City's 2006 OMMP
Remediation of American Plating property completed
City's Year 7 Annual OMMP Report completed
4.7.3. Remedial Actions
4.7.3.1 Remedy Selection
Remedy selection for the CB/NT Sediments OU 01 is described in Section 4.1.
4.7.3.2 Remedy Implementation (Sources)
Information through 2009 for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
In the course of developing the remedial design for waterway sediments required by the AOC,
the City identified marinas as a source of contamination to waterway sediment for PAHs and
phthalates. The predicted impacts of marinas to sediment were cause for concern because
marinas are an important part of the existing waterway, as well as critical to the City's plans for
downtown redevelopment. The City and the Foss Waterway Development Authority began
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
working with the DNR, Ecology, marina owners, marina operators, and marina clients on ways
to manage and minimize the predicted impacts of marinas on sediments.
The need for additional source control is driven by the need to protect post-remediation sediment
quality in the waterways from urban contaminants conveyed in municipal stormwater and is
evaluated using multiple lines of evidence: long-term outfall monitoring, computer model
predictions, and post-construction sediment quality monitoring. The City continues to evaluate
potential sources of concern for the Thea Foss basin through monitoring of stormwater,
baseflow, and particulate matter in seven outfalls. The City is continuing to evaluate possible
stormwater treatment options. As additional sediment sampling results become available, the
areas and need for further source control measures will be identified.
4.7.3.3 Remedial Action (Sediments)
Information through 2009 for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
For background, remedial action construction was completed in 2006 by the City of Tacoma
under a Consent Decree issued by the EPA. The Utilities are responsible for Remedial Action
(RA) areas 23 and 24, consistent with the Consent Decree, and portions of RAs 19b, 20, and 22,
as described in a confidential agreement with the City of Tacoma. Portions of the waterway
south of a sheet pile wall installed at Station 70+10 are the responsibility of the Utilities.
Construction of the remedy for the Utilities' Work Area was completed in February 2004. See
Figures 4-17a and 4-17b (a two-part figure) for the RA areas.
4.7.3.4 Post-Construction Monitoring/Operation and Maintenance
4.7.3.4.1 City's Area
Following the completion of the City's remedial action activities, the OMMP for the City's work
area was finalized based on as-built conditions. The City's OMMP sampling program includes
the following:
• Performance monitoring of capped, enhanced natural recovery, and natural recovery areas
located within the Thea Foss and Wheeler-Osgood Waterways to evaluate the long-term
effectiveness of the remedial actions and progress toward natural recovery;
• Cap integrity monitoring through low tide inspections and hydrographic surveys to ensure
that the sediment caps remain intact;
• Early warning monitoring of remediated areas within the Thea Foss and Wheel er-Osgood
Waterways to evaluate the potential for recontamination;
• Benthic recolonization monitoring to evaluate the post-construction recovery of benthic
organism communities within the Thea Foss and Wheeler-Osgood Waterways;
• Monitoring of groundwater quality in the vicinity of the St. Paul Confined Disposal
Facility (CDF), to ensure the contaminated dredged sediments are effectively contained in
the disposal facility; and
• Habitat area monitoring to evaluate habitat conditions established within the project area
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and to confirm that mitigation sites are making progress toward providing habitat function
necessary to meet site specific objectives.
Monitoring activities were conducted in 2009, 2010, 2011, 2012 and 2013 (Monitoring Years 3 -
7) during this review period. Surveys were conducted in each of these years, with more
comprehensive monitoring being conducted in Years 4 (2010) and 7 (2013). The Year 7
monitoring results represent the most current and comprehensive characterization of the
condition of the various remedy components within the City's work area, but all years are
reported below.
Monitoring by City -Year 3 (2009)
Operations, maintenance, and monitoring activities were performed during Year 3 throughout the
waterways, at the confined disposal facility (CDF), and at the habitat areas within the Thea Foss
Project site. Monitoring conducted in Year 3 included qualitative habitat ground surveys,
elevation monitoring, juvenile salmonid monitoring, invertebrate monitoring, and water surface
elevation monitoring.
Baseline Confined Disposal Facility monitoring
Ambient surface water samples detected copper and nickel at similar concentrations at all
locations sampled. Groundwater sampling found mercury and PAHs in contaminated sediments
in the CDF. Wells outside the CDF showed no elevated PAHs. The majority of the analytes
showed relatively stable concentrations over time.
Habitat Mitigation Area Monitoring (2009)
The habitat mitigation areas for the project are the North Beach Habitat, Middle Waterway
Tideflat Habitat, Puyallup River Side Channel, and the Hylebos Creek Mitigation site. The Thea
Foss Habitat Enhancement Areas are Johnny's Dock Habitat Enhancement, Head of Thea Foss
Shoreline Habitat, SR 509 Esplanade Riparian Habitat and the Log Step Habitat Enhancement.
Year 3 habitat monitoring activities were initiated on May 5, 2009, and continued intermittently
at the various sites until September 1, 2009. The activities at each area are presented below.
North Beach Habitat
The qualitative ground survey was conducted on June 25, 2009. There were no indications of
animal damage or vandalism. There is no indication of vegetative disease with the exception of
the remnant effects of the willow weevil. Repairs to the goose exclusion grids are needed. There
continues to be minimal success of saltgrass but the pickleweed is spreading in the marsh
restoration area. There is mixed success survival of the riparian plantings. Invasive species need
weed management. Sediment elevation changes averaged +1.2 inches from baseline. Juvenile
salmonids were not observed during the May 6-7, 2009 event, but were observed during the May
27, 2009 event.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Middle Waterway Tideflat Habitat
The qualitative ground survey was conducted on June 25, 2009. There were no indications of
animal damage or vandalism. There is no indication of vegetative disease. The goose exclusion
grids are generally in good condition. Vegetative plantings in the riparian zone are doing well
with high survival rates in the irrigated areas. Invasive species need weed management.
Sediment elevation changes averaged -1.6 inches from baseline. Juvenile salmonids were
observed during both May events.
Puyallup River Side Channel
The qualitative ground survey was conducted on June 24, 2009. There were minimal indications
of animal damage (beaver removing vegetation) or vandalism. There is no indication of
vegetative disease. Vegetative plantings in the riparian zone are doing well. Sediment elevation
changes averaged +3.0 inches from baseline. Juvenile salmonids were not observed during the
May events.
Hylebos Creek Mitigation Site
The qualitative ground survey was conducted on June 24, 2009. There no indications of animal
damage or vandalism. There is minimal indication of vegetative disease (willow leaf galls).
Vegetative plantings in the riparian zone are doing well. Invasive species need weed
management. Sediment elevation changes averaged +0.4 inches from baseline. Juvenile
salmonids were not observed during the May events.
Johnny's Dock Habitat Enhancement
The qualitative ground survey was conducted on June 23, 2009. There no indications of animal
damage or vandalism. There is no indication of vegetative disease. Vegetative plantings in the
marsh zone are doing well with the saltgrass covering approximately 95% of the area.
Head of Thea Foss Shoreline Habitat
The qualitative ground survey was conducted on June 23, 2009. There no indications of
vandalism and minimal geese damage to the planted vegetation. This may be due to the removal
of the goose exclusion grid. There is no indication of vegetative disease. Vegetative plantings in
the marsh zone are doing well with the gumweed spreading to the upper beach area. Invasive
species need weed management.
SR 509 Esplanade Riparian Habitat
The qualitative ground survey was conducted on June 23, 2009. There no indications of
vandalism or animal damage. There is no indication of vegetative disease. Vegetative plantings
in the marsh zone are doing fairly well. Invasive species need weed management.
Log Step Habitat Enhancement
The qualitative ground survey was conducted on June 23, 2009. There no indications of
vandalism or animal damage. There is no indication of vegetative disease even with the removal
of the goose exclusion grid. Vegetative plantings in the marsh zone are doing fairly well.
Invasive species need weeding management.
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Monitoring by City -Year 4 (2010)
Operations, maintenance, and monitoring activities were performed during Year 4 (2010)
throughout the waterways, at the confined disposal facility, and at the habitat areas within the
Thea Foss Project site. Sediment remediation area performance monitoring is conducted to
evaluate the long-term effectiveness of sediment caps, enhanced natural recovery, and natural
recovery remedies implemented by the City of Tacoma. See Figures 4-17a and 4-17b for
locations of RA areas. Monitoring conducted in Year 4 (2010) included the following: low tide
slope cap inspections, subtidal cap hydrographic surveys, sediment quality observations,
sediment profile imaging, CDF performance monitoring, and qualitative ground surveys and
quantitative vegetation surveys in habitat areas.
Low Tide Slope Cap Inspections
In accordance with the OMMP, Year 4 performance monitoring to evaluate the physical integrity
of intertidal slope cap areas consisted of low tide inspections of the slope caps in Remedial Areas
(RA) IB, 3, 8, 14, 19A, 19B, 20, and the Sheen Source Removal Area. No deficiencies were
identified upon inspection of RAs 14, 19A, 19B, 20, and the Sheen Source Removal Area. Three
of the five monitoring intervals within RA IB were observed to have piling present at the surface
of the capped area. Since no SQO exceedances were detected in the slope cap composite sample
collected from RA IB, it was recommended that exposed piling areas continue to be monitored
to determine if the cap is performing as required. There is a small, approximately 6-inch-
diameter hole at the surface of the grout mat in Monitoring Interval RA 3-2. However, this hole
does not appear to be impacting the integrity of the cap or containment of the underlying
contaminated sediments. No deficiencies were identified upon inspection of 15 of 17 monitoring
intervals in RA 8. At the mouth of Outfall 230, erosion and downslope movement of the riprap
material on the slope has occurred. For the erosion and downslope movement observed at the
mouth of Outfall 230 in RA 8-2, a plan for evaluating and potentially repairing this area will be
prepared and submitted to EPA for review in a separate memorandum.
Subtidal Cap Hydrographic Survey
In general, the Year 4 cap surface elevations are within six inches of the baseline surface
elevation and within the allowable accuracy of the survey equipment. A comparison of the Year
4 to the Year 2 survey shows that the elevations in most areas have remained fairly consistent
during the past two years. There are limited locations where the decrease in the cap surface
elevation from baseline to Year 4 is greater than six inches but less than one foot. These
locations are generally small, localized, and non-contiguous. In areas where subsidence of
greater than 6 inches but less than 1 foot are documented, no response action is warranted but
will be resurveyed in Year 7. In areas where subsidence is greater than 1 foot, small in nature,
and non-contiguous, no response action is warranted, but the areas will be resurveyed in year 7.
The two areas where subsidence was greater than 1 foot were RA 8 and RA 9. At Outfall 230 in
the area identified by the hydrographic survey (RA 8), exposed sand and a depression resulting
from loss of cap material was observed at the mouth of the outfall greater than 18 inches. A
composite sediment sample was collected and no SQO exceedances were noted. In RA 9 an area
of decreased cap elevation (cap scour depression) with an associated area of elevated cap area
adjacent to the depression was observed. This area is located immediately adjacent to a marine
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float, where a tug boat was moored at the time of the Year 4 survey. Detected chemical
concentrations did not exceed the SQOs.
Sediment Quality
Detected chemical concentrations did not exceed the SQOs in any of the slope cap samples
collected as part of Year 4 performance monitoring (RAs IB, 3, 8, 14, 19A, 19B, and 20.).
Nickel was detected just below the SQO in sample SC-03-Y4, with an SQO exceedance factor of
0.96. With the exception of some nickel and BEHP concentrations detected near the SQOs in the
slope cap samples, the remaining detected chemical concentrations in the slope cap samples were
substantially less than the SQOs. In accordance with the OMMP, Year 4 performance monitoring
slope cap sample results were compared to the Year 2 slope cap sample results. While there were
no SQO exceedances, nickel concentrations were detected at substantially higher levels in the
Year 4 slope cap samples compared to the Year 2 slope cap samples. During Year 2, silver was
detected at all the slope cap sampling locations but was not detected in any of the Year 4 slope
cap samples. The reason for the nickel and silver differences between Year 2 and Year 4 remain
unclear, but may be due to a change in the analytical method between Year 2 and Year 4. These
metals will continue to be monitored in the slope cap samples collected in Year 7.
A total of 6 of the 11 Year 4 channel sand cap samples (0 to 10 cm) had no SQO exceedances.
Four of the 11 samples had only one SQO exceedance in Year 4, for BEHP (CC-23-Y4, CC-29-
Y4, CC-33-Y4) or nickel (CC-30-Y4), and only one sample had multiple SQO exceedances (CC-
32-Y4). The Year 4 channel sand cap sample concentrations were also generally comparable to
the Year 2 channel sand sample concentrations. In general, concentrations of PAHs and BEHP
appear to be increasing over time at the southern end of the Thea Foss Waterway, a depositional
area within the Thea Foss Waterway. The areas with SQO exceedances will be monitored in
Year 7.
Samples from 8 of the 13 natural recovery stations had no SQO exceedances in Year 4. Three of
the 13 stations had samples with only one SQO exceedance, BEHP, and three stations had
samples with multiple SQO exceedances (samples NR-12-Y4, NR-17-Y4, and NR- 25-Y4). The
Year 4 sample collected from the enhanced natural recovery station, Station 16, had no SQO
exceedances. Two of the three natural recovery / slope rehabilitation stations had samples with
no SQO exceedances. Sample SR-10-Y4 had one exceedance for mercury, just above the SQO.
Additional confirmation and verification sampling performed at Stations 12 and 17 in Year 4
showed that the elevated concentrations and multiple SQO exceedances in samples NR-12-Y4
and NR-17-Y4 were not typical of the sediment quality at or in the vicinity of these stations.
Benzoic acid in the Year 4 early warning samples was detected more frequently and generally at
higher concentrations than in the Year 2 early warning samples. The higher Year 4 benzoic acid
results in the early warning samples were confirmed with the reanalysis of three of the Year 4
early warning samples. Silver concentrations decreased substantially between Year 2 and Year 4
in all of the early warning samples. Five of the 27 stations with early warning samples had Year
4 nickel concentrations that were substantially higher, although still below the SQO, when
compared to the Year 2 early warning concentrations. It should be noted that the increased
concentration of nickel (and benzoic acid) in Year 4 as compared to Year 2 was attributed to a
change in analytical methods, rather than a new source (e.g.,) in the waterway (City of Tacoma
2010).
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Sediment Profile Imaging
The sediments throughout the Thea Foss and Wheeler-Osgood Waterways, as observed from the
sediment profile images, were primarily very fine-grained silts and clays (all stations had a
sediment grain size major mode of >4 phi [phi is a unitless measure]), with eight of the stations
showing a depositional layer of silt to fine sand at the surface, ranging from 3.9 cm to 8.2 cm in
depth. The depth of the apparent redox potential discontinuity (RPD) in the sediment column is
an important time-integrator of dissolved oxygen conditions within sediment porewater. The
depth is related to the supply rate of molecular oxygen by diffusion into the bottom sediments
and the consumption of that oxygen by the sediment and associated microflora. The distribution
of mean RPD depths ranged from a low of 0.0 cm in the highly organic sediments observed at
Station BR-23, to a high of 3.39 cm at Station BR-21 in the dredge to clean area. Over ninety
percent of all images taken as part of Year 4 benthic recolonization monitoring, regardless of
remedial area type, have evidence of Stage 3 infaunal taxa present (Stage 3 is the mature,
equilibrium community of deep-dwelling, head-down deposit feeders), consistent with the results
of the Year 2 survey. Year 4 monitoring of the channel sand cap areas showed locations with the
presence of Stage 1, and Stage 1 and 2 infaunal successional assemblages, including BR-18, BR-
23, BR-31 and BR-33. In Year 2 there were no stations in the study area where photos showed
domination by Stage 1, or mixed Stage 1 and 2 infaunal successional assemblages. It was
concluded that "No further action is warranted at this time based on the results of benthic
recolonization monitoring performed in Year 4."
Confined Disposal Facility Monitoring
The first performance monitoring event at the St. Paul Waterway CDF was conducted June 2-9,
2010. Performance monitoring included surface water and groundwater sampling and analysis as
well as CDF berm and cap inspections. The metals lead, zinc, nickel, and mercury were not
detected in the surface water sample. Copper concentrations were consistent with the baseline
monitoring results. Groundwater metals were not detected for dissolved lead and mercury.
Copper, zinc, nickel were detected within the range of the baseline monitoring concentrations.
All the groundwater PAH detections and concentrations were within the range of those observed
during baseline monitoring. No seeps, sheens, or other indications of contamination were
identified during the berm and cap visual inspections. The maximum observed loss of topsoil at
the containment berm due to erosion was a height of approximately 39 inches and appears
relatively consistent with previous observations. No deficiencies were identified upon inspection
of the offset berm and CDF cap.
Habitat Mitigation Area Monitoring (2010)
The primary function of habitat monitoring is to evaluate the effectiveness of the development of
biological features and physical features at the mitigation and enhancement sites to confirm that
they are on a trajectory to provide habitat function necessary to meet the objectives for each site,
and to confirm that the individual habitat sites have attained and continue to meet their objectives
over time. Qualitative monitoring was performed at both the mitigation and enhancement sites to
document visual observations at the site and to identify any general maintenance concerns, track
site naturalization, and document use of the sites by wildlife. Photo documentation was
performed at both the mitigation and enhancement sites to record habitat site development over
time from specific photo locations.
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North Beach Habitat
The qualitative ground survey confirmed that the site is in fair condition, and becoming more
established. For both the existing riparian area and the salt marsh, there was an increase in
habitat values comparing Year 2 to Year 4 (2010).
Middle Waterway Tideflat Habitat
The qualitative ground survey confirmed that the site was continuing to develop adequately and
the brackish marsh plants were continuing to spread outside of the planted nodes within the
sprinkled area. Based on the analyses performed, the site meets all of the performance criteria for
vegetation establishment.
Puyallup River Side Channel
The qualitative ground survey confirmed that the site was developing adequately and the plants
were becoming better established in the riparian areas relative to the previous year's monitoring.
The site meets the performance criteria for riparian vegetation establishment.
Hylebos Creek Mitigation Site
The qualitative ground survey confirmed that the site was continuing to flourish and the
emergent wetland plants were continuing to spread. Vegetation within the forested wetland area
was doing well. The site meets all of the performance criteria for vegetation establishment. No
obstruction to fish passage was identified in the channel areas.
Johnny's Dock Habitat Enhancement
The qualitative ground survey confirmed that the site is well established and the planted species
were continuing to spread, although the plants are somewhat less lush than they had been in Year
3 (2009).
Head of Thea Foss Shoreline Habitat
The qualitative ground survey confirmed that the site is established and the planted species were
continuing to spread.
SR 509 Esplanade Riparian Habitat
The qualitative ground survey confirmed that the site was generally continuing to establish well,
although it was modified by construction of a park on the adjacent site during the spring and
summer of 2009. Overall, the site appeared to be in fair condition.
Log Step Habitat Enhancement
The qualitative ground survey confirmed that the site is adequately established and the plants
were continuing to thrive.
Additional Project Related Activities (2010)
The City submitted a request to update navigational charts to the National Oceanic and
Atmospheric Administration (NOAA). Per communications with NOAA representatives on
September 1, 2010, the updated navigation charts showing the modified shoreline near the St.
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Paul Waterway are available. According to a December 8, 2010 email from a USCG
representative, the rule (establish a regulated navigation area in the Thea Foss Waterway
prohibiting anchorage and other activities that could disturb the cap) had been published in the
Federal Register and would become effective on January 7, 2011. The City submitted a request
to the United States Coast Guard (USCG) to establish a regulated navigation area (RNA) in the
Thea Foss Waterway prohibiting anchorage and other activities that could disturb the cap. The
rule was finalized on January 7, 2011. Therefore, the City now has the authority to post "No
Anchoring" signs in the capped portions of the waterway, if determined necessary.
Project representatives continued to work with the City's Building and Land Use Services
division to implement procedures to ensure that future development in and adjacent to the Foss
Project areas where remedial actions and habitat mitigation work have been completed, are
undertaken in a manner that protects the remedy and the habitat. Projects in review or
development include: 21st Street Park, Waterway Park, public esplanade, construction of the
Center for Urban Waters, rehabilitation of the Murray Morgan Bridge, development of plans for
a cogeneration facility to be placed on top of the CDF, reconfigure the Commencement Bay
Marine Services marina, and Tacoma metals site remediation.
Under the Unilateral Administrative Order dated September 30, 2002, and the Consent Decree
with EPA dated May 9, 2003, the City is implementing a stormwater monitoring and source
control program for the municipal storm drains entering the Thea Foss and Wheeler-Osgood
Waterways to help provide long-term protection of sediment quality in the waterways. Phthalates
were identified as a contaminant expected to exceed Sediment Quality Objectives (SQO) yet
defied source tracing efforts for the monitoring reported in the City's 2010 annual source control
report. Storm pipes were scrubbed to reduce legacy contaminants found adhering to the walls of
the old pipes. Decreasing chemical concentrations in stormwater discharges into the Thea Foss
Waterway have been noted as a result of the stormwater management program.
Monitoring by City -Year 5 (2011)
Only elevation monitoring, water surface elevation monitoring, and Habitat Mitigation Area
monitoring (qualitative ground surveys of all components) occurred in 2011 (Year 5). See
Figures 4-17a and 4-17b (a two-part figure) for the completed RA areas where monitoring
occurs.
Two areas were re-inspected following recommendations from Year 2 and Year 4 monitoring:
the Outfall 230 slope cap (for erosion) and RA-8 piling area (for exposure). The results of the
Year 4 survey indicated a reoccurrence of the decrease in cap elevation at Outfall 230. It is
currently unknown whether the additional loss of cap material identified was associated with the
winter 2009/2010 storm events and the associated heavier drainage flows, or if the loss occurred
more slowly over time since the Year 2 hydrographic survey. However, slope cap performance
monitoring does not indicate that there is a concern with the slope cap in RA 8 surrounding
Outfall 230 relative to chemical concentrations and compliance, and the slope cap is still
performing as required. During the Year 4 low tide slope cap inspections, seven pilings were
observed in RA-8 (low tide inspection interval 10), with the top of the piling estimated to range
from approximately 0.5 to 3 feet above the mud line. There are no other indications of cap
subsidence in the area, so maintenance actions do not appear warranted. The City returned to the
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
location of these pilings on May 18, 2010, during a daytime low tide and determined that no
maintenance actions were deemed necessary because the areas will continue to be monitored
during routine OMMP events.
Habitat Mitigation Area Monitoring (2011)
Year 5 habitat mitigation area monitoring activities are set forth in the OMMP. The primary
function of habitat monitoring is to evaluate the effectiveness of the development of biological
features and physical features at the mitigation and enhancement sites to confirm that they are on
a trajectory to provide habitat function necessary to meet the objectives for each site, and to
confirm that the individual habitat sites have attained and continue to meet their objectives over
time. Year 5 habitat monitoring activities were initiated on July 1, 2011, and continued
intermittently at the various sites until August 31, 2011. The activities at each area are presented
below.
North Beach Habitat
An additional planting area was constructed by the City in 2010, as authorized by EPA, to
provide additional habitat acreage owed by the City as a result of the remediation construction
project. The qualitative ground survey noted the success of the plantings, but no transects were
required to verify that success is occurring. The island is noted as not having any volunteer
vegetation, and original plantings on the slope along the confined disposal facility berm area are
being lost to erosion. The Year 5 OMMP report (City of Tacoma 2011) stated that "there is a
high survival rate for the new plantings, although some have not survived." Elevation monitoring
showed an average change from the baseline as +3.8 inches.
Middle Waterway Tideflat Habitat
This brackish marsh is supported by supplemental irrigation to dilute the influence of sea water.
The qualitative ground survey was conducted on July 11, 2011. Overall, the site was noted to be
in good condition and was being used by avian species (geese eating grass). Erosion was noted at
two locations and may be the result of a sprinkler malfunction. Elevation monitoring showed an
average change from the baseline as +4.5 inches.
Puyallup River Side Channel
The mitigation area provides off-channel habitat for juvenile salmonids during out-migration.
The qualitative ground survey was conducted on July 11, 2011. Plantings appeared to be growing
well, and the levee had recently been mowed by USACE. Elevation monitoring showed an
average change from the baseline as +4.0 inches.
Hylebos Creek Mitigation Site
This area was created to enhance the riparian/forested wetlands and create aquatic habitat. While
invasive species were removed originally, their presence is still noted in the mitigation area. The
qualitative ground survey was conducted on July 12, 2011. Both the upland forest and forested
wetland portion of the site appear to be doing well, and no required maintenance activities were
noted. Elevation monitoring showed an average change from the baseline as +0.6 inches. Surface
water elevation monitoring was conducted between July 1 and August 31, 2011. There were
2,802 measurements recorded from the water level logger monitoring with an elevation of 2 feet
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
National Geodetic Vertical Datum (NGVD) 29 or higher. This value represents 47% of the time
and meets the performance goal of 30%.
Johnny's Dock Habitat Enhancement
This area is a pocket beach to enhance habitat between commercial establishments. The
qualitative ground survey was conducted on July 13, 2011. The site condition was considered to
be fair and avian species were present. Geese seem to be eating the planted grasses, preventing
complete establishment.
Head of Thea Foss Shoreline Habitat
This area was created to provide aquatic habitat below ordinary high water at the head of the
waterway. The qualitative ground survey was conducted on July 13, 2011. The site appears to be
in good condition with no indication of animal damage to the plantings. Plantings are thriving
and volunteer species are becoming established, increasing habitat value.
SR 509 Esplanade Riparian Habitat
This area was planted in upland vegetation to provide riparian habitat. The qualitative ground
survey was conducted on July 13, 2011. The site plantings are doing well outside the bridge
shadow but have minimal success in the shaded area under the bridge. The sprinkler system was
damaged, potentially due to vandalism.
Log Step Habitat Enhancement
This area consisted of a two-step log transition (where the treated timber pilings and other debris
were removed) and was replanted with saltmarsh grasses. The qualitative ground survey was
conducted on July 13, 2011. The site appeared to be in good condition, although no usage by
wildlife was noted. Volunteer saltmarsh plants are becoming established at the site.
Additional Project-Related Activities (2011)
Institutional Controls
The City submitted a request to the United States Coast Guard (USCG) to establish a regulated
navigation area (RNA) in the Thea Foss Waterway prohibiting anchorage and other activities
that could disturb the cap. The rule was finalized on January 7, 2011. Therefore, the City now
has the authority to post "No Anchoring" signs in the capped portions of the waterway, if
determined necessary.
Project representatives continued to work with the City's Building and Land Use Services
division to implement procedures to ensure that future development, in and adjacent to the Foss
Project areas where remedial actions and habitat mitigation work have been completed, is
undertaken in a manner that protects the remedy and the habitat. Several development plans are
currently under construction or consideration and are being evaluated relative to their potential
impact on the cleanup areas. These proposals include the following: Waterway Park, North
Moorage, Public Esplanade, Seaplane Float, Murray Morgan (11th Street) Bridge, Simpson
cogeneration Facility, Commencement Bay Marine Services, and Tacoma Metals Site
Remediation.
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Stormwater Source Control
The Thea Foss and Wheeler-Osgood Waterways are located in a highly urbanized basin with
residential, commercial, and industrial land uses and transportation corridors. Sources of COCs
continue to exist in the drainage basins and are conveyed to the waterways via stormwater drains
(municipal and private), aerial deposition, marinas, and groundwater seeps. The contaminants
identified as having the greatest potential to affect sediment quality following the cleanup action
include PAHs and phthalates.
The City of Tacoma prepared and submitted the Thea Foss and Wheeler-Osgood Waterways
2010 Source Control and Water Year 2010 Stormwater Monitoring Report in March 2011.
Twenty-six statistically significant time trends (26 out of 49 tests, or slightly greater than 50
percent of the tests) were observed in Tacoma's stormwater monitoring record. All trends were
in the direction of decreasing concentrations. In 2010, City staff performed the following field
activities within the Thea Foss Basin:
• Responded to 212 spills/complaints, including conducting investigations;
• Provided technical assistance on source control and best management practices (BMPs);
• Conducted 996 business and BMP inspections; and
• Continued the Illicit Discharge Detection and Elimination (IDDE) program, which
investigates and removes illicit connections to the stormwater drainage system.
While overall stormwater COC concentration trends are decreasing, analytical data indicate that
there are some areas with higher concentrations of certain contaminants that could benefit from
additional source control efforts. The City believes further improvements in stormwater quality
may be realized in the future through ongoing Phase INPDES permit programs and continued
improvement in source control.
Recontamination in the Head of the Thea Foss Waterway
Sediment sampling and analysis was performed in the Head of the Thea Foss Waterway in
coordination with the Utilities as part of Year 7 (2011) OMMP activities. These activities were
conducted on April 18-20, 2011. Compliance interval (0 to 10 cm) sediment samples were
collected from a total of 18 waterway sample locations and 4 intertidal slope cap locations (the
latter were composited into four samples). The results are summarized below:
• The laboratory reporting limits were above the SQOs in one or more of the waterway
sediment samples for ten SVOCs including dimethyl phthalate, phenol, 2-methylphenol,
2,4-dimethylphenol, pentachlorophenol, benzoic acid, 1,2-dichlorobenzene, 1,4-
dichlorobenzene, 1,2,4-trichlorobenzene, and N-nitrosodiphenylamine, and for two of the
pesticides, including 4,4'- DDE and 4,4'-DDT.
• The detected concentrations of most chemicals were substantially below their SQOs in the
waterway sediment samples. BEHP, benzyl alcohol, benzoic acid, six of the nine
individual high molecular weight polycyclic aromatic hydrocarbons (HPAHs), and total
HPAHs were detected at concentrations greater than their SQOs at more than one sample
location. Phenanthrene, one of the low molecular weight polycyclic aromatic hydrocarbons
(LPAHs), only exceeded its SQO at one sample location (WC-02). Metals, pesticides, and
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
PCBs were not detected at concentrations above their respective SQOs in the waterway
sediment samples that were tested. In general, the average detected concentrations for
HPAHs, phthalates, and other SVOCs were higher in Year 7 relative to Years 2, 3, and 4.
LP AH average detected concentrations generally increased in Year 7 relative to the
average detected concentrations in Year 3 and Year 4.
Monitoring by City -Year 6 (2012)
OMMP activities were performed during 2012 (Year 6) in the waterway and at the habitat areas
within the Thea Foss Project site and at the confined disposal facility. The following monitoring
tasks were performed in 2012: Habitat mitigation area monitoring, including qualitative
monitoring of the cap and berm at the St. Paul Waterway Confined Disposal Facility (CDF), and
additional project related tasks.
Habitat Mitigation Area Monitoring (2012)
The habitat mitigation areas for the project are the North Beach Habitat, Middle Waterway
Tideflat Habitat, Puyallup River Side Channel, and the Hylebos Creek Mitigation site. The Thea
Foss Habitat Enhancement Areas are Johnny's Dock Habitat Enhancement, Head of Thea Foss
Shoreline Habitat, SR 509 Esplanade Riparian Habitat and the Log Step Habitat Enhancement.
Year 5 habitat monitoring activities were initiated on July 19, 2012, and continued intermittently
at the various sites until August 20, 2012. The activities at each area are presented below.
North Beach Habitat
The qualitative ground survey at this site was conducted on July 19, 2012. The site was noted to
be in good condition. There were no indications of animal damage or vandalism found, and very
minimal amounts of trash and wrack associated with the tide line. There was no change noted in
the appearance of the surface soils in the riparian or aquatic areas relative to previous monitoring
events. There was no indication of odor or sheen in either area. Planted pilot nodes due to their
exposure and were not successful in becoming established. There continues to be minimal
success of the saltgrass in the remainder of this area; however, the pickleweed is spreading in the
potential marsh area although the area appears somewhat reduced from previous observations. A
few invasive weeds were present in the overall riparian area, including white sweet clover,
willow herb, daisy, and cudweed. Oxeye daisy is present all along the berm. Minor weeding of
the riparian area is therefore needed.
Middle Waterway Tideflat Habitat
The qualitative ground survey at this site was conducted on July 19, 2012. The site was noted to
be in good condition. There was some minor indication of animal damage in the marsh area
where it appeared that geese/birds were continuing to eat the grasses (goose exclusion grids were
previously removed), but there continues to be no indication of disease or animal damage in the
riparian area. The animal damage in the marsh does not seem to be significantly impacting the
continued growth and development of the site. There were no indications of vandalism at the site
and only very small amounts of trash present in the tide line. It was noted during the inspection
that all of the plants were doing well, with continued growth and spreading of both established
plants and volunteers.
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Puyallup River Side Channel
The qualitative ground survey at this site was conducted on July 19, 2012. The site was noted to
be in good condition. No new areas of erosion were observed within the side channel. There was
no indication of animal damage or disease at the site. There was minimal trash present, and some
cut branches noted. An occupied transient camp was found near the breach on the old levee
structure, and the Tacoma Police Department was subsequently notified. It was noted during the
inspection that overall on the old levee the riparian plants were doing well, and both original and
newer plants are growing and spreading. The plants on the new levee were not doing as well with
the alder and willow showing better success than the red-osier dogwood. Recently it was
observed that the waterward face of the new levee had been mowed by USACE down to the mud
line. Some invasive species, including butterfly bush, chamomile, birdsfoot trefoil and reed
canary grass were present. Minor weeding of this area is therefore required.
Hylebos Creek Mitigation Site
The qualitative ground survey at this site was conducted on July 20, 2012. The site was noted to
be in good condition. There was no indication of disease noted and only minor beaver damage
observed. The only trash present was one large, suspicious-looking black plastic bag that had an
odor. This was referred to the Tacoma Police Department. There were no wrack or organic
material accumulations present. The LWD were present and in good condition and no
maintenance actions were identified. No obstruction to fish passage in the channels was
observed. Several willows and alder have fallen into the marsh area, providing shade and
diversity without blocking fish passage. Some invasive weeds were identified at the site,
including reed canary grass, poison hemlock, tansy, curled dock and blackberry, and minor
weeding as a part of regularly scheduled maintenance is needed.
According to the OMMP, the performance criteria relative to elevation changes at this site
indicate that the average elevation change along the centerline transect of the channels must be
less than 0.2 feet from the as-built elevations. Based upon this criteria, the south lobe does not
meet this performance criteria (average Year 6 change in south lobe relative to as-built elevations
was 0.45 feet) while the north lobe is right at the criteria with an average change of 0.20 feet
(Table 6-5). However, when the elevations are compared to either the design elevations or the
Year 0 elevations, both lobes meet the performance criteria.
Johnny's Dock Habitat Enhancement
The qualitative ground survey at this site was conducted on July 19, 2012. The site was noted to
be in fair condition. Extensive goose predation on the grasses was noted, but there were no
indications of disease, vandalism, trash or wrack present. The goose exclusion grid was
previously removed and the LWD was found to be in good condition. There were no invasive
species identified during the inspection.
Head of Thea Foss Shoreline Habitat
The qualitative ground survey at this site was conducted on July 19, 2012. The site was noted to
be in good condition. There were no indications of animal damage, disease or vandalism at the
site, and only minor amounts of trash and wrack found at the high tide line. The goose exclusion
grid has been removed, and the site appears stable. The log step appeared to be in good
condition. South of the site near the twin 96ers outfalls, a number of invasive species are present
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
including blackberry, nightshade, Scotch broom and white sweet clover. The City will look into
maintaining this area to eliminate this seed source.
SR 509 Esplanade Riparian Habitat
The qualitative ground survey at this site was conducted on July 19, 2012. The site was noted to
be in fair condition. Vegetation outside of the bridge shadow is doing well while those plants
under the bridge are nearly non-existent. There was some damage to the sprinkler system and
some broken limbs on the trees which may have been a result of vandalism. The sprinkler system
needs to be inspected to ensure that it is in good, working order. Invasive species identified
during the inspection include plantain, tansy, poison hemlock and oxeye daisy. Ongoing weeding
of the site is needed.
Log Step Habitat Enhancement
The qualitative ground survey at this site was conducted on July 19, 2012. The site was noted to
be in good condition. The log step appeared to be in good condition and only minor maintenance,
including checking the anchors on the logs, is needed. Some invasive species are present
adjacent to the site including St. John's Wort and a cherry tree. Therefore, only minor weeding is
needed.
Additional Project-Related Activities (2012)
Several development plans and proposals are currently under construction or consideration and
are being evaluated for their potential to impact the cleanup areas. These proposals include the
following: Waterway Park, North Moorage, Public Esplanade, Seaplane Float, Murray Morgan
(11th Street) Bridge, Simpson cogeneration Facility, Commencement Bay Marine Services, and
Tacoma Metals Site Remediation.
The Thea Foss and Wheeler-Osgood Waterways are located in a highly urbanized drainage basin
with residential, commercial and industrial land uses and transportation corridors. Sources of
COCs continue to exist in the drainage basins and are conveyed to the waterways via stormwater
(municipal and private), aerial deposition, marinas, and groundwater seeps. The City prepared
and submitted the Thea Foss and Wheeler-Osgood Waterways 2011 Source Control and Water
Year 2011 Stormwater Monitoring Report (Stormwater Annual Report) in March 2012. This
Stormwater Annual Report outlines the City's existing programs and studies completed in 2011
and includes a discussion of the need for additional source controls. Included are annual source
control evaluations for the seven major outfalls discharging to the waterways; Outfalls 237A,
237B, 235, 230, 243, 245 and 254.
The time trends were modeled with best-fit regression equations to estimate percent reductions
over the 10-year monitoring period for these constituents and outfalls (OFs):
• TSS: 44 to 67 percent reduction in OFs 230, 235, 237A, and 237B
• Lead: 41 to 49 percent reduction in OFs 235, 237A, 237B, and 245
• Zinc: 48 to 51 percent reduction in OFs 237B and 254, respectively
• PAHs: 80 to 96 percent reduction in phenanthrene in all seven drains
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
• Pyrene: 83 to 97 percent reduction in all seven drains
• Indeno(l,2,3-c,d)pyrene: 85 to 96 percent reduction in all seven drains
• BEHP: 57 to 87 percent reduction in OFs 230, 235, 237A, 237B, 243, and 245
While overall stormwater trends are decreasing, analytical data indicate that there are some areas
with higher concentrations of certain contaminants where additional source control efforts can be
implemented. The City believes further improvements in stormwater quality may be realized in
the future with ongoing Phase INPDES permit programs and continuing improvements in source
control implementation.
Monitoring by City -Year 7 (2013)
OMMP activities were performed during 2013 (Year 7) in the waterway and at the habitat areas
within the Thea Foss Project site and at the confined disposal facility. The following monitoring
tasks were performed in 2013: low tide slope cap inspections, hydrographic surveys, sediment
chemical monitoring, benthic recolonization monitoring, and confined disposal facility
monitoring.
Low Tide Slope Cap Inspections
Remedial Area (RA) 3 has five small (2-3 inch) holes in the surface of the grout mat cap. They
do not appear to be impacting the integrity of the containment. No SQO exceedances were
present in the slope cap composite sample.
Some potential down-slope movement of rip rap was noted below Outfall 230 in Remedial Area
8, but it does not appear to be impacting cap integrity. No SQO exceedances were found. Some
debris remained on the beach below the Colonial Fruit Warehouse that was demolished, and the
contractor will be required to remove the debris.
In Remedial Area 14, a potential vessel-scour area was noted near the waterline, which
previously was only a small depression. However, no SQO exceedances were noted.
Hydrographic Survey
The Year 7 multi-beam hydrographic survey was conducted on April 9-10, 2013. In general, the
Year 7 cap surface elevations are within six inches of the baseline surface elevation and within
the allowable accuracy of the survey equipment. A comparison of the Year 4 to the Year 7
survey shows that the elevations in most areas have remained fairly consistent during the past
three years. There are limited locations where the decrease in the cap surface elevation from
baseline to Year 7 is greater than six inches but less than one foot. These locations are generally
small, localized, and non-contiguous.
Sediment Chemical Performance Monitoring
In Year 7, a total of 4 of the 11 channel sand cap performance monitoring samples had no SQO
exceedances (samples CC-01-Y7, CC-18-Y7, CC-26-Y7, and CC-30-Y7). Five of the 11
samples had only one SQO exceedance, for BEHP (samples CC-27-Y7, CC-29-Y7, CC-31-Y7,
CC-33-Y7, and CC-RA9-Y7), and two samples had multiple SQO exceedances (CC-23-Y7 and
CC-32-Y7). Figures 4-18a and 4-18b (a two-part figure) show sampling locations.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
At Station 23 in RA 6, adjacent to Outfall 230, a total of 4 analytes were detected at
concentrations greater than the SQOs in the Year 7 channel sand cap sample. Analytes that
exceeded the SQOs in sample CC-23-Y7 included three HPAHs and BEHP, with SQO
exceedance factors ranging from 1.04 to 1.29 for the HPAHs and approximately 3.5 for BEHP.
Specific PAHs exceeding the SQOs have fluctuated in different monitoring years. BEHP
remained relatively stable between Year 4 and Year 7.
At Station 32, located in the south end of the City's work area in RA 19A, there were detections
of phenanthrene, dibenz(a,h)anthracene, and BEHP at concentrations greater than the SQOs;
however, the number of SQO exceedances and magnitude of exceedances decreased or remained
comparable between Year 4 and Year 7 in the channel sand cap samples, indicating possible
stabilization.
Early Warning Monitoring for Recontamination
In the Year 7 monitoring, PCBs were detected in 24 of 27 of the early warning samples
collected; however, there were no PCB SQO exceedances detected. In contrast to Year 7, there
were only two detections of PCBs in the Year 2 early warning samples, and PCBs were not
detected in any of the Year 4 early warning samples. In general, there were no new source
control issues identified for follow-up. The vast majority of early warning exceedances of the
threshold concentrations were for BEHP and PAHs. General stormwater source control
activities are being implemented on an ongoing basis, and are reducing concentrations of BEHP
and PAHs in stormwater sediments.
Natural Recovery Monitoring
In Year 7, a total of 8 of the 13 natural recovery stations had performance monitoring samples
with no SQO exceedances. Two of the 13 stations had natural recovery samples with only one
SQO exceedance in Year 7, both for BEHP with SQO exceedance factors of less than 2; and
three of these stations had natural recovery samples with multiple SQO exceedances (NR-12-Y7,
NR-20-Y7, and NR-25-Y7).
Station 25, on the mudflat behind the Delin Docks Marina slips, has consistently had multiple
analytes detected at concentrations above the SQOs. In Year 7, there were 5 analytes detected at
concentrations above the SQOs. Total PCBs were present at this location with an exceedance
factor of 1.67. This value is somewhat higher than the exceedance factor found for total PCBs in
this location in Year 2 sampling. No action is recommended at this time, and this area will be
monitored next in Year 10 (2016).
Slope Cap and Slope Rehabilitation Monitoring
There were no SQO exceedances in 6 out of 7 slope cap areas sampled. SC-20, which is a
composite sample from the shoreline area on the east side of the waterway between the sheet-pile
wall (i.e., the south end of the City's work area and the north end of Johnny's Dock restaurant),
had SQO exceedances for BEHP and benzyl alcohol at exceedance factors of approximately 1.2
and 1.6, respectively. No follow-up action was recommended.
Two of the three natural recovery/slope rehabilitation stations also had samples with no SQO
exceedances. Natural recovery/slope rehabilitation sample SR-10-Y7 on the northern shoreline
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
of Wheeler-Osgood had one SQO exceedance for total PCBs. The concentration was similar
to that found in Year 2 monitoring.
Benthic Recolonization Monitoring
For benthic monitoring, nearly all of the areas sampled show evidence of mature infaunal
communities present and evidence of benthic ecosystem recovery.
Confined Disposal Facility (CDF) Monitoring
In general, groundwater samples collected from shallow and deep wells adjacent to the CDF had
similar or lower metals results than the quarterly baseline monitoring results and the Year 4
performance monitoring results. The Year 7 detected concentrations of PAHs for all performance
monitoring wells located adjacent to the CDF, and for MW-04 within the CDF, were less than or
within the range of concentrations detected in each well throughout quarterly baseline
monitoring and Year 4 performance monitoring.
Erosion at North Beach continues, but containment does not appear compromised. Dune grass is
establishing on the upper beach, which will help to stabilize the berm.
Habitat Mitigation Area Monitoring (2013)
Four habitat mitigation sites were monitored during this period: North Beach, Middle Waterway
Tideflat Habitat, Puyallup River Side Channel, and Hylebos Creek. Overall, areas are performing
as designed; however, some issues still need to be addressed by EPA and the City to determine if
objectives should be altered.
North Beach Habitat
A qualitative ground survey confirmed that the site is in good condition, and continues to
become more established in both the marsh and riparian areas, particularly with the growth and
development of the more recently planted area on top of the berm. The pickleweed is continuing
to spread well throughout the potential marsh portion of the site, and is the dominant species in
this area. Some small areas of salt grass are present, but it is much less prevalent than the
pickleweed. Dune grass is also present and doing well at the upper elevations on the beach
between the marsh and riparian areas. The original pilot nodes were not particularly successful,
but the plants are very well developed higher on the shoreline and amongst the large woody
debris where conditions are more conducive to survival.
Middle Waterway Tideflat Habitat
A qualitative ground survey confirmed that the site was continuing to develop well, and the
brackish marsh plants were continuing to spread outside of the planted nodes within the area
watered by sprinklers (irrigated). The vast majority of the upper intertidal area is filled with
vegetation. As described in the Habitat Preliminary Findings Memorandum, a break in the
sprinkler header line just south of mid-site was noted during the inspection. Water flowing from
the break caused an area of erosion on the slope. Upon identification of the issue, the City turned
off the sprinkler system and the end of the header pipe was capped. Following placement of the
cap, the system was turned back on. As a result of this break, the northern portion of the marsh is
not currently being irrigated. The City has notified EPA of this issue and plans to further discuss
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the need for any restoration of the eroded area with the agencies, and to determine whether or not
repair of the sprinkler system will be required. Since the time of the inspection, two additional
minor breaks in the system were identified and repaired. Maintenance of the irrigation system
remains an ongoing issue at this site.
Puyallup River Side Channel
A qualitative ground survey confirmed that the site was developing well and the plants are filling
in the riparian areas along the old levee section. The primary issue noted at the site was the fairly
extensive use of the site by transients. Due to the presence of encampments, the Tacoma Police
Department (TPD) accompanied staff during the inspection. This undesirable use of the site has
damaged the vegetation to some extent, since it has been cut or trampled during access and
development of the campsites. Removal of these campsites and the associated trash will likely be
an ongoing issue to coordinate with the TPD.
Hylebos Creek Mitigation Site
A qualitative ground survey confirmed that the site was continuing to flourish, with vegetation in
both the riparian and marsh areas thriving and spreading, and many volunteer plants noted. Trees
on the slope area are growing well. There is minimal presence of invasive species, with the
exception of some blackberry and reed canary grass, which is extremely difficult to control with
upstream seed sources present. No obstruction to fish passage was identified in the channel areas.
Overall, this site appeared to be in good condition, with only minor weeding and tightening of
the large woody debris anchors needed at this time.
Additional Project-Related Activities (2013)
The Foss Waterway Development Authority (FWDA) received a grant for remediation of the
American Plating property, which was completed in December 2012. Slope stabilization and
habitat plantings were completed. The FWDA completed the design of a public esplanade
immediately south of the Murray Morgan Bridge on the western shoreline. The existing seawall
supporting the timber esplanade in this area has been failing in recent years, and it was recently
determined that the failure rate had increased substantially. In 2014, the City removed the
seawall and cut back the slope to an acceptable angle to eliminate the need for a bulkhead in this
area. A confining cap was placed over the shoreline in accordance with the Slope Area
Maintenance Plan that was developed by the City and approved by EPA as part of the Year 0
Baseline Monitoring Annual OMMP Report.
In early 2010, the City took ownership of the Murray Morgan Bridge under a turnback
agreement with the Washington Department of Transportation (WSDOT). Rehabilitation and re-
opening of the bridge to vehicular traffic was recently completed. Sampling revealed differences
between the pre- and post-construction sediment data that indicated a sediment quality impact
caused by the rehabilitation work on the bridge. Additional sediment sampling was performed in
the spring of 2014 to determine the extent of contamination of sediments below the bridge to
determine if there is a need for additional response actions and where such actions would needed.
Results of that effort indicate that additional response actions are needed to address elevated
metals levels (primarily lead) in sediments below the bridge. EPA and the City of Tacoma are
currently working on planning and implementing cleanup work in this area.
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The Tacoma Metals Site Remediation site is located adjacent to the Puyallup River Side Channel
habitat mitigation area. As of the date of this report, the property owners are continuing to work
with Ecology to finalize the update to the RI/FS. Once that is complete, the parties will work to
develop the cleanup action plan for the site.
Over a 12-year period (August 2001-September 2013), stormwater and stormwater suspended
particulate matter (SSPM) have been sampled at the 7 major outfalls that discharge into the Thea
Foss and Wheeler-Osgood Waterways. In addition, baseflow was sampled at the same 7 outfalls
for the first 10 years of the program. Over the last 12 years, more than 1,400 samples have been
collected: 322 baseflow and 846 stormwater samples were collected at the outfalls, and 74
(outfall) and 230 (upline) SSPM samples were collected in pipeline sediment traps deployed
throughout the watershed. The number of statistically significant time trends (in this case,
showing improving conditions) observed in Tacoma's stormwater monitoring record increased to
forty-four (44 out of 49 tests, or approximately 90 percent of the tests) in Year 12 using simple
linear regression. All trends were in the direction of decreasing concentrations (City of Tacoma
2014).
4.7.3.4.2 Utilities' Area
Following the completion of the Utilities' remedial action activities, the OMMP for the Utilities'
work area (a 2003 document prepared by Tetra Tech FS, Inc.) was finalized based on as-built
conditions. The Utilities' OMMP sampling program is designed to collect data to meet the
following objectives:
• Evaluate the effectiveness of the hybrid cap installed over contaminated sediments
(evaluated principally by coring).
• Determine compliance with the SQOs (by collection of compliance sediment samples [0 to
10 cm]).
• Assess source control effectiveness (by collection of early warning sediment samples ([0 to
2 cm]).
Monitoring activities were conducted in 2009, 2010, 2011, 2012 and 2013 (Monitoring Years 5 -
9) during this review period. Qualitative ground surveys were conducted in each of these years,
with more comprehensive monitoring being conducted in Year 7. The Year 7 (2011) monitoring
results represent the most current and comprehensive characterization of the conditions of the
various remedy components within the Utilities' work area and are reported below, as are
findings from the Year 9 (2013) qualitative ground survey. The Utilities completed their Year 10
field monitoring activities in May 2014, but the results of those efforts were not available for
inclusion in this review. Those results will be reported in the next FYR in 2019.
Results from the Utilities' OMMP monitoring activities conducted during this review period
(Years 5, 7 and 9) are summarized below.
Monitoring by Utilities -Year 5 (2009)
To meet the OMMP objectives, monitoring of the Utilities Work Area included physical cap
integrity assessment, and compliance and recontamination sampling. Physical observations
included visual inspections of the cap. Sediment sampling included collection of samples for
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
chemical testing (compliance - 0-10 cm, early-warning recontamination, and core samples). See
Figure 4-19 for the Utilities' OMMP monitoring locations.
Visual Inspection
The visual inspection assessed the slope cap and outfall scour cap protection. A visual inspection
of the cap was made on April 13, 2009 and July 9, 2009 during low tide events. The scour
protection apron was functioning as intended. Side slopes showed no visible evidence of slope
erosion, sloughing, etc. At Outfall 235, both wing walls were separating from the Outfall 235
head wall. The new kayak float and the associated anchor pad for the ramp to connect to the float
were installed on the east side of the Waterway just south of the SR-509 Bridge. The new park
on the west side of the waterway (Former Standard Chemical site) was being landscaped during
the site visit. The associated parking lot and restroom facilities had been completed. Based on the
physical observations made during the Year 5 monitoring, it was recommended that the slope
armor and outfall scour protection adjacent to Outfall 235 be restored.
Sediment Samples
Available data continued to indicate that the top of the Utilities' cap has been recontaminated at
levels above the CBNT SQOs. Evaluation of a variety of data concluded that the recontamination
sources were stormwater outfalls that discharge to the head of the waterway. Fifteen early
warning (recontamination core [RC]; 0 to 2 cm deep) surface sediment samples and 19 waterway
compliance (waterway cap [WC]; 0 to 10 cm deep) surface sediment samples were collected for
Year 5 OMMP monitoring. Based on the stratigraphy of the grab samples, it was evident that the
material had accumulated on top of the sand cap and had increased in depth each year. The most
likely source of the material deposited over the cap is from the stormwater outfalls. The
waterway cap compliance samples (0 to 10 cm) from the locations beneath and south of the SR
509 Bridge were analyzed for partial SVOCs (PAHs, BEHP, and phthalates), TOC, and total
solids. BEHP concentrations were higher than the SQO (1,300 (J,g/kg) in all compliance samples
south of the SR 509 Bridge in May 2009. In December 2004, the City remediated the area north
of the bridge by placing additional capping material to address recontamination from dredging
activities. In Year 5, five of the seven samples collected from the compliance sampling interval
north of the bridge contained BEHP concentrations exceeding the SQO of 1,300 (J,g/kg as a result
of the increasing thickness of sediment above the cap. Fluoranthene was detected at its SQO
(2,500 (J,g/kg). All early-warning samples south of the SR 509 Bridge contained BEHP
concentrations above the SQO of 1,300 (J,g/kg. The early-warning samples contained
concentrations of individual PAHs and/or total HP AH that exceeded their SQOs. BEHP was the
only parameter that exceeded its SQO for early-warning samples north of the bridge. Compliance
sample concentrations of BEHP and HP AH within the turning basin below and south of the SR
509 Bridge have consistently increased between 2007 and 2009. In addition, the number of
individual PAH SQO exceedances had increased between 2008 and 2009. The average
concentration of BEHP increased from approximately 3,100 (J,g/kg in 2007 to 5,500 (J,g/kg in
2009, while HP AH concentrations increased from approximately 6,171 (J,g/kg in 2007 to 14,000
[j,g/kg in 2009. Compliance sample concentrations of BEHP and HP AH north of the SR509
Bridge have increased between 2007 and 2009. The average concentration of BEHP increased
from 529 (J,g/kg to 3,200 (J,g/kg, while the average concentration of HP AH increased from 1,133
[j,g/kg to 7,200 (J,g/kg from 2007 to 2009; resulting in a six-fold increase since 2007.
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Monitoring by Utilities - Year 6 (2010)
Consistent with the requirements of the Consent Decree, Year 6 of the OMMP had no
requirement to conduct physical integrity monitoring. No qualifying events (earthquakes or large
storms) that would have triggered the need for monitoring had occurred since the last monitoring
event. As a follow up to the recommendations made in Year 5 OMMP report, site observations
and maintenance activities at Outfall #235 were conducted. A Technical Memorandum was
submitted for Year 6 OMMP activities.
At Outfall 235, both wing walls are separating from the Outfall 235 head wall. The separation
between the head wall and the south wing wall was larger than the separation between the head
wall and the north wing wall. The distances measured during this site visit were approximately 9
1/2 inches and 7 3/4 inches respectively, slightly greater than the distances measured during Year
5 observations (9 3/8 inches and 7 1/2 inches respectively).
The slope armor adjacent to both the south and north wing walls was observed to have been
displaced or sloughed, leaving the underlying slope cap exposed. It is believed the intentional
displacement of the outfall scour material in front of Outfall 235 and from the toe of adjacent
slopes contributed to instability and caused downward movement of armor material from the
slope areas. As a result, the underlying slope cap became exposed and potentially subject to
erosion. The Year 5 OMMP Technical Memorandum recommended restoration of the outfall
scour protection to ensure the integrity of the underlying slope cap. At the time of the site visit in
April 2010 (Year 6), the area of exposed slope cap adjacent to both the south and north wing
walls appeared slightly greater than was observed during Year 5 OMMP. Armor stones were
replaced back into the original locations.
The condition of the scour protection apron at the south end of the waterway was consistent with
observations presented in the Year 5 OMMP Technical Memorandum. Water was flowing out of
Outfalls 237a and 237b during the site visit.
The new kayak float on the east side of the Waterway just south of the SR-509 Bridge was in
use.
The scour protection adjacent to Outfall 243 (at Station 73+40 on the east side of the waterway
under the SR-509 Bridge) showed no further signs of erosion or displacement. The Tideflex™
valve at the end of Outfall 243, which was extensively covered with barnacles and mussels at the
time of the Year 5 observations, appeared to have been cleaned.
Monitoring by Utilities - Year 7 (2011)
Available data indicate that the top of the Utilities' cap has been recontaminated at levels above
the CB/NT SQOs. BEHP exceeds the SQOs by the greatest degree and over the widest area.
Several individual PAHs, total HPAHs, benzyl alcohol, and benzoic acid also exceed their
respective SQOs at one or more locations. The greatest exceedance of the SQOs occurs at sample
location RC/WC-05, where BEHP was measured at 21,000 (J,g/kg with an exceedance factor of
16.2. The HP AH and BEHP trend relationship in early warning sediment samples is similar to
the trend relationship of stormwater sediment samples collected near the end of the Twin 96-inch
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outfalls at the Head of Thea Foss. These data indicate that the Twin 96-inch outfalls are the
primary source of PAHs and BEHP to the Head of the Thea Foss Waterway.
Physical Observations
Visual inspections of the cap were made on May 16 and May 17, 2011, during predicted low
tides of -2.1 feet MLLW and -2.4 feet MLLW. The scour protection apron is functioning as
intended. No obvious signs of significant erosion were observed. A series of small shallow
channels are present in the apron near the middle of the south end of the waterway, as previously
noted in the Year 0 through Year 6 observations. Waterway slopes show no visible evidence of
slope erosion, sloughing, etc. Gas bubbles were observed throughout the head of the waterway
and in the vicinity of the former SR-509 seep area during the site visit, but no sheens were
observed in the former SR-509 seep area.
Hydrographic Survey
The Year 7 (2011) bathymetry survey has revealed the sediment cap to be relatively stable when
compared with the Year 4 OMMP August 2008 survey. At the south end of the waterway, some
erosion of habitat mix placed on the scour protection apron sill was occurring in 2008, likely due
to the flow from the Twin 96-inch outfalls. This erosion was not observed in the 2011 survey
data. However, material appears to be depositing in a mound just below the sill. The results of
the hydrographic survey indicate that the minimum cap thickness performance criterion is being
met as provided for in the OMMP, and no further evaluation or remediation is warranted at this
time.
Sediment Samples
The waterway cap (WC) compliance samples (0 to 10 cm) from the WC locations beneath and
south of the SR-509 Bridge were analyzed for grain size, total organic carbon (TOC), metals,
TPH-Dx (diesel range), SVOCs, DDT compounds, and PCB Aroclors. The percent fines ranged
from 4.2 percent at location RC/WC-01 south of the bridge at the edge of the scour apron to 65.2
percent at location WC-13 under the SR-509 Bridge, averaging 49.8 percent. The high
percentage of fines is an indicator of sedimentation occurring south of the bridge. BEHP
concentrations were higher than the SQO (1,300 (J,g/kg) in all compliance samples south of the
SR-509 Bridge in April 2011. In addition, SQOs were exceeded for individual PAHs and total
HPAHs at locations WC-02, WC-04, WC-05, and WC-06; for individual PAHs at location WC-
03; for benzyl alcohol at location WC-01 to WC-06, WC-13, and WC-14; and for benzoic acid at
locations WC-02 and WC-05.
The early-warning "top down" (0 to 2 cm) sediment samples south of the SR-509 Bridge were
analyzed for partial SVOCs (PAHs and BEHP), metals (lead, mercury, and zinc), TPH-Dx, PCB
Aroclors, TOC, total solids, and grain size. All early-warning samples south of the SR-509
Bridge (WC/RC-01 through WC/RC-09, RC-13, and RC-14) contained BEHP concentrations
above the SQO of 1,300 (J,g/kg. BEHP concentrations ranged from 3,300 (J,g/kg (2.5 exceedance
factor) at RC7WC-07 to 8,900 (J,g/kg (6.8 EF) at WC/RC-02. The early warning samples
collected at locations WC/RC-01, WC/RC-02, WC/RC-03, WC/RC-04, WC/RC-05, WC/RC-6,
RC-13, and RC-14 contained concentrations of individual PAHs and/or total HP AH that
exceeded their SQOs.
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Recolonization
As part of the Utilities' OMMP, the primary means to evaluate habitat recolonization is through
the use of sediment profile imaging (SPI). While the overall site benthic habitat status and
recolonization were not significantly different between the first two surveys, the results from this
most recent survey show a dramatic regression in both habitat conditions and benthic community
assemblages. While there were some indications of stalled recovery in the 2008 survey because
conditions were essentially the same as those detected in 2006, the profile images from the 2011
survey were notably different because of the increased deposition of low oxygen/anoxic, fine-
grained sediments throughout the area that erased most visible signatures of the capping layer.
Given the study area's location and the point sources of input to this system (mainly stormwater
outfalls at the head of the waterway and on the east and west sides under the SR-509 Bridge),
there appears to be a constant supply of organically enriched material to the study area that will
continue to be a stressor to benthic community.
Monitoring by Utilities - Year 8 (2012)
Consistent with the requirements of the Consent Decree, Year 8 of the OMMP had no
requirement to conduct physical integrity monitoring. No qualifying events (earthquakes or large
storms) that would have triggered the need for monitoring had occurred since the last monitoring
event. The Utilities continued to conduct low tide site observations on an annual basis during the
spring/summer timeframe. A Technical Memorandum was submitted for Year 8 OMMP
activities.
At Outfall 235, both wing walls were separating from the Outfall 235 head wall. The separation
between the head wall and the wing walls were similar to Year 4, 5, 6 and 7 observations
indicating little to no additional movement. The distance between the head wall and the north
wing wall was measured at 7.5 inches, and the distance between the head wall and the south
wing wall was measured at 9.5 inches. Slope armor stone adjacent to Outfall #235 showed
minimal signs of erosion and displacement. There continued to be a pool with a sandy bottom
directly in front of the outfall as noted in previous years.
As previously noted in the Years 0, 1, 2, 3, 4, 5, 6 and 7 site observation memoranda, the coarser
slope cap materials and habitat mix were covered with algae, seaweed, and barnacles at the
exposed east and west bank waterway slopes.
The scour protection apron placed at the head of the waterway was functioning as designed and
no corrective action was recommended.
The American Plating Site occupies approximately 1.4 acres of land that is located along the
eastern shoreline at the head of the Thea Foss Waterway. Remedial action was conducted by the
Foss Waterway Development Authority (FWDA) to address contamination resulting from
releases from past metal plating operations at the Site. Observations of the former American
Plating remediation site along the top of the east slope of the waterway showed that it was fenced
in by heavy duty silt barriers. The planned restoration of the capped portion of the site adjacent
to the shoreline in the habitat enhancement area at and above the ordinary high water line with
native plantings had not been completed as of the June 4th or 6th site visits.
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The scour protection adjacent to Outfall 243 (on the east side of the waterway under the SR-509
Bridge) showed no obvious signs of erosion or displacement. The Tideflex™ valve at the end of
Outfall 243 did not appear to have been cleaned recently and had more barnacles than the
observations in previous years.
Monitoring by Utilities - Year 9 (2013)
In Year 9, the Utilities monitored the outfalls, bank work, the scour protection apron, and the
former American Plating site.
Condition of Outfall 235 Wing Walls
At Outfall 235, both wing walls are separating from the head wall. The separation in the south
wing wall is larger than the separation in the north wing wall. The distance between the sets of
Parker-Kalon (PK) nails in the north wing wall was measured as 7.5 inches. The same
measurement at the south wing wall was done using the existing nail holes and the measurement
was 9.5 inches from the first nail hole. The measurements were also taken from the second and
the third nail hole on the head wall. These measurements were 10.25 and 11.25 inches. The
measured separation between the wing walls was similar to previous observations, indicating
little to no additional movement.
Upper Bank Work
Above Outfall 235 and along the upper part of the west bank, some work was completed that
allows the public closer access to the Waterway. The work includes construction of a new
walking path and restacking of erosion control quarry spalls above the head wall of Outfall 235
and placement of toe protection for the walking path. It appears that the upper west bank slopes
below the Thea Foss Waterway Public Esplanade and the 21st Street Park were scraped and
shaped to create a bench slope during construction of the path. The origins of the constructed
path are unknown, and in checking with the City, they had no information regarding who
installed it or when it was constructed.
Scour Protection Apron
A series of small, shallow channels are present in the apron near the middle of the south end of
the waterway. The configuration and shallow depth of these channels appear unchanged from
previous observations, and the overall integrity of the cap has not been observed as adversely
impacted by the presence of these features. No corrective action was proposed. Silt continues to
build up on and adjacent to this scour apron, with the greatest accumulation on the east side of
the scour apron.
Former American Plating Upland Remediation Site
The American Plating Site occupies approximately 1.4 acres of land that is located along the
eastern shoreline at the head of the Thea Foss Waterway. Remedial action was conducted in
2012 by the FWDA to address contamination resulting from releases from past metal plating
operations at the Site. The remediation included excavation and capping of soil with contaminant
concentrations greater than the Site cleanup levels, and restoration of the site to support the
planned future development of the site as a public park with public access to the waterway.
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4.7.4. Progress since the Last Five-Year Review
Results from the OMMP activities are discussed in the previous Section 4.7.3, Post-Construction
Monitoring/O&M.
4.7.4.1 Previous Protectiveness Statement
The protectiveness statement in the third FYR (2009) stated:
"The remedy at the Thea Foss and Wheeler-Osgood Waterways currently protects
human health and the environment because the sediment remedial action
significantly reduced sediment concentrations and most of the required
institutional controls are in place to protect the integrity of the sediment cap.
However, in order for the remedy to be protective in the long-term, additional
source control activities need to be identified and implemented to reduce the
extent of recontamination in the waterway and the USCG institutional control
needs to be completed to help protect the long-term integrity of the sediment cap."
4.7.4.2 Status of Recommendations
The recommendations made in the third FYR (2009) for the Thea Foss and Wheeler-Osgood
Waterways are summarized below, along with a progress evaluation presented in italics.
• Thea Foss and Wheeler-Osgood Waterways - source control does not appear adequate to
prevent recontamination; continue to monitor and evaluate sources of phthalates and PAHs
to sediments. Results from the Utilities' Year 7 (2011) monitoring indicate that stormwater
from the Twin 96-inch outfalls continues to be a source of BEHP and PAH sediment
concentrations exceeding the SQOs at the Head of Thea Foss. Year 10 (2014) monitoring
results were not available for inclusion in this review, but will provide valuable
information about whether the Twin 96-inch outfalls are continuing to contribute BEHP
and PAHs to the sediments at the head of the waterway.
4.7.5. Five-Year Review Process
4.7.5.1 Administrative Components
The Thea Foss and Wheeler-Osgood FYR team was led by Bill Ryan, the EPA RPM, Region 10.
Deborah Johnston (biologist) with the USACE, Seattle District, assisted with the review.
By December 2013, the review team had been formed and the review schedule had been
established for the following activities:
• Document collection and review;
• Data assessment and analysis;
• Site inspection;
• Interviews and community notification and involvement; and
• FYR report development and review.
The FYR has a statutory completion date of December 23, 2014.
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4.7.5.2 Community Involvement
On January 17, 2014, a display advertisement ran in the Tacoma News Tribune newspaper
providing notification and contact information for the FYR. In addition, on January 21, 2014,
EPA Community Relations staff sent postcards to stakeholders and neighbors included on the
CB/NT project mailing list (approximately 1,150 addressees), providing notification about the
five-year review process. Both notifications requested that any information that people would
like EPA to consider during the review be provided to the EPA before April 15, 2014. On
February 19, 2014, Kevin Rochlin, Bill Ryan, and Jonathan Williams (all with EPA Region 10)
met with Bill Andersen, the Executive Director of Citizens for a Healthy Bay, at which time EPA
provided information on CB/NT activities and preparation of the fourth FYR.
The Foss Waterway Development Authority (FWDA) provided comments describing the pro-
active stewardship actions taking place at the marinas in the waterway and the EnviroStar
certifications obtained by those marinas.
No other community input was provided related to the review of the Thea Foss and Wheeler-
Osgood Waterways.
4.7.5.3 Document Review
A review of reports pertinent to this FYR was conducted by the review team. The types of
documents reviewed included decision documents, annual data reports, technical memoranda,
and other supporting materials. OU 01 Attachment 1 is a complete list of documents reviewed
during this FYR.
4.7.5.4 Data Review and Evaluation
Results from the OMMP activities are discussed in Section 4.7.3, Post-Construction
Monitoring/O&M. Institutional Control Plans for the City's Work Area and the Utilities' Work
Area were approved in September 2006. The City's project representatives also continue to work
with the City's Building and Land Use Services division to implement procedures to ensure that
future development in and adjacent to the Foss Project areas, where remedial actions and habitat
mitigation work have been completed, are undertaken in a manner that protects the remedy and
the habitat. Additionally, publicly-owned marinas on the waterway require the use of
Department of Ecology Best Management Practices (BMPs) in the leases with boaters as well as
pump-out requirements. The FWDA also actively educates marina staff and boaters, and partners
with Citizens for a Healthy Bay (an environmental organization) on BMPs to ensure compliance
with BMPs. Spill response plans are also in place.
A request was submitted to the U.S. Coast Guard (USCG) to establish a regulated navigational
area (RNA) in the Thea Foss Waterway prohibiting anchorage and other activities that could
disturb the cap. The rule was finalized on January 7, 2011. Therefore, the City now has the
authority to post "No Anchoring" signs in the capped portions of the waterway, if determined to
be necessary.
The City is implementing a stormwater monitoring and source control program for the municipal
storm drains entering the Thea Foss and Wheeler-Osgood Waterways to help provide long-term
protection of sediment quality in the waterways. The City continues to pursue control of sources
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to stormwater and continues to evaluate enhanced BMPs and their effectiveness on reducing
COC loads to the waterway. Over a 12-year period (August 2001-September 2013), stormwater
and SSPM have been sampled at the 7 major outfalls that discharge into the Thea Foss and
Wheeler-Osgood Waterways. In addition, baseflow was sampled at the same 7 outfalls for the
first 10 years of the program. Over the last 12 years, over 1,400 samples have been collected:
322 baseflow and 846 stormwater samples were collected at the outfalls, and 74 (outfall) and 230
(upline) SSPM samples were collected in pipeline sediment traps deployed throughout the
watershed. The number of statistically significant time trends observed in Tacoma's stormwater
monitoring record increased to forty-four (44 out of 49 tests, or approximately 90 percent of the
tests) in Year 12 using simple linear regression. All trends were in the direction of decreasing
concentrations (City of Tacoma 2014).
No interviews were conducted.
4.7.6. Technical Assessment
Question A: Is the remedy functioning as intended by the decision documents?
Answer: Yes.
Overall, sediment concentrations in the waterway have decreased since completing the
sediment remedial actions, indicating that the caps throughout the waterway are stabilizing
and performing as designed (no upward migration of contamination has been documented).
Cap integrity monitoring, which includes visual and hydrographic survey work, indicates that
capped and natural recovery areas are stabilizing and meeting performance criteria in much
of the waterway. The remedy in a large portion of the waterway is supporting benthic
communities. In the head of the Thea Foss Waterway, some analyte concentrations appear to
have increased while other analyte concentrations appear to have decreased in Year 7 (2013)
samples relative to the baseline samples. Broad variability exists in data trends from station
to station, as described in Section 4.7.3.4, Post-Construction Monitoring/O&M. Additional
monitoring is needed at most stations to further evaluate the variation in data trends. Whether
remedial actions taken in the natural recovery and enhanced natural recovery areas have been
successful will be determined once a 10-year period of monitoring is completed by the City
in 2016. Those determinations, and any associated actions, will be presented in the next FYR
report.
Results of stormwater sampling show overall downward trends of COC concentrations in
stormwater and contaminant loading to the Thea Foss Waterway, though contaminants are
still entering the waterway via stormwater outfalls. Data indicate that the discharges from
stormwater outfalls in the head of the waterway are the likely sources of the PAH and BEHP
recontamination. Capped areas in the head of the Thea Foss Waterway are being overlain
with contaminated sediments that appear to be discharged by the Twin 96-inch outfalls
located at the southern end of the waterway. These sediments contain concentrations of
PAHs and BEHP and other site contaminants (benzyl alcohol, benzoic acid) that exceed
SQOs. Two other areas (near Outfall 230 and in RA 19) in the waterway also show evidence
of being recontaminated with PAHs and BEHP, but the exact sources have not been
identified at this time.
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The incoming, stormwater-generated sediments are organically enriched, fine-grained
materials that appear to be limiting the suitability of the area as habitat for benthic
communities. The City of Tacoma continues its efforts to reduce or eliminate the discharge
of the contaminated sediments to the waterway from the City's stormwater system. Those
efforts are expected to further reduce contamination entering the waterway over time, though
the reductions are likely to be smaller than what has been achieved during the first 12 years
of the City's stormwater monitoring and source control program.
There is no site-specific habitat mitigation objective outlined in the ROD. The Department of
Health (DOH) has a flatfish and rockfish consumption advisory in place for the
Commencement Bay waterways. Habitat function and enhancement of fisheries resources is
incorporated as part of the overall project cleanup objective. Habitat mitigation objectives
and goals are site-specific and were developed for the site prior to construction. Generally,
the mitigation sites appear to be performing in accordance with the overall project goals.
A request was submitted to the U.S. Coast Guard (USCG) to establish a regulated
navigational area (RNA) in the Thea Foss Waterway prohibiting anchorage and other
activities that could disturb the cap. The rule was finalized on January 7, 2011. Therefore, the
City of Tacoma now has the authority to post "No Anchoring" signs in the capped portions of
the waterway, if determined to be necessary.
The City submitted a request to the U.S. Army Corps of Engineers (ACOE) in 2007 to
deauthorize portions of the federally authorized navigation channel in the Thea Foss where
capping materials encroach on the authorized channel. The City worked with the ACOE and
the Congressional delegation in drafting deauthorization language for inclusion in the Water
Resources Development Act (WRDA). The most recent version of WRDA was enacted in
2014, but the deauthorization language for the Thea Foss was not included in the law. The
City plans to continue to coordinate with the ACOE and Congressional delegation in an
effort to have the deauthorization language included in the next version of WRDA that is
enacted.
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy still valid?
Answer: Yes.
Changes in Standards and To Be Considered. See Section 4.2.6 (Question B).
Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics. See
Section 4.2.6 (Question B).
Changes in Land Use. There have been no changes in the physical conditions of the site
that would affect the protectiveness of the remedy.
Remedial Action Objectives. The RAOs from the ROD are still valid and protective for the
site.
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Question C: Has any other information come to light that could call into question the
protectiveness of the remedy?
Answer: No.
4.7.6.1 Technical Assessment Summary
According to the data reviewed and information obtained from site monitoring efforts, the
sediment remedial actions have reduced sediment concentrations (the sediment concentrations
remain below SQOs in most areas of the waterway), and the capped areas appear to be
stabilizing and functioning as designed (no upward migration of contamination has been
documented). Cap integrity monitoring, which includes visual and hydrographic survey work,
indicates that capped and natural recovery areas are stabilizing, meeting performance criteria,
and supporting benthic communities in much of the waterway. Stormwater control efforts,
critical to the long-term effectiveness of the sediment remedial actions, have reduced
contaminants entering the waterway. Those efforts, however, have not yet been fully successful
because top-down recontamination is occurring near some stormwater outfalls in the southern
portion (head) of the waterway. Recontamination constituents include PAHs, phthalates,
pesticides, and PCBs. The City of Tacoma has implemented an aggressive stormwater
monitoring and source control program that has reduced contamination entering the waterway.
That program is expected to continue into the foreseeable future.
Institutional controls have been put in place that enhance the long-term integrity of the remedy.
The USCG institutional control (prohibiting anchorage and other cap-disturbing activities) was
completed in 2011 and will help protect the long-term integrity of the cap. The City continues to
work with US ACE and Congressional delegation to deauthorize the capped areas of the
authorized navigation channel in the Thea Foss Waterway. There have been no promulgated
changes in the ARARs, standards, or To Be Considered (only non-promulgated changes to the
AET database from which the SQOs were derived) that could affect the protectiveness of the
remedy. Overall, the sediment remedy remains protective of human health and the environment.
There is no other information that calls into question the protectiveness of the sediment remedy.
4.7.7. Issues and Recommendations/Follow-up Actions
No issues or recommendations/follow-up actions were identified during this fourth FYR for the
Thea Foss and Wheeler-Osgood Waterways.
Action items that do not affect protectiveness, but are expected to require future action, are listed
in Table 7-2.
4.7.8. Protectiveness Statement
The protectiveness statement is provided in Section 8.
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4.8. CB/NT Sediments Oil 01, OU-wide Issue
4.8.1. CB/NT Sediments OU 01, OU-wide Issue and
Recommendation/Follow-up Action
For the CB/NT Sediments OU 01, the ROD specifies that site use restrictions, such as advisories
restricting seafood consumption, will be implemented to protect human health until recovery is
complete. The third FYR (2009) provided a rationale for using fish tissue data to address the
"Site Use Restrictions" element of the remedy (the 2009 FYR is available at the link
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt).
A summary of the issue and the recommendation/follow-up action made in the 2009 FYR and an
evaluation of its progress are presented below:
"Sediments OU 01, OU-wide Issue from Third Five-Year Review (2009) - Recent fish
tissue data for bioaccumulative chemicals have not been collected in Commencement
Bay. Thus, it is not known whether contaminant levels in fish tissues have been reduced
since the remedies have been implemented, particularly for PCBs (which have a human-
health based Sediment Quality Objective), and whether fish advisories should be
continued, modified, or removed.
Sediments OU 01. OU-wide Recommended Follow-Up Action from Third Five-Year
Review (2009) - Develop and implement a sampling plan for collection and analysis of
bay-wide fish tissue data for bioaccumulative chemicals (particularly for PCBs, which
have a human-health based Sediment Quality Objective). Provide results to appropriate
state and local agencies to evaluate protectiveness of health-based fish consumption
advisories for Commencement Bay.
Planned Completion Date for the Recommendations/Follow-Up Actions from Third Five-
Year Review (2009) - December 29, 2014."
In the third FYR (2009), EPA concluded:
"EPA believes that a fish tissue sampling effort is necessary to evaluate progress toward
remedial objectives and whether fish advisories should be continued, modified, or
removed. EPA envisions developing a sampling plan for collection and analysis of bay-
wide fish tissue data for the overall site. EPA believes that it would be appropriate to
initiate the fish tissue sampling effort at this time, since the majority of remedial actions
within the Sediments OU have been completed (by 2008), and the PCB-contaminated
sediments have been addressed by these actions.
Moreover, since sediment quality monitoring is the primary means of assessing whether
ROD objectives have been met, fish tissue data could be used for informational purposes
to evaluate short-term risk reduction for human health since the remedies have been
implemented (e.g., do data suggest a reduction in fish tissue levels?). In Principles for
Managing Contaminated Sediment Risks at Hazardous Waste Sites, EPA (2002) notes
" While it is generally more practical to use measures such as contaminant concentrations
in sediment to identify areas to be remediated, other measures should be used to ensure
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that human health and/or ecological risk reduction goals are being met. Such measures
may include direct measurements of indigenous fish tissue concentrations" "
Background information on this Issue and Recommendation/Follow-up Action is provided
below, followed by a description of progress made since the last five-year review.
4.8.1.1 Background
As described in the CB/NT ROD (EPA 1989; Declaration, p. 1), the overall goal of the selected
remedy is "to protect the marine environment and thereby reduce associated public health
concerns." The selected remedy "is protective of the marine environment and related human
health concerns" (ROD; Declaration, p. 2). The subsequent PCB ESD (EPA 1997; p.4)
reiterated that the cleanup goal for the Commencement Bay problem areas is to achieve
reduction of contaminant concentrations in sediments [emphasis added] to levels that will
support a healthy marine environment and will protect the health of people eating seafood from
the Bay.
Neither the CB/NT ROD nor the PCB ESD specifies a cleanup goal or cleanup level for
contaminants in seafood tissue. As set forth in the ROD and described in Section 4.1.1 of this
Five-Year Review, Sediment Quality Objectives for all problem chemicals were set based on an
evaluation of the ecological and human health risks posed by these chemicals. Only the SQO for
PCBs was based on the human health risk assessment (EPA 1989; EPA 1997). SQOs for all
other chemicals were based on the ecological risk assessment, because the ecologically-based
cleanup levels were determined to be also protective of human health [emphasis added].
The ROD specifies five key elements of the selected remedy for sediments. The ROD does not
include seafood tissue sampling as a specific element of the selected remedy (see Sections 10.2.5
and 10.3 of the ROD). Subsequent ESDs for the individual waterways, including the PCB ESD
(EPA 1997), do not discuss seafood tissue sampling for the Sediments OU.
In reviewing the CB/NT ROD, it can be surmised that the OU-wide recommendation for fish
tissue sampling in the second Five-Year Review was intended to address the "Site Use
Restrictions" element of the remedy. The ROD describes site use restrictions as follows:
"Site use restrictions, such as advisories against seafood consumption, will be
implemented to protect human health until recovery is complete." [Declaration, p. 2]
"Site use restrictions: protect human health by limiting access to edible resources prior to
and during implementation of source and sediment remedial activities." [Section 8]
"Site use restrictions consist mainly of public warnings and educational programs
intended to reduce potential exposure to site contamination, particularly ingestion of
contaminated seafood. Local health advisories are an integral part of the overall remedy
because the ultimate objectives will be achieved over a 15-20 year period." [Sections 8.2
and 10.2.1]
"Site use restrictions (e.g., public warnings and fisheries advisories to reduce potential
human exposure) implemented by state and local health authorities." [Section 2.4.2]
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Thus, the ROD for the Sediments OU specifies site use restrictions in the form of fish advisories
to limit human exposure to contaminated seafood until the remedial objectives are met [see
Section 4.1.1],
Fish and shellfish advisories were put in place before the ROD (1989). According to the CB/NT
RI (1985; p. 1.6), an advisory on fish consumption was issued by the Tacoma-Pierce County
Health Department (TPCHD) in 1982. According to the CB/NT Summary Report of the RI
(1985; p. 6), an advisory on fish consumption (advising against any consumption of bottom fish
from Hylebos Waterway and against regular consumption of bottom fish from the other
waterways) was issued by the TPCHD in January 1983. Relevant information on restrictions
after 1984 was described in the RI and summarized by Hanowell 2008 of TPCHD, as provided in
OU 01 Attachment 2 and described below:
• The original fish and shellfish (including crab) advisories issued by TPCHD were based
on results from environmental investigations in Commencement Bay and EPA's
Assessment of Human Health Risk from Ingesting Fish and Crabs from Commencement
Bay (EPA 910/9-85-129, April 1985, prepared by Versar, Inc. for Ecology, under
contract to EPA). The 1985 human health risk assessment utilized fish and crab tissue
data collected in 1984. After the 1985 assessment, the TPCHD, in conjunction with the
Washington Department of Social and Health Services (DSHS), issued a revised health
advisory. The advisory recommended against the consumption of fish from the
Commencement Bay waterways (EPA 1985, Summary Report of the RI, p. 52). DSHS
(1985) listed precautions for fishing in Commencement Bay in April 1985 (see OU 01
Attachment 3). DSHS recommended that "individuals not fish or gather shellfish from
parts of Elliott, 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. Should it be necessary to fish in these areas, it
would be prudent 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." Specific meal
recommendations or limits were not provided.
• In 1985, the TPCHD posted fish and shellfish advisory signs in City Waterway (now
Thea Foss Waterway), Hylebos Waterway, and Blair Waterway (Hanowell 2008; OU 01
Attachment 2).
• In 1996, TPCHD replaced the original signs with similar signs that were written in
English and other languages (Hanowell 2008; OU 01 Attachment 2). A map showing
locations of these signs is provided in OU 01 Attachment 2.
• Over time (prior to 2008), many of the fish and shellfish advisory signs in Hylebos and
Blair Waterways disappeared and were not replaced because TPCHD observed that
fishers were not utilizing these areas (Hanowell 2008; OU 01 Attachment 2). In 2012,
TPCHD identified and photographed three remaining signs in these waterways (see OU
01 Attachment 2).
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• Currently, fish and crab/shellfish advisory signs are maintained by TPCHD in Thea Foss
Waterway, and are updated when new signs (in many languages) are provided to TPCHD
from the Washington DOH (Tuttle 2012a; see OU 01 Attachment 2). TPCHD posts signs
in Thea Foss Waterway because this is the area where recreational harvesters are
observed fishing and harvesting crab (Tuttle 2012b).
• A photograph of the current signage and a map showing the current location of seafood
advisory signs in Thea Foss Waterway is provided in OU 01 Attachment 2 (Tuttle
2012c). The current advisory signs read: "Do Not Eat Crab, Shellfish, or Bottom-
Feeding Fish due to Pollution." While the DOH and TPCHD agreed on this language for
the Commencement Bay waterways - Hylebos, Thea Foss, and Blair (December 2008;
see OU 01 Attachment 2), this advisory is not an official advisory due in part to the lack
of data.
Fish, crab, and shellfish advisories remain in effect in the Commencement Bay area. Puget-
Sound wide advisories for fish, crab, and shellfish apply to Commencement Bay, and the specific
advisory "Do Not Eat Crab, Shellfish, or Bottom-Feeding Fish due to Pollution" currently
applies to Thea Foss, Blair, and Hylebos Waterways.
4.8.1.2 Fish Consumption A dvisories
The most recent information on fish advisories for the Commencement Bay area was published
in a report released by the Washington State Department of Health (DOH) in October 2006. In
that report, DOH (2006) assessed available fish tissue data to address potential health impacts to
humans who eat marine fish from the Puget Sound area. Crabs and shellfish (e.g., clams,
oysters, mussels) were not included in the assessment. The Commencement Bay area, which is
part of Puget Sound, was included in the DOH assessment (see Figure 4-20).
For the Puget Sound-wide area, DOH evaluated over 100 individual chemicals in tissue muscle
data available for Chinook and Coho salmon, English sole, and four species of rockfish (see
Appendix E of DOH 2006).15'16 DOH (2006) concluded that two of the contaminants are of
15 From DOH 2006: "Contaminants were not considered for assessment if they were detected in fewer than 10% of
fish tissue samples. Only a few chemicals or chemical groups were detected in more than 10% of the samples
analyzed (alpha chlordane, arsenic, benzyl alcohol, copper, DDT and degradation products, DEHP, mercury, and
PCBs). Ninetieth percentile contaminant levels in Puget Sound fish tissue were then compared to health-based
comparison values. DOH used EPA's Guidance for Assessing Chemical Contaminant Data for Use in Fish
Advisories to determine health-based comparison values (EPA 2000). Comparison values were based on a
consumption rate representative of a subsistence consumer (142.4 g/day) and derived for non-cancer and cancer
endpoints. Contaminant levels exceeding comparison values indicate a subsistence consumer receives a dose greater
than the RfD, or results in a cancer risk greater than 1x10-5."
16 From WDOH 2006: "Of the species collected for PSAMP, rockfish can live the longest (up to 90 years),
followed by English sole (between 2 and 21 years), Chinook salmon (typically up to a few months in freshwater and
2 to 4 years in the marine environment), and then Coho salmon (typically one winter in freshwater and 16 - 18
months in the marine environment) (Hart 1973; S. O'Neill, personal communication, 2004; G. Ruggerone, personal
communication, 2005)."
"English sole are bottom feeders with a limited home range while rockfish tend to be even more sedentary.
Contaminant levels in English sole and other bottom fish may show greater spatial variation than other species due
to the localized nature of sediment contamination in Puget Sound. Contaminants such as PCBs and mercury may be
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potential public health concern: PCBs and mercury (methylmercury). A summary of PCBs and
mercury measured in fish tissue from Puget Sound is provided in OU 01 Attachment 4
(reproduced from Table 3 of DOH 2006). DOH developed meal recommendations for salmon,
English sole and other flatfish, and rockfish from Puget Sound. The specific fish consumption
advisories and meal recommendations for the Commencement Bay area (which occurs within
Recreational Marine Area 11) are provided in OU 01 Attachment 5 (Attachment KK-3
[reproduced from Table 11 of DOH 2006]). The consumption advisory and meal
recommendations for English sole are the most relevant to the evaluation of sediment
17
contamination in the CB/NT Site.
While a summary of the fish advisories is provided below, the full advisory should be reviewed
for details:
• Salmon - See Page 3 of Fact Sheet in OU 01 Attachment 5 (Attachment KK-9 [DOH
Fish Consumption Advice Fact Sheet]).18
• Flatfish including English sole, starry flounder, and rock sole.
o No more than 2 meals per month in Inner Commencement Bay (SE of imaginary
boundary between Sperry Ocean dock and Cliff House Restaurant).
o No more than 1 meal per week in Outer Commencement Bay (SE of imaginary
boundary between Boathouse Marina and Brown's Point).
• Rockfish (based on contaminant levels in brown, quillback, and copper rockfish).
o No more than 2 meals per month in Inner Commencement Bay (SE of imaginary
boundary between Sperry Ocean dock and Cliff House Restaurant).
o In addition to contaminant concerns, non-tribal harvest of yelloweye and canary
rockfish is prohibited for conservation purposes.
4.8.1.3 Crab Consumption A dvisories
For crab, DOH provides consumption advisories on these species at their website (available at
the link below by clicking on "Puget Sound"):
present at higher levels in older (i.e., rockfish) and larger fish because these metabolically-resistant contaminants
can bioaccumulate over time (i.e., exposure time is greater in older fish). Further, contaminants biomagnify
(chemical concentrations increase in species toward the top of the food chain) as fish grow and consequently feed on
higher trophic level prey (Rand 1995)."
17 English sole are demersal species that live on the bottom where they are exposed to contaminants in sediments
and prey species at the site. PCBs in tissue of English sole reflect conditions in the sediments where they live.
English sole are more prevalent than rockfish in the Commencement Bay waterways, and historical data for English
sole were collected in and near the waterways prior to and after the remedial action. Salmon are a migratory
species, and accumulate most of their body weight and associated burden of contaminants while foraging in marine
waters (O'Neill et al. 1998).
18 http://www.doh.wa.gOv/Portals/l/Documents/Pubs/334-098.pdf
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• http://www.doh.wa.gov/CommunitvandEnvironment/Food/Fish/Advisories.aspx
The consumption advisory for crab in Puget Sound states:
• "Crab: Eat Dungeness or red rock crab from non-urban areas of Puget Sound. Don't eat
the crab butter or viscera. Viscera are the internal organs under the shell. If you cook
crab in boiled water, don't use the water for soup stock, broth, or gravy. Limited data
show that crab from industrial urban areas contain more contaminants than those from
non-urban areas, and crab butter has more contaminants than crab muscle."
http://www.doh.wa.gov/CommunitvandEnvironment/Food/Fish/Advisories.aspx
Due to limited crab tissue data, DOH does not have specific definitions or boundaries for urban,
near-urban, or non-urban areas in Puget Sound. For geographical boundaries of urban and near-
urban areas, DOH often refers to the Shellfish Safety Information maps (link follows) with the
understanding that this is likely to be over protective for crab.
• http://ww4.doh.wa. gov/scripts/esrimap.dll?Name=bioview&Step=l
Also, the Washington Department of Fish and Wildlife (WDFW), who regulates crab harvesting
in Puget Sound,19 identifies State and County Fish Advisories and Consumption Advice in 2013
regulations posted at their website:
• http://wdfw.wa. gov/publications/013 84/wdfwO 13 84.pdf
The WDFW 2013 regulations provide a link to Washington DOH consumption advisories (as
listed above), and in addition, WDFW describes Safe Handling Practices for crab:
• "Crab can also concentrate pollutants in their internal organs (crab butter). Clean crab
before cooking. Eat only the meat."
http://wdfw.wa. gov/publications/013 84/wdfw013 84.pdf
[See WDFW 2013 regulations, p. 124; excerpt provided in OU 01 Attachment 5 (Attachment
KK-10)]
Regarding the DOH crab advisory for Puget Sound, DOH (McBride 2012a) clarified that the
crab advisory posted on the DOH website is a precautionary advisory due to the general
understanding of pollution in urban areas and the limited availability of specific contaminant
data for crab tissue from Puget Sound. In 2011 and 2012, crab and spot prawn samples were
collected in Puget Sound (including one station in Commencement Bay) by WDFW for analysis
of contaminants. Tissue analyses began in Fall 2012, and analytical data are scheduled to be
available by Spring 2013 (McBride 2012b). DOH will assess these data to address potential
health impacts to humans who eat crab and spot prawn from Puget Sound.
19 WDFW establishes schedules (including closures) for recreational crab fishing in the Commencement Bay area,
which is identified as Marine Area 11.
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DOH (McBride 2012b) advises that crab from Commencement Bay should not be eaten until
new data have been collected and evaluated and DOH has determined that a modification to the
advisory is warranted.
4.8.1.4 Shellfish Consumption Advisory
DOH and WDFW have closed all beaches in the Commencement Bay area, as well as many
other nearshore areas in Puget Sound, for the harvesting of clams, mussels, and oysters due to
health restrictions (see WDFW regulations and DOH advisories in OU 01 Attachment 5
[Attachment KK-10]). DOH and TPCHD have issued "A guide to SAFE shellfish harvesting in
Pierce County" (see OU 01 Attachment 5 [Attachment KK-11]). The DOH Shellfish and Water
Protection Office (SWPO) is concerned about harm to human health based on high coliform
counts, and previously issued a "Do not eat shellfish" advisory due to biological pollution in the
Commencement Bay waterways (see December 26, 2008 memorandum in OU 01 Attachment 2).
Contaminant concentrations in shellfish (e.g., clams, mussels, and oysters) tissue are not being
evaluated as part of this FYR.
4.8.1.5 Summary of Fish and Crab Consumption Advisories
While the DOH fish and crab advisories and meal recommendations for Puget Sound are
intended to limit human exposure and are considered to be a good tool available to do so,
consumption advisories are not enforceable under law. A consumption advisory is not a
20
regulation, but rather a voluntary recommendation issued to inform people. Throughout Puget
Sound, including Commencement Bay, there is anecdotal evidence that some people do not
follow the consumption advice provided in the advisories.
After reviewing the status of the remedial actions in the CB/NT Sediments OU, it is EPA's
assessment that the overall remedy for sediments is expected to be protective once all actions
(including monitored natural recovery) are complete. In the interim, until site remedial
objectives are met [see Section 4.1.1], site use restrictions (i.e., fish and shellfish consumption
advisories) shall remain in effect to limit human exposure to contaminated seafood.
4.8.2. Progress since the Last Five-Year Review
Since the last Five-Year Review, EPA has summarized relevant historical fish and shellfish
tissue data for the nearshore Commencement Bay area. Due to workload restraints, EPA was
unable to prepare or implement a sampling and analysis plan for fish and/or crab near the
Hylebos and Thea Foss Waterways of the CB/NT Site. EPA intends to develop a plan to assess
contaminant concentrations in fish and/or crab tissue data to evaluate progress toward achieving
remedial objectives (e.g., do data suggest a reduction in contaminants in seafood tissue?) and to
provide data that may be used by DOH in their assessment of fish and shellfish advisories and
21
meal recommendations for the Commencement Bay area. Some of the historical data
evaluated by EPA in this report are the same data evaluated by DOH (2006) in their health
assessment for advisories.
20 http://water.epa.gov/scitech/swguidance/fishshellfish/fishadvisories/archive/2003_index.cfm
21 Washington DOH is the state agency responsible for decisions on whether advisories are continued, modified, or
removed.
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This FYR summarizes historical fish tissue (muscle) data for English sole (Parophrys vetulus)
and for Dungeness crab (Cancer magistef) and red rock crab (Cancerproductus). These species
were selected for the sampling and analysis plan for the following reasons:
• English sole and crab are demersal species that live on sandy and muddy bottoms in
estuaries and nearshore areas where they may be exposed to contaminants in sediments
and prey species at the site. PCBs in tissue of English sole and crabs reflect conditions in
the sediments where they live.22'23
• These species are generally considered non-migratory, and they have more site fidelity
than salmonids.
• English sole and crab tissue data were collected in Commencement Bay in 1984 for the
RI.
• English sole and crabs are consumed by fishers. English sole were used by DOH to
develop fish consumption advisories and meal recommendations for English sole and
other flatfish in Puget Sound.
• The Puget Sound Assessment and Monitoring Program (PSAMP) and WDFW have
collected English sole data at the mouth of Thea Foss Waterway since 1989, which
allows for potential trends analyses in contaminant concentrations in fish tissue.
For this FYR, historical tissue data are summarized for two contaminants: PCBs and mercury.
PCB tissue data are summarized because the CB/NT Sediment Quality Objective for PCBs was
based on the human health risk assessment (see Sections 4.1.1 and 4.8.1 of this Five-Year
Review), and in the CB/NT ROD, PCBs were identified as a problem chemical in sediments in
two waterways: Hylebos Waterway and Thea Foss Waterway (EPA 1989; EPA 1997). While
limited, the RI (1985) stated that the English sole and crab tissue data showed that those two
waterways consistently had the highest concentrations of PCBs in tissue. Historical PCB tissue
data are available for total PCBs (Aroclors) and PCB Congeners. Over the years, various
22 From http://wdfw.wa.gov/conservation/research/projects/marine_toxics/englishsole.html: Much of the research
on contaminant accumulation in fish in the Puget Sound has focused on English sole. These demersal fish are
moderately long-lived (age of the oldest English sole collected by the Fish Component was estimated at 21 years),
have a close association with the bottom sediments, consume benthic invertebrates, and have relatively restricted
movements associated with seasonal migration for reproduction. These characteristics suggest that their probability
of exposure to persistent bioaccumulative toxins is moderately high and that they will reflect regional spatial
patterns of contamination in bottom sediments. Also, because they are purchased from the commercial fishery and
are captured and consumed by some anglers, English sole represent a food-web pathway through which
contaminants can move from sediments to humans.
23 From http://wdfw.wa.gov/conservation/research/projects/marine_toxics/dungenesscrab.html: Dungeness crab are
an important predator and prey organism at all life history stages. They have pelagic larvae (zoea and megalops
stages) which are preyed on by many fishes, including copper rockfish and Co ho and Chinook salmon. Being
planktivorous, the larvae may be exposed to pollutants that are present in the water column and plankton. Once they
molt into the juvenile stage, they become demersal, feeding in the benthic food web. They can readily adjust their
diet, but the younger/smaller crabs generally eat mollusks, progressing to shrimp and then to fish as they age and
grow. The adults have developed an evolutionary niche for feeding on mud-sand substrate, thus providing a food-
web pathway through which contaminants can move from sediments to humans. Dungeness crabs are relatively
short-lived with a maximum lifespan of 8 to 10 years. They move between estuaries and offshore waters seasonally.
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analytical methods for PCBs and PCB Congeners have been used, and resulting PCB data must
be evaluated in consideration of the analytical methods performed (see OU 01 Attachment 5
[Attachment KK-5, "Final meeting notes"]).
Mercury tissue data are summarized because mercury was identified in the CB/NT ROD as a
problem chemical in Middle Waterway and in the head of Thea Foss Waterway (EPA 1989). As
described previously, the Sediment Quality Objective for mercury was based on an ecological
risk assessment and was determined to be also protective of human health.
As discussed previously, PCBs and mercury are the two human health contaminants of concern
in fish and shellfish in Puget Sound according to an assessment by Washington DOH (2006).
In evaluating fish and crab tissue concentrations, it is relevant to consider home ranges of
species. The size of the home range of resident species (e.g., English sole and crab) to the entire
Commencement Bay is unclear, because no site-specific research on home ranges has been
conducted. As cited in the RI for the Lower Duwamish Waterway Superfund Site (LDWG
2003), "the unconstrained average home range of English sole, as reported by PSDDA (1988c) is
9 km . Similarly, the unconstrained home range of Dungeness crab has been reported to range
from 0.1 to 1 km per day (Breen 1985; Waldron 1958), and Ecology has used an area of 10 km2
in crab-based risk assessments performed elsewhere in Puget Sound (e.g., Bellingham Bay)."
Other considerations are that an adequate baseline data set (before cleanups were implemented)
is not available for mercury, methyl mercury or PCBs, background concentrations of mercury
and PCB tissue data are not readily available, appropriate statistical methods have not been
identified for trend analyses, and contaminant reductions in seafood tissue may or may not be
linked.
EPA has compiled available fish and shellfish tissue data, as summarized in OU 01 Attachment
5. However, a fish and shellfish sampling effort has not been implemented due to EPA resource
constraints. Thus, this issue remains as a recommendation with follow-up actions for this FYR.
4.8.3. Issues and Recommendations/Follow-up Actions
Issues and recommendations/follow-up actions that affect protectiveness for the site-wide
Sediments OU 01 are provided in Section 7.
4.8.4. Protectiveness Statement
The protectiveness statement for the site-wide Sediments OU 01 (seafood advisories) is provided
in Section 8.
4.9. CB/NT Sediments OU 1, Commencement Bay Environmental
Data
In April 2010, the Washington Department of Ecology (Publication No. 10-03-019) published
results of an environmental assessment conducted in 2008 in Commencement Bay. As stated in
the Abstract:
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"The Urban Waters Initiative (UWI) is a multi-agency program to reduce toxic chemical
pollution in selected urban bays of Puget Sound. As part of the UWI, the Washington
State Department of Ecology is assessing sediment quality throughout those bays to
determine current conditions and compare them to past conditions. These bay-scale
assessments provide information to environmental managers concerned whether and how
the collective effects of multiple localized cleanups and source controls improve bay-
wide conditions over time. In 2008 Ecology sampled Commencement Bay, including
adjoining waterways."
Surface sediment samples were collected at 30 locations throughout Commencement Bay,
including many stations located outside the waterways addressed by the CB/NT RODs (see
Figure 4-21 for locations). Each sample was analyzed to measure three different indicators of
sediment quality: sediment chemistry, sediment toxicity, and the composition of benthic
(bottom-dwelling) invertebrate assemblages. These three indicators were then combined into
Ecology's Sediment Quality Triad Index (SQTI), an important, multi-variable indicator of
sediment quality in Puget Sound. Samples were collected and analyzed for sediment chemistry,
sediment toxicity, and benthic infaunal community structure.
The report concluded:
"In 2008, approximately 15% of Commencement Bay [samples were collected in a much
larger area than addressed by the CB/NT ROD] had contaminated sediments and 35%
had adversely affected benthic communities. About 12% of the area had both. None of
the sediments were highly toxic in two kinds of laboratory tests. Overall, 61% of the area
had high sediment quality."
Comparisons with similar data from 1999 showed:
• Decreased sediment contamination by numerous toxics, primarily polycyclic aromatic
hydrocarbons and metals.
o For the 30 stations, chemical exceedances of the SQS were found at 8 stations,
and chemical exceedances of the cleanup screening level (CSL) were found at 4
stations.
o For total PCBs at the 30 stations in Commencement Bay:
¦ Total PCBs were undetected in 10 of 30 samples
¦ In 10 of the 20 samples with detected concentrations of PCBs, samples
had only single Aroclor detections slightly above the detection limit (e.g.,
Aroclor 1254 reported at 7ppb dw, with a DL of 5 ppb dw).
¦ Total PCBs exceeded the SQS at only one station throughout the
Commencement Bay area.
¦ Total PCBs did not exceed the CSL at any station.
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¦ There were too few detected concentrations ofPCBs in sediments in either
1999 or 2008 to conduct a statistical comparison.
• Increased contamination by phthalates.
• Slightly decreased toxicity.
o In the 2008 survey, two types of toxicity tests were performed: sea urchin
fertilization success and amphipod survival test. For the 30 stations, no sediment
toxicity was observed, as compared to standards.
• Improved benthic community health in the waterways, but deterioration in the central-
southeastern bay.
• Shifts from both degraded conditions and high sediment quality to intermediate
conditions, possibly reflecting both positive effects of numerous cleanups and source
controls and negative effects of habitat changes in the central-southeastern portion of the
bay.
o In 2008, none of the 30 stations were identified as degraded, as compared to the
Sediment Quality Triad Index.
The full report is available at the link:
https://fortress.wa.gov/ecv/publications/publications/1003019.pdf
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5. Remedial Actions and Five-Year Review
Process for CB/NT Asarco Operable Units 20,
22, and 19
5.1. Background
The Asarco Area Site consists of the former Asarco copper and lead smelter facility and the
surrounding areas. The Asarco Area Site was divided into three OUs, each with its own ROD, as
described below:
• Asarco Smelter Facility (Asarco Smelter) OU 20 (also known as OU 02), which consists of
the smelter property and the slag peninsula;
• Ruston/North Tacoma Study Area (Study Area) OU 22 (also known as OU 04), which
consists of contaminated properties in an approximate one-mile arc surrounding the
smelter; and
• Asarco Sediments/Groundwater (Asarco Sediments) OU 19 (also known as OU 06), which
encompasses the sediments offshore of the smelter and the Yacht Basin formed by the slag
peninsula.
See Figure 5-1 for a general map of the majority of these areas, and see Figure 5-2 for a parcel
map with taxpayer information.24
The Asarco Smelter (OU 20) is located along the Commencement Bay shoreline within the
municipal boundaries of Ruston and Tacoma, Washington. The upland portion of the Asarco
Smelter is approximately 100 acres in size and encompasses the 67-acre smelter area and the 23-
acre slag breakwater peninsula. The habitat basin is also discussed as part of this OU. Point
Ruston LLC is the taxpayer for the Asarco Smelter property, and the Metropolitan Park District
(Metro Parks) is the taxpayer for the slag peninsula. See Figure 5-1 for the areas surrounding the
slag peninsula, and see Figure 5-3 for the former Asarco Smelter upland site and the former fuel,
copper, and ore docks.
The Ruston/North Tacoma Study Area (OU 22) encompasses approximately 950 acres in a one-
mile arc around the former Asarco Smelter. The OU includes an estimated population of
approximately 5,000 people, and about 1,820 housing units. See Figure 5-4 for a map of the
Ruston/North Tacoma Study Area.
The Asarco Sediments (OU 19) encompasses the Yacht Basin formed by the slag peninsula and
the sediments offshore of the smelter. The taxpayer for the Yacht Basin is the Metropolitan Park
District, and the taxpayer for the sediments offshore of the smelter is Point Ruston LLC.
Additional offshore areas are owned by the State of Washington and are managed by DNR. See
Figure 5-5 for a map of the Asarco Sediments area.
24 Taxpayer information is publicly available; determining ownership typically requires a full title search.
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Smelter operations caused contamination of the area by releasing metals such as copper, lead,
and arsenic into the air, soil, and Commencement Bay. In addition, much of the smelter property
and the peninsula are constructed entirely of slag from the smelting process. The Ruston/North
Tacoma Study Area was contaminated primarily with arsenic and lead in soil due to airborne
emissions from smelting operations. Offshore sediments were contaminated primarily with
copper, arsenic, and lead due to smelter site runoff, contaminated groundwater discharges, and
slag spills.
5.2. Site Chronology
Information through 2009 is available in the third FYR (EPA 2009), which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
Current site chronology information, as well as a brief history of Asarco bankruptcy information,
is provided below.
5.2.1. Recent Site Chronology
5.2.1.1 Asarco Smelter
2006 -present Point Ruston LLC has been and is redeveloping the site into an upscale
waterfront community. EPA is overseeing their work to ensure that their
redevelopment activities meet the performance standards for remediation
of the Asarco Smelter site. In 2013, Metro Parks, as part of a contribution
protection claim by Point Ruston LLC, capped the slag peninsula areas that
Point Ruston was required to remediate under the Second Amendment to
the Consent Decree (2006).
2014 In September 2014, EPA began design for repair of the habitat basin that
was damaged in the 2001 Nisqually earthquake. The design to cap the
portion of the slag peninsula occupied by the Tacoma Yacht Club and for
armoring the remaining section of the slag peninsula described in the ROD
is ongoing. See further discussion in Section 5.3.2.1.2.
5.2.1.2 Ruston/North Tacoma Study Area
2009 EPA began remediation on the remaining properties.
2012 Property cleanup was completed except for a small number of refusals. The
2013 Remedial Action Report was approved by EPA for this portion of the
work (EPA 2013).
2014 A cooperative agreement was put in place with Ecology, who will handle
any future work, including institutional controls.
5.2.1.3 Asarco Sediments
2006 The Second Amendment to the Asarco Consent Decree (CD) was issued.
This 2006 amendment added Point Ruston LLC as a new party to the CD,
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
and required Point Ruston LLC to remediate the Asarco smelter, cap the
slag peninsula, cap offshore sediments, and excavate shallow sediments in
the Yacht Basin. The area for excavation of shallow Yacht Basin
Sediments in shown by the blue line in Figure 5-7.
2010 EPA began evaluating options for remediating the Yacht Basin sediments.
As of 2014, no remedial work in the Yacht Basin has occurred.
2011 Washington State DNR, as part of a contribution action by Point Ruston
LLC, demolished the fuel, ore, and copper docks (see Figure 5-3) along the
Asarco Smelter shoreline and placed a 1.6-acre quarry spall cap over the
sediments where the docks had been. This work was required of Point
Ruston LLC under the Second Amendment to the Consent Decree (2006).
DNR manages the State-owned aquatic land where the ore and copper
docks were located. Point Ruston LLC owns the upland site and the aquatic
lands where the fuel (north) dock was located.
2013 Point Ruston LLC placed a 3-foot-thick layer of clean riprap over
approximately 6.1 acres of contaminated sediment and placed a 3-foot-
thick layer of clean sand and gravel over approximately 1.9 acres of
contaminated sediment in Commencement Bay, for a total of 8 acres
capped (see Figure 5-8).
5.2.2. Asarco Bankruptcy Information and Summary of Enforcement
Actions
Prior to 2005, Asarco was the responsible party required by a 1997 CD and subsequent
amendments to the CD to remediate the former Asarco Smelter property, the slag peninsula, the
Yacht Basin, the Ruston/North Tacoma Study Area, and sediment contamination in
Commencement Bay. Following the Asarco bankruptcy, EPA took responsibility for the
Ruston/North Tacoma Study Area and the Yacht Basin, and Point Ruston LLC purchased the
Asarco Smelter property. As a condition of the purchase, the United States in 2006 amended the
1997 Consent Decree with Asarco to require Point Ruston LLC, as the new owner, to remediate
the former Asarco Smelter property, cap the slag peninsula, cap offshore sediments, and excavate
a small area of shallow sediments in the Yacht Basin (USDC 2006). The general chronology is
below.25
1997 Asarco entered into a CD to cleanup up the Asarco Tacoma Smelter site.
2000 First amendment to CD occurred, stipulating penalties for Asarco's failure to
achieve specified milestone dates.
2003 Asarco and its parent company, Grupo Mexico, signed a CD with the
United States deferring enforcement of their national environmental
liabilities in exchange for setting up a $100 million trust fund (the Trust) to
25 For more detailed Asarco bankruptcy information prior to 2009, see pages 148-149 of the third FYR.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
be used for Asarco's environmental liabilities around the country.
Asarco declared bankruptcy.
Asarco sold 97 acres of its property in Tacoma and Ruston, WA, to MC
Construction Consultants, who in turn assigned their rights to Point Ruston
LLC.
The Second Amendment to the CD was issued. This 2006 amendment
added Point Ruston LLC as a new party to the CD, and required Point
Ruston LLC to remediate the Asarco smelter, cap the slag peninsula, cap
offshore sediments, and excavate shallow sediments in the Yacht Basin.
The Schedule for Implementation for these activities is below.
The Bankruptcy Court for the Southern District of Texas, Corpus Christi
Division, issued the Amended Settlement Agreement Regarding
Miscellaneous Federal and State Environmental Sites (USBC 2009a). The
bankruptcy court approved a settlement of $27 million plus interest between
Asarco and the United States for the three operable units related to the Asarco
Area Site.
Schedule for Implementation
Table 5-1 below provides the implementation schedule for Point Ruston LLC that was provided
in the statement of work (SOW) that accompanied the 2006 Second Amendment to the Asarco
CD. The SOW described how Point Ruston LLC would implement the remedial requirements
(EPA 2006a). The inferred dates for when work should have been completed, as well as the
actual status of completion, have been added. Because the project has been delayed, a new
schedule will be negotiated between EPA and Point Ruston LLC.
Table 5-1. 2006 Implementation Schedule for Point Ruston LLC for Remedial Action
Action Required
Due
When Work Should
Have Been Completed
Year of
Actual
Completion
Cap Nearshore/Offshore Sediment
with Sand/Silt Cap (apprx. 10.5 acres)
One year from effective date of
Second Amendment
2007
2006-2007
Cap Slag Peninsula
Prior to EPA Certification of the
First Phase (October 30, 2008)1
October 30, 2008
2014
Construction of temporary site cap
Prior to EPA Certification of the
First Phase (October 30, 2008)1
October 30, 2008
2014
Excavation of shallow sediments in
Yacht Basin per SOW requirements
Prior to EPA Certification of the
Second Phase (No later than
November 15, 2009)1
November 15, 2009
Not started
Site Cap 50 percent complete
Four years from effective date of
Second Amendment
2010
Ongoing
Complete Site Cap
Seven years from effective date of
Second Amendment
2013
Ongoing
Complete Sediment Cap 2
Seven years from effective date of
Second Amendment
2013
2013
1 Certification refers to EPA issuing a Certification of Completion for a phase of the project. Certification must be
issued before occupancy is allowed.
2 This sediment cap was also referred to as the "hard cap" in the third FYR.
2005
2005
2006
2009
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5.3. Remedial Actions
5.3.1. Remedy Selection
Three RODs were prepared for the Asarco Area Site, one each for the Asarco Smelter (1995), the
Ruston/North Tacoma Study Area (1993), and the Asarco Sediments/Groundwater (2000). In
addition, one ESD (1996) has been issued for the Asarco Smelter Facility, and one ESD (1994)
has been issued for the Ruston/North Tacoma Study Area.
5.3.1.1 Asarco Smelter
The selected remedy in the ROD is summarized below:
• Excavation of soil and granular slag from five source areas. Soils that fail the Toxic
Characteristic Leaching Procedure (TCLP) will be excavated from stack hill, the
cooling ponds, arsenic kitchen, the former copper refinery, and fine ore bins
building, and disposed of on site.
• Construct a RCRA Subtitle C on-site containment facility (OCF) on the property for
disposal of contaminated material from the source areas. The facility will be
designed to hold approximately 240,000 CY of material.
• Construct surface and groundwater diversion and controls to protect the OCF from
water infiltration.
• Grade and prepare site for capping using residential material from the Study Area as
sub-base.
• Incorporate plans for future development into the cap design.
• Armor the shoreline around the plant site to prevent further erosion of the shore.
• Mitigate for shoreline armoring activities where they adversely impact intertidal
lands.
5.3.1.2 Ruston/North Tacoma Study Area
The remedy addresses the principal threat posed by soil and dust in the Study Area, and contains
the following elements:
• Designation of "action levels" for arsenic or lead in soil. Engineering measures will
address properties or areas that exceed action levels.
• Sampling of individual properties to determine if soil exceeds the action levels.
• Excavation and off-site disposal of contaminated soil and slag from properties that
exceed action levels. Contaminated soil below 18 inches will not be excavated but
will be capped.
• Replacement of excavated soil and slag with clean soil and gravel.
• Asphalt capping or soil removal and replacement with gravel of contaminated dirt
alleys and parking areas.
• Fencing and planting low lying shrubs in steep areas that cannot be excavated.
• Soil collection program for soil above action levels that is not excavated during the
cleanup (e.g., soil below 18 inches that is uncovered in the future).
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• The development and implementation of Community Protection Measures (CPMs).
CPMs are administrative requirements that will address soil that is not excavated but
that contains concentrations of contaminants above 20 parts per million (ppm)
arsenic and 250 ppm lead, but below the 230 ppm arsenic and 500 ppm lead action
levels.
5.3.1.3 Asarco Sediments/Groundwater
The selected remedy for the Asarco Sediments/Groundwater OU includes groundwater and
sediments. EPA determined in a Groundwater Task Force, comprised of Asarco, EPA, and other
regulatory agencies, that additional groundwater remedial actions, over and above those already
being implemented under the Smelter Facility ROD, were not necessary.
The selected remedy for marine sediments included the following elements:
• Dredge contaminated sediment in the Yacht Basin and place the dredged sediment
beneath a low-permeability soil cap to be constructed on the upland portion of the
Smelter Facility. The sediments will be contained under the low-permeability cap at
an elevation such that groundwater will not come in contact with the sediment. The
areas for dredging and capping are severely impacted areas where chemical
concentrations exceeded cleanup screening levels (CSLs) and multiple biological
impacts (e.g., more than one biological test exhibited a significant effect) were
observed. This also included all areas where benthic community structure indicated
a stressed environment.
• Monitor the dredged area in the Yacht Basin to verify that it does not become
recontaminated.
• Cap contaminated sediments in selected offshore areas.
• Monitor the sediment caps to confirm that they remain in place, continue to isolate
the underlying contaminated sediment, become recolonized with healthy biological
communities, and do not become recontaminated.
• Use institutional controls to prevent activities that could damage the sediment caps.
• Monitor the areas outside the capped and dredged areas to confirm that these areas
meet RAOs.
• Continue to monitor groundwater to evaluate the long-term effects that the Facility
cleanup will have on future groundwater quality.
• Implement institutional controls to restrict future use of Smelter facility groundwater.
5.3.2. Remedy Implementation
Information through 2009 is in the third FYR (EPA 2009), which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
5.3.2.1 Asarco Smelter
Remedial actions for the Smelter and slag peninsula have been occurring since the mid-1990s.
By December 2005 the OCF had been constructed and filled, all buildings had been demolished,
and most of the shoreline armoring had been completed. Recent remedy implementation
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
activities that have occurred since the third FYR for Point Ruston, the slag peninsula, and the
habitat basin are provided below.
5.3.2.1.1 Point Ruston
Since 2006, the site developer, Point Ruston LLC, under a 2006 CD with EPA, has been
transforming the Smelter site into an upscale waterfront community known as Point Ruston
(USDC 2006; EPA 2006a). The community consists of new condominiums and apartments
("Copperline"), new homes ("Stack Hill"), a Waterwalk (boardwalk), and a ferry-based event
center.26 The transformation is ongoing as of 2014. Site capping is being accomplished through
use of specially designed impermeable hardscapes, multi-layer RCRA-compliant caps and
building foundations to meet the performance standards for remediation of the Asarco Smelter
site.
As of February 2014, the following progress has been made on the Smelter site remediation.
Master infrastructure for Point Ruston was constructed site-wide, which included main-line
water infrastructure; public and private sewer and storm water-sewer conveyance systems; and
electrical, gas, and communication systems.
The fuel, ore, and copper docks that extended from the Smelter into Commencement Bay were
demolished. Shoreline armoring in Commencement Bay was constructed in areas that were not
accessible when the docks were present.
The Waterwalk portion of the remediated Smelter site, which is approximately 100 feet wide
(from the edge of the shoreline armoring to approximately 100 feet inland) and nearly a mile
long, was remediated using a multi-layer cap composed of a geocomposite clay liner (GCL), 40-
mil high-density polyethylene (HDPE), a drainage net, 9 inches of clean backfill, a woven
marker layer, and 9 more inches of clean fill. Asphalt, cement concrete, or vegetation was placed
on top of the clean fill depending on the final surface design.
Phase 1 remediation was completed and consisted of construction of the Copperline apartments
and condominiums (Building 2A); the foundation slab for Building 2B located between 2A and
the Waterwalk; portions of a multi-layer cap in green areas; and hardscapes consisting of low-
permeability asphalt concrete and low-permeability cement concrete. See Figure 5-9 for a map of
the Point Ruston development.
A temporary impermeable cap (TIC) composed of welded 40-mil HDPE on a graded subsurface
was constructed over areas of the site that did not have a minimum of 6 inches of clean gravel, a
building foundation, or other permanent infrastructure in place. The TIC is held in place using
sandbags and a gravel berm located around the edge. The areas of the site that did not receive the
TIC were construction roads that had a clean gravel surface, the nursery which has up to 10 feet
of topsoil, or areas of the site where remedial action has been completed (i.e., Phase 1 areas).
The portion of Ruston Way located in Ruston, WA, and a section of Ruston Way (approximately
26 See "Lifestyle" at http://www.pointruston.com/site/ for a description of the Point Ruston redevelopment plans
including a map of the site itself, the Waterwalk, and the ferry event center (Point Ruston LLC 2014).
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
50 feet long) in Tacoma east of the Grand Avenue traffic circle was constructed using composite
GCL/HDPE liner located below a conventional asphalt road bed.
The OMMP for the site-wide cap was completed and approved by EPA (Hydrometrics 2013a),
and the Development and Occupancy Plan (DOP) was completed and approved by the EPA
(Hydrometrics 2013b). An extensive air monitoring network consisting of high-volume samplers
and real-time samplers was installed on-site and is being used to monitor air quality as
redevelopment continues. Phase 2 development, which focuses on the commercial core, is
beginning in 2014 and estimated to be completed in 2015. The details are described in the Point
Ruston Construction Management Plan, Phase 2 Remedial Action (Hydrometrics 2013 c).
5.3.2.1.2 Slag Peninsula
Approximately 15 acres of the slag peninsula have been permanently capped using the multi-
layer cap design (i.e., GCL, HDPE, drainage net, 9 inches of clean fill, woven marker layer, and
9 inches of additional clean fill). The cap extends from the tip of the peninsula to the property
line with Point Ruston, and from the Commencement Bay side of the peninsula to the fence
delineating the portion of the peninsula controlled by the Tacoma Yacht Club. Design for
capping the remainder of the Slag Peninsula (i.e., the area of the Slag Peninsula occupied by the
road to, parking areas of, and areas in front of, the Tacoma Yacht Club) is ongoing and is
expected to be implemented by EPA in 2015.
The area of shoreline around the North Tacoma outfall on the slag peninsula was armored.
About 3,500 feet of shoreline has not been armored (Griffiths 2014). As depicted in Figure 5-6,
this segment is between the red arrows along the yellow dashed line along the Yacht Basin side
of slag peninsula. EPA's consultant, CH2M HILL (2013b) recommended that this segment of
shoreline be armored. However, it should be noted that armoring of this segment is NOT
required as part of the Asarco Smelter ROD, and based on communication with Metro Parks, the
armoring might be done separately by Metro Parks. The ROD for the Asarco Smelter (EPA
1995) states: "The interior portion of the Yacht Club basin will not require armoring." In
addition, the ROD for the Asarco Sediments/Groundwater OU (EPA 2000) also does not require
armoring of the Yacht Basin; the sediments remedy for the Yacht Basin required only dredging
and upland disposal. EPA will need to determine whether armoring of the Yacht Basin is
warranted and therefore requires a ROD amendment or ESD, or whether armoring is not
warranted for this portion of the shoreline.
5.3.2.1.3 Habitat Basin
The habitat basin, which runs along the north side of the slag peninsula, was constructed by
Asarco in 1999 as part of mitigation measures for filling in intertidal areas during armoring of
the Smelter site. To create the habitat basin, a breakwater was constructed using riprap on the
outer edge of the basin (CH2M Hill 2013a), see Figure 5-6. In 2001, the Nisqually earthquake
caused a portion of the breakwater forming the habitat basin to collapse, and it was determined
that repair would cause a significant reduction in the size of the basin. Although the habitat basin
continues to function as designed without that section of breakwater, inspection by EPA and
CH2M Hill in 2013 determined that the collapsed area was causing the habitat basin to erode
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significantly. EPA evaluated repair options for the habitat basin in 2013 and determined repair
was necessary. EPA began the design in September 2014.
5.3.2.2 Ruston/North Tacoma Study Area
Sampling and cleanup of residential yards in the Ruston /North Tacoma Study Area has been
ongoing since the early 1990s. In 2009, EPA resumed work on the remainder of the residential
remediation that had not been completed by Asarco (due to Asarco's bankruptcy). The USAGE
(Seattle District), on EPA's behalf, began cleanup activities in 2009 by acquiring sampling and
construction contracts for the residential cleanups. By the end of 2012, the number of properties
sampled and cleaned up was as follows:
Number of residences, parks, and vacant
lots sampled
2,729
Three refusals in Zones 1-3
and nine refusals in Zone 4
Number of residences, parks, and vacant
lots remediated
1,984
One refusal in Zones 1-3 and
12 refusals in Zone 4
Number of right-of-ways sampled
941
Number of right-of-ways remediated
452
The cleanup of the Study Area was essentially completed in 2012, and the actions have been
documented in EPA's 2013 Remedial Action Completion Report (EPA 2013). There was a small
number (<30) of refusals (i.e., property owners who did not want their properties sampled or
remediated); those properties and all remaining work have been turned over to Ecology for
completion.The completion of the Study Area cleanup was funded by the 2003 Asarco Trust
Fund, and American Recovery and Reinvestment Act (ARRA) federal funding (EPA 201 la).
EPA used approximately $5.2 million in ARRA funds to support the cleanup activities at the
Study Area.
Steep slopes on private property that were required by the ROD to be remediated but were not
remediated due to erosion or stability concerns were noted on property maps. For a steep slope
noted on Burlington Northern and Santa Fe Railroad (BNSF) property, the area was sampled in
four locations under the Winnifred Street Bridge, and only one location exceeded action levels
(230 ppm arsenic; 500 ppm lead). EPA met with BNSF Railroad in 2012 and determined that
given the steep slopes, marginal contamination, existing fencing, and numerous "No
Trespassing" signs posted in the area, that no further action was required on this issue.
Earlier, in 1999, Ecology had determined that it no longer concurred with the cleanup decision
for the Study Area and began a separate investigation into residual contamination from smelter
operations. Ecology initiated a cleanup action in 2000 for the Tacoma Smelter Plume (TSP) and
will be performing a second remediation of the Study Area and the surrounding 1,000 square
27 For those properties, the address and owner information has been provided to Ecology for inclusion in their remediation
project. The list of properties was provided as a hard copy (Appendix 9) to EPA's 2013 Remedial Action Completion Report
(EPA 2013). That report also states that the list of properties will be revisited as part of each FYR. Ecology is currently
managing the list of refusals. Ownership records will be checked to see if new owners have purchased the property. Property
owners will be contacted again to see if they will allow sampling and/or remediation. No change to the list is needed at the time
of this review.
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miles beginning in 2013.28 Under a cooperative agreement, Ecology will complete any remaining
project tasks in coordination with EPA. Those tasks include the following:
• Remediation: Two properties will be sampled and remediated if necessary. Eight
additional properties will be remediated.
• Database: Project files have been converted and uploaded to Ecology's web-based
"Arsenic in Soil Database" located at https://fortress.wa.gov/ecv/areispublic/. Ecology will
maintain this database and add results from their project as it progresses. Users can search
this database by parcel or address to locate soil sampling results and cleanup records.
• Education: The educational program for the Study Area will be incorporated into
Ecology's on-going Dirt Alert soil safety program. EPA will fund a portion of this program
to cover the Study Area portion of the TSP.
• Soil Disposal: Long-term soil disposal options have not yet been identified. The issue will
be addressed by a workgroup of agency representatives from the Tacoma-Pierce County
Health Department (TPCHD), Ecology, EPA, and City of Tacoma Landfill.
5.3.2.3 Asarco Sediments
Prior to bankruptcy in 2005, Asarco had in 2004 completed the remedial design for capping
offshore sediments and excavating the Yacht Basin, but no progress on implementing the remedy
had occurred. The prior (2000) sampling results in the Yacht Basin conducted by Asarco, and
future plans (at that time) for the Yacht Basin cleanup, are described in Asarco's Final Design
Report for Sediment Dredging: Marine Sediments and Groundwater (Asarco 2004). In 2005
Asarco filed for bankruptcy. EPA assumed responsibility for remediation of the Yacht Basin
sediments following Asarco's bankruptcy, but some of the requirements for remediating the
Yacht Basin sediments were assigned to Point Ruston LLC. When Point Ruston LLC became the
owner of the Asarco Smelter site in 2006, Point Ruston LLC was required under the 2006
Amendment to the Asarco CD with EPA to cap the offshore sediments with a sediment cap,
complete the hard cap (the part of the sediment cap that joins the sediment cap with the shoreline
armoring), and excavate shallow sediments in the Yacht Basin (in addition to its Smelter Facility
responsibilities).
As of 2009, the following actions still needed to be completed in the Sediments OU: 1) limited
offshore capping in Commencement Bay where the ore and copper docks had been, 2) hard
capping in Commencement Bay by Point Ruston LLC, 3) excavation of shallow Yacht Basin
sediments by Point Ruston LLC, and 4) remediation of remaining Yacht Basin sediments by
EPA. The status of each item is discussed below.
5.3.2.3.1 Offshore Capping in Area of Former Fuel, Copper, and Ore Docks in
Commencement Bay
Between November 2006 and February 2007, Point Ruston LLC placed approximately 10 acres
of sediment to cap offshore sediments, but at that time Point Ruston LLC could not reach areas
28 Information on Ecology's cleanup can be viewed on Ecology's Toxics Cleanup Program page,
http://www.ecY.wa.gov/programs/tcp/sites brochure/tacoma smelter/2011/ruston.html
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under the fuel, copper, and ore docks in Commencement Bay because the pilings blocked the
sediment capping materials from entering between them. In July 2009, Point Ruston LLC and
DNR were working together to remove the docks. In 2011 the Washington State DNR
demolished the docks and placed a 1.6-acre quarry spall cap over the sediments where the docks
had been, effectively completing the offshore capping. See Figure 5-10 for the areas capped by
DNR (Parametrix 2011).
5.3.2.3.1 Hard Capping in Commencement Bay
In 2013 in Commencement Bay, Point Ruston LLC completed their requirements for a hard cap
by placing a 3-foot-thick layer of clean riprap over approximately 6.1 acres of contaminated
sediment and a 3-foot-thick layer of clean sand and gravel over approximately 1.9 acres of
contaminated sediment, for a total of 8 acres capped. See Figure 5-8 for the areas capped by
Point Ruston LLC.
5.3.2.3.2 Excavation of Shallow Yacht Basin Sediments by Point Ruston LLC
As of 2014, Point Ruston LLC still needs to excavate the shallow Yacht Basin sediments. The
details for Point Ruston's Yacht Basin responsibilities can be found in Section 2.8 of the 2006
Final Statement of Work for Remedial Design and Remedial Action (EPA 2006a); the SOW is
associated with the 2006 CD.29
5.3.2.3.3 Remediation of Remaining Yacht Basin Sediments by EPA
EPA is responsible for remediating the remaining Yacht Basin sediments (e.g., non-shallow
sediments) and will use settlement trust funds to accomplish the work. As of 2014, no remedial
actions have been implemented. However, in January 2010, EPA met with its consultant (CH2M
Hill), the Washington Department of Fish and Wildlife, and Ecology to evaluate Asarco's 2004
final design documents for dredging of Yacht Basin marine sediments and to brainstorm
potential options for the site. The results of the evaluation are presented in CH2M Hill's
February 2010 technical memorandum (CH2M Hill 2010a) and summarized here. Part of the
2000 ROD for OU 19 was to dredge contaminated sediments in the Yacht Basin and the North
Shore hot spot area, and place the dredged material beneath a low-permeability cap on the upland
portion of the adjacent Asarco facility. The RAO in the ROD for the Yacht Basin sediments is to
restore and preserve aquatic habitats by limiting and/or preventing the exposure of environmental
receptors to sediments with contaminants above the 1991 Washington State Sediment
Management Standards (SMS, WAC 173-204), originally adopted in 1991 and amended in 1995.
29 The SOW language specific to Point Ruston LLC's Yacht Basin responsibilities states in Section 2.8.1 and 2.8.2,
"For the purpose of remediation under this SOW, dredging the shallow sediments in the Yacht Basin has been
separated from the dredging of the deeper sediments in the Yacht Basin. As described below, Point Ruston shall
implement the excavation of these shallow sediments. Remaining sediment remediation in the Yacht Basin shall not
be the responsibility of Point Ruston and shall be addressed separately by others... .Point Ruston shall excavate the
nearshore shallow sediments on the southwestern shoreline of the Yacht Basin which could be contacted by
recreational users. Sediments shall be excavated above the MLLW tide line (0 MLLW) to a minimum depth of 12
inches. Excavation limits shall extend from the MLLW tide line to existing bulkhead or tidal grid at the northern end
of the southwestern shoreline and from the MLLW tide line to existing bulkhead, shoreline or tidal grid on the
southern end of the southwestern shoreline. Existing bulkheads and tidal grids will not be removed."
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Contaminants of concern presented in the ROD and associated cleanup levels included arsenic
(93 mg/kg), copper (390 mg/kg), lead (450 mg/kg), and zinc (410 mg/kg).
The 2010 evaluation determined that the remedy could not be implemented as currently designed
because the planned upland Asarco disposal site was no longer available (i.e., it was now owned
by Point Ruston LLC and has been capped), and off-site disposal options could cost more than
$20,000,000. Another challenge with remediating the Yacht Basin sediments was the need to
temporarily relocate the vessels and infrastructure in the Yacht Basin (up to 500 boats and 300
boat houses).
Regarding choices for another disposal site, the evaluation team considered the following
options:
• Use the adjacent slag peninsula;
• Develop an extension of the OCF at the adjacent Asarco site;
• Buy back a part of the former Asarco property from Point Ruston LLC;
• Construct a new nearshore confined disposal facility (CDF), possibly along the north
shore;
• Select an off-site landfill based on waste characteristics (e.g., landfill in Pierce County,
Klickitat County, or in Oregon); or
• Consider a mitigation approach by reducing dredging within the Yacht Basin and
implementing in-kind restoration elsewhere to achieve equal or better environmental
benefit.
Regarding the challenge of remediating sediments under the vessels and infrastructure, the team
considered the following options:
• Dredge only the "fairways" (i.e., open-water boat channels between the boat docks in the
marina areas);
• Outside of the fairways, cap beneath the boathouses; possibly use environmentally friendly
material (e.g., underwater mats such as AquaBlok™); or
• Use articulated dredging equipment.
In December 2010, EPA's designers prepared a cost comparison of on-site and off-site disposal
options for the Yacht Basin sediments (CH2M Hill 2010b). The estimated volume of sediments
was 48,000 to 63,000 cy. The on-site option considered placing the sediments in a disposal cell
in a 10-acre area on the slag peninsula; the off-site option considered using landfills in Oregon or
Washington that could accept solid waste (i.e., it was assumed the sediments would not be
hazardous or dangerous). The rough order of magnitude for the cost of the on-site option was
approximately $5,000,000. The cost of the off-site option was between $10,290,000 and
$11,490,000.
In a subsequent December 2010 memo (CH2M Hill 2010c), EPA's designers noted that Metro
Parks Tacoma had development plans for the slag peninsula that might allow only 15,000 to
23,000 cy of sediments to be disposed under the cap to be installed on the slag peninsula. Thus,
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
EPA's designers developed a hybrid disposal option that would place 23,000 cy of sediments
under the cap on the peninsula, and dispose of the remaining 40,000 cy of sediments at an off-
site landfill. The estimated costs for the hybrid disposal option were approximately $6,700,000 to
$7,200,000, depending on the location of the off-site landfill. As of 2014, EPA has not decided
how the Yacht Basin sediments will be remediated or disposed; thus, this portion of the ROD
remedy has not yet been constructed.
5.3.3. Post-Construction Monitoring/Operation and Maintenance
The Asarco Smelter cleanup is being completed in phases as Point Ruston LLC redevelops the
site. For the portions that have been redeveloped, operations and maintenance activities have
begun. There is an OMMP that addresses scheduled inspections and maintenance and repair of
the Smelter site cap, the OCF, and the portion of shoreline armoring on Point Ruston's property;
it also addresses maintenance of the slag peninsula cap (Hydrometrics 2013a). A Development
and Occupancy Plan (DOP) was also created that describes the health and safety controls
required for each element of the remedial action that will be implemented as Point Ruston carries
out phased development and occupancy of the site (Hydrometrics 2013b).
The Ruston/North Tacoma Study Area yards cleanup is considered complete by EPA, and any
additional work has been transferred to Ecology as of January 2014.
For the Asarco sediments, offshore capping work was done in 2006-2007 (by Point Ruston
LLC), in 2011 (by Washington DNR), and in 2013 (by Point Ruston LLC). For the areas capped
by Point Ruston LLC, their post-construction monitoring requirements are summarized in
Section 2.8.3 of the 2006 Final Statement of Work for Remedial Design and Remedial Action
(EPA 2006a).
As stated in that document, long-term monitoring shall be conducted on the sediment cap to
confirm that it remains in place, continues to isolate the underlying contaminated sediments, and
does not become recontaminated with site contaminants. After Point Ruston completes
construction of the sediment cap required in a phase and EPA issues a Certification of
Completion for that phase, Point Ruston shall no longer be required to meet performance
standards with respect to the capped sediments (including making repairs to correct the effects of
recontamination, settling, subsidence, erosion, physical disturbances, or other forces); provided
however, that if the sediment cap does not meet performance standards at the completion of the
Remedial Action, then EPA may withdraw its Certification(s) of Completion for the cap until
either (i) Point Ruston demonstrates that its actions were not responsible for the cap no longer
meeting Performance Standards, or (ii) Point Ruston takes those actions necessary to again meet
Performance Standards. In a 2014 Consent Decree with EPA, Washington DNR is taking over
O&M requirements for the offshore sediments owned by DNR.
Since no work has been done on the Yacht Basin sediments, O&M activities have not yet been
implemented for that area.
5.4. Progress since the Last Five-Year Review
This section provides the previous protectiveness statements and an evaluation of the issues
identified in the third FYR.
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5.4.1. Previous Protectiveness Statements
The Asarco Smelter protectiveness statement in the third FYR (2009) stated:
"Remedial actions at the Asarco Smelter are expected to be protective of human
health and the environment when the remedy is completed. In the interim,
exposure pathways that could result in unacceptable risks are being prevented
because the site is fenced and access to the site is controlled by cell phone
operated gates, monitoring during the day, and police patrols in the evenings.
Dust control and other dust suppression activities (temporary capping, spraying
tackifiers) are used to ensure that site contaminants remain on site."
The Ruston/North Tacoma Study Area protectiveness statement in the third FYR (2009) stated:
"Remedial actions for the Ruston/North Tacoma Study Area are expected to be
protective of human health and the environment when the remedy is completed.
In the interim, exposure pathways on the unremediated properties are only
controlled through the compliance with the education program (hand washing,
wetting soil, etc.)."
The Asarco Sediments protectiveness statement in the third FYR (2009) stated:
"Remedial actions for the Asarco Sediments are expected to be protective of human
health and the environment when the remedy is completed. For the area of sediments
offshore of the Smelter where capping has been done, the remedy is already protective of
human health and the environment. For the remaining sediments offshore of the Smelter
and the Yacht Basin, implementation of the remedy is expected to occur in the next two
to three years using money obtained from the Asarco bankruptcy settlement."
5.4.2. Status of Recommendations
Table 5-2 below presents the issues and recommendations made in the third FYR (2009) and
provides a progress evaluation for the Ruston / North Tacoma Study Area (OU 4, now OU 22);
and the Asarco Sediments (OU 6, now OU 19). There were no issues or recommendations in the
third FYR for the Asarco Smelter Facility (OU 2, now OU 20). Much of the progress for the
Ruston/North Tacoma Study Area (OU 22) was documented in EPA's 2013 Remedial Action
Completion Report (EPA 2013). It should be noted that the habitat basin was incorrectly
associated with OU 6 in the issues and recommendation tables in the third FYR. The habitat
basin should be associated with OU 20.
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Table 5-2. Recommendations for Asarco 0
Us from the Third FYR and Progress
Issue 1
Recommendations /
Follow-Up Actions
Responsible
Party /
Oversight
Agency
Planned
Completion
Dale
Progress
OUs 2, 4, 6: Ruston/North
Tacoma Study Area. Based
on phone calls received by
EPA and Ecology, there is
a subset of the people in
the study area who do not
know anything about the
site, the fact that yards in
the study area may be
contaminated, the yard
cleanup program and the
required institutional
controls.
Review the
institutional controls
(ICs)/education
component for the
Ruston/North Tacoma
Study Area and
determine what
changes are needed to
ensure that people are
aware of the controls
and that they are
carried forward.
EPA / EPA
January
2011
OU 22: As of 2014,
ICs/educational
responsibilities have been
transferred to Ecology. The
educational program for the
Study Area will be
incorporated into Ecology's
on-going Dirt Alert soil
safety program. EPA will
fund a portion of this
program to cover the Study
Area portion of the TSP.
OUs 2, 4, 6: Ruston/North
Tacoma Study Area. The
site development may
bring new people as well
as different land uses to the
area. This could result in
differing exposures than
those currently accounted
for in the ROD.
Review ongoing site
and area development
and ensure that
changes in the area do
not impact remedy
protectiveness.
EPA/EPA
Ongoing
OU 22: The Study Area and
former smelter site have
generally been developed or
have approved development
plans that remain residential
or commercial in nature. No
major changes in use are
expected. Exposures remain
similar to those analyzed in
the ROD, thus the remedy
will remain effective.
OUs 2, 4, 6: Ruston/North
Tacoma Study Area. There
may be recontamination of
the yards that have been
remediated in the Study
Area.
Resample a subset of
properties to ensure
that recontamination
has not occurred.
EPA/EPA
June 2010
OU 22: Resampling
occurred in 2011 and the
results are documented in
EPA's 2013 Remedial
Action Completion Report.
The report concluded that
the remedy effectively meets
the goal of bringing the
average soil exposures
below 230 ppm arsenic and
500 ppm lead, and that the
remedy remains effective
overtime.
OUs 2, 4, 6: Ruston/North
Tacoma Study Area.
Potential for properties
outside the Study Area to
be contaminated is being
addressed by Ecology.
EPA will document
these activities.
EPA/EPA
January
2011
OU 22: A 2014 cooperative
agreement exists between
EPA and Ecology that
describes how any
additional work will be
accomplished by Ecology.
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Table 5-2. Recommendations for Asarco OUs from the Third FYR and Progress
(continued)
I r< r< i i ri D «i«innn / D rtnniU 1^ D liinnnrl D fr-i ii
Issue 1
Recommendations /
Follow-Up Actions
Responsible
Party /
Oversight
Agency
Planned
Completion
Dale
Progress
OUs 2, 4, 6: Ruston/North
Tacoma Study Area.
Ecology has requested that
EPA review the remedy for
the site to ensure that it is
still protective.
EPA has agreed to
conduct a more in
depth review of the
remedy for the site to
ensure its
protectiveness. This
review will be
completed by July 27,
2010. The review will
use the criteria in the
"Comprehensive Five-
Year Review Guidance
(OSWERNo. 9355.7-
03B-P, June 2001 and
also consider strategies
that Ecology has
developed for
addressing arsenic and
lead throughout the
State and within the
Tacoma Smelter
Plume.
EPA/EPA
August 2010
OU 22: EPA prepared a
report on January 27, 2011
to evaluate the
protectiveness of the remedy
(EPA 2011b). EPA
concluded that the remedy is
still protective. EPA also
noted that more properties in
Zone 4 required remediation
than were predicted at the
time of the ROD; thus
required remediation (rather
than voluntary sampling)
was expanded to include
Zone 4 and has been
completed (except for a few
refusals).
OUs 2, 4, 6 Sediments:
The habitat basin is
functioning as designed
even though part of the
breakwater collapsed in the
2001 Nisqually earthquake.
Because the "shelf'
holding the breakwater is
no longer there,
replacement would require
a significant reduction in
size of the habitat basin.
EPA will need to
determine whether the
habitat basin should be
repaired or left as it is.
EPA/EPA
January
2011
OU 20: EPA has decided to
repair the habitat basin, and
began the design work in
September 2014.
1 - The text is taken from Table 23 of the third FYR, which did not specify the exact OU, but instead combined all the OUs
together as "2,4, 6."
5.5. Five-Year Review Process
5.5.1.1 Administrative Components
The Asarco Area Site FYR team was led by Karen Keeley and Kevin Rochlin, the EPA RPMs in
Region 10. Veronica Henzi (environmental engineer) and Karah Haskins (physical scientist)
with USACE, Seattle District, assisted with the review as representatives of the support agency.
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By December 2013, the review team had been formed and the review schedule had been
established for the following activities:
• Interviews and community notification and involvement;
• Document collection and review;
• Data assessment/analysis;
• Site inspection; and
• FYR report development and review.
The FYR has a statutory completion date of December 23, 2014.
5.5.1.2 Community Involvement
On January 17, 2014, a display advertisement ran in the Tacoma News Tribune newspaper
providing notification and contact information for the FYR. In addition, on January 21, 2014,
EPA Community Relations staff sent postcards to stakeholders and neighbors included on the
CB/NT project mailing list (approximately 1,150 addressees), providing notification about the
FYR process. Both notifications requested that any information that people would like EPA to
consider during the review be provided to EPA before April 15, 2014.
On February 19, 2014, Kevin Rochlin, Bill Ryan, and Jonathan Williams (all with EPA Region
10) met with Bill Andersen, the Executive Director of Citizens for a Healthy Bay, at which time
EPA provided information on CB/NT activities and preparation of the fourth FYR. A telephone
interview was completed with CHB.
No input was received from the public for the overall CB/NT site or for the Asarco Area Site.
5.5.1.3 Document Review
A review of reports pertinent to this FYR was conducted by the review team. The types of
documents reviewed included decision documents, construction management plans, completion
reports, technical memoranda, and other supporting materials. See Attachment 1 for OUs 20, 22,
and 19 for a complete list of documents reviewed for the Asarco Area Site.
5.5.1.4 Data Review and Evaluation
Data reviewed and evaluated as part of the document review is summarized throughout Section 5
but concentrated in Section 5.3.
5.5.1.5 Site Inspection
Asarco Smelter: EPA holds construction meetings and inspections of the site on a regular basis
(every 2 to 3 weeks). Participants include EPA oversight personnel, Point Ruston LLC and their
contractors, and Ecology. Additional biweekly meetings are held with personnel from the city of
Tacoma and Town of Ruston who work on the site. Therefore, a significant separate site
inspection was not conducted. However, Kevin Rochlin, the EPA RPM, conducted a brief site
inspection on May 8, 2014. See Attachment 2 for OUs 20, 22, and 19 for the site inspection
checklist.
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Ruston/North Tacoma: The remediation consisted of property soil replacement. EPA
conducted a drive by inspection of the properties on May 8, 2014, to ensure that soil caps
remained in place. No exceptions were noted. See Attachment 2 for OUs 20, 22, and 19 for the
site inspection checklist.
Asarco Sediments: The sediments are underwater. No inspection was conducted.
5.5.1.6 Interviews
No interviews were conducted for the Asarco OUs.
5.6. Technical Assessment
Question A: Is the remedy functioning as intended by the decision documents?
Asarco Smelter
Answer: Yes.
Site remediation is ongoing as Point Ruston LLC continues to redevelop the site with
condominiums, homes, parking areas, etc. Their construction monitoring plans and other
associated redevelopment plans are reviewed by EPA and contain measures to ensure that
the intent of the remedy is being met as the site is redeveloped. In the interim (i.e., until
construction/redevelopment is complete), exposure pathways that could result in
unacceptable risks are being prevented because the site is being controlled by the
developer. The O&M responsibilities of Point Ruston LLC are explained in the 2013
OMMP and cover the Smelter site cap, the slag peninsula cap, the shoreline armoring,
and site utilities. The obligations of the OMMP are incorporated as institutional controls
in the Covenants, Conditions and Restrictions (CCRs) for the site. Property management
will be conducted by either Point Ruston LLC or the Point Ruston Homeowners'
Association (HOA), once the latter entity is formed. The HOA will then assume O&M
responsibilities from Point Ruston LLC.
Although the habitat basin does not affect remedy protectiveness, it was intended to be
mitigation for armoring. It was damaged in 2001 and currently provides less fish habitat
than as designed. EPA evaluated repair options for the habitat basin in 2013 and
determined repair was necessary. EPA began the design in September 2014.
Ruston/North Tacoma Study Area
Answer: Yes.
Site remediation is complete except for a small number of yards where the property
owners refused. These properties and any remaining work have been transferred to
Ecology as of early 2014.
Asarco Sediments
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Answer: Yes.
The offshore sediments have been capped, and the remedy is functioning as intended in this
area. The sediment remedy has not yet been implemented for the Yacht Basin sediments.
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy still valid?
Asarco Smelter
Answer: Yes.
Changes in Standards and To Be Considered. ARARs cited in the ROD were not
reviewed during this FYR. Since the entire site is being capped, there will be no
exposure when the remediation is completed and CCRs are implemented.
Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics.
The ROD described current and future land uses and identified likely exposure pathways;
the descriptions are accurate for the site conditions at the time of this review.
Changes in Land Use. There have been no changes in the physical conditions of the site
that would affect the protectiveness of the remedy. Point Ruston LLC is redeveloping the
site with oversight by EPA to ensure that the intent of the remedy is being met as the site
is redeveloped.
Remedial Action Objectives. The RAOs from the ROD are still valid and protective for
the site.
Ruston/North Tacoma Study Area
Answer: Yes.
In 1999, Ecology decided that it no longer concurred with the cleanup decision for
the Study Area and began a separate investigation into residual contamination
from smelter operations. Ecology initiated a cleanup action in 2000 for the
Tacoma Smelter Plume (TSP) and will be performing a second remediation of the
Study Area and the surrounding 1,000 square miles beginning in 2013.
In the 2009 FYR, Ecology also requested that EPA conduct a more in-depth review of the
remedy for the site to ensure its protectiveness. This review was completed by EPA and
documented in their report dated January 27, 2011 (EPA 201 lb). EPA concluded that the
remedy is still protective. EPA did acknowledge that more properties in Zone 4 required
remediation than were predicted at the time of the ROD; thus, remediation was expanded
to include Zone 4 and has been completed (except for a few refusals).
Changes in Standards and To Be Considered. ARARs cited in the ROD were not
reviewed during this FYR since the remedy is complete except for a small number of
properties (refusals) that have been turned over to Ecology.
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Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics.
The ROD described current and future land uses and identified likely exposure pathways;
the descriptions are accurate for the site conditions at the time of this review.
Changes in Land Use. There have been no changes in the physical conditions of the site
that would affect the protectiveness of the remedy.
Remedial Action Objectives. The RAOs from the ROD are still valid and protective for
the site.
Asarco Sediments
Answer: Yes.
Changes in Standards and To Be Considered. See Section 4.2.6 (Question B).
Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics.
Prior to any remediation of the Yacht Basin, the Yacht Basin sediments will need to be
resampled, and the sediment sample results will need to be compared to the toxicity data
available at that time. See also Section 4.2.6 (Question B).
Changes in Land Use. There have been no changes in the physical conditions of the site
that would affect the protectiveness of the remedy.
Remedial Action Objectives. The RAOs from the ROD are still valid and protective for
the site.
Question C: Has any other information come to light that could call into question the
protectiveness of the remedy?
Asarco Smelter
Answer: No.
Ruston/North Tacoma Study Area
Answer: No.
Asarco Sediments
Answer: No.
5.6.1. Technical Assessment Summary
Asarco Smelter
The remedy has not been fully constructed, but it is functioning as intended where implemented.
Point Ruston LLC continues to redevelop the site (and thereby construct the remedy) in
accordance with plans approved by EPA. No information was evaluated related to ARARs,
toxicity, or otherwise that calls into question the protectiveness of the remedy. Additional repair
of the habitat basin is anticipated to occur within the next (fifth) FYR period.
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Ruston/North Tacoma Study Area
The remedy has been fully constructed (i.e., all properties have been cleaned up), with the
exception of a small number of refusals. Those properties and all future work have been
transferred to Ecology as of early 2014. No information was evaluated related to ARARs,
toxicity, or otherwise that calls into question the protectiveness of the remedy.
Asarco Sediments
The offshore sediments have been capped, and the remedy is functioning as intended in those
areas. The remedy for the Yacht Basin sediments is not functioning as intended since it has not
yet been implemented. The Yacht Basin sediments still need to be remediated. The sediment
ARAR information indicated that the revisions to the 2013 SMS resulted in no material changes
relative to the pre-revision SMS and MTCA (see Section 4.2.6). Since no Yacht Basin sediment
work has occurred, no toxicity data were evaluated. Toxicity data will be evaluated when future
samples are collected. No other information is known that calls into question the protectiveness
of the remedy.
5.7. Issues and Recommendations/Follow-up Actions
No issues that affect protectiveness were identified for the Asarco OUs (Table 7-1).
Action items that do not affect remedy protectiveness, but are expected to require future action,
are provided in Table 7-2.
5.8. Protectiveness Statement
Protectiveness statements for the Asarco OUs are provided in Section 8.
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6. Remedial Actions and Five-Year Review
Process for CB/NT Tacoma Tar Pits
Operable Unit 03
6.1. Background
The Tacoma Tar Pits site is designated as OU 03, an uplands component of the overall CB/NT
Superfund site in Tacoma.30 The site is situated within a peninsula of land between the Puyallup
River and the Thea Foss Waterway, approximately three-quarters of a mile north of Interstate 5
(see Figure 6-1). The total area of the site encompasses approximately 52 acres.
Results of site investigations conducted in the 1980s indicated that soil, surface water, and
groundwater across most of the site were contaminated with organic and inorganic contaminants
from former on-site coal gasification plant operations and the recycling of automobiles and
electrical transformers. The primary contaminants in soil, surface water, and groundwater
included metals, PAHs, PCBs, and various volatile organic compounds (VOCs), including
benzene. Soil and surface water cleanup goals have been achieved; groundwater in one of the
aquifers is still being addressed.
The ROD (EPA 1987) called for excavation and stabilization of contaminated soils into an
engineered waste pile covered by a low permeability cap, and surface water controls to 1)
manage storm water runoff from the waste pile and metal recycling operations, and 2) limit
infiltration of surface water into the subsurface. The remedy also called for continued
groundwater monitoring across the entire site to discern whether the remedial action
implemented for soils and surface water caused contaminants in groundwater to drop below the
ROD cleanup criteria. If it did not do so in a timely manner, the ROD anticipated the need for a
groundwater remedy to be implemented.
In 1998, due to continued exceedances of the groundwater cleanup criteria, EPA directed the
PRP to design and install a groundwater extraction and treatment (GWET) system to treat on-site
groundwater contamination (focused on benzene) and to prevent it from migrating off the site
and potentially impacting the Puyallup River. The GWET system has been operating since 2002.
Several active facilities are located within the site boundary including Simon Metals (formerly
known as Joseph Simon & Sons, or JS&S) on about 9 acres of the east interior of the site; a
portion of the Tri-Pak transloading facility and Union Pacific Railroad (UPRR) tracks on the
northeast; the approximately 14-acre Northwest Detention Center (NWDC) property on the
northwest (site of the former Hygrade meat packing plant); Burlington Northern Railroad
(BNRR) tracks on the southwest; a Puget Sound Energy (PSE) natural gas regulator station on
the south; and, on the far southeastern portion of the site, an Associated Petroleum Products
(APP) card lock fueling station and a portion of the City of Tacoma's vactor facility (along
Cleveland Avenue). The remainder of the site is occupied by an 8-acre capped engineered waste
pile containing stabilized soils and wastes, two lined detention ponds, and light industrial
buildings. Figure 6-2 shows most of these facilities and site features.
30 In the 1987 ROD, the site is known as OU 23.
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6.2. Site Chronology
Information through 2009 for this section is in the third FYR (EPA 2009), which is available
online at http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
Key activities since 2009 are presented below:
2010 The defective programmable logic controller (PLC) unit and modules for
groundwater extraction and treatment (GWET) were replaced.
2010 A new Signet 2551 Magmeter (flow meter) was installed at the request of
the City of Tacoma for the GWET system.
2011 Asphalt permeability testing occurred.
2012 Trench line sampling and evaluation occurred near the buried sewer lines on
the southeastern border of the site to assess benzene migration.
2013 Two East Branch groundwater monitoring wells (DOF-35M and DOF-36M)
were installed.
2013 Cracked asphalt was repaired in the detention basins.
6.3. Remedial Actions
6.3.1. Remedy Selection
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
6.3.2. Explanation of Significant Differences
Information for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
6.3.3. Remedy Implementation
Information for this section is in the third FYR, which is available online at
http://yosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
6.3.4. Post-Construction Monitoring/Operation and Maintenance
The Operation and Maintenance (O&M) program encompasses two main elements: 1) the initial
remedy consisting of low-permeability covers and storm water drainage systems completed in
1995, and 2) the groundwater extraction and treatment (GWET) system completed in 2002.
General O&M information is provided below, and progress since the third FYR is discussed in
more detail in Section 6.5.4.
6.3.4.1 Inspection and Routine Maintenance of Site Areas
Inspection and maintenance (I&M) activities are carried out by Puget Sound Energy's (PSE's)
consultant, Dalton, Olmstead and Fuglevand, Inc. (DOF), and follow the 1995 Inspection and
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Maintenance Manual (Ebasco 1995) for the components of the initial remedy. The manual calls
for routine inspection of the following items: the Simon Metals facility drainage system
including Detention Basin No. 2, asphalt and concrete pavements, waste pile cover drainage
systems and turf, and the waste pile drainage system including Detention Basin No. 1.
Inspections occur at least yearly and also after heavy rainfall events. I&M activities completed
during this fourth FYR period were summarized in DOF's 2010-2011 Inspection and
Maintenance Report (DOF 2012j) and 2012-2013 Inspection and Maintenance Report (DOF
2014c) and are presented in Section 6.5.4.
6.3.4.2 Groundwater Extraction and Treatment System
Operations and maintenance (O&M) activities for the GWET system are conducted in
accordance with the 2003 Groundwater Remediation System, Operation and Maintenance Plan
(DOF 2003). Typical maintenance items for the GWET system include the following
inspections and operational checks: 1) weekly monitoring of general plant operations and
resupply of biofouling treatment chemicals if needed, 2) monthly check of meter functions and
the need for replacement of vapor-phase carbon, and 3) other system checks (monitored
remotely) to verify the plant is operating properly.
In addition to the above O&M activities, the City of Tacoma reviews and renews PSE's
Industrial Wastewater Discharge Permit every five years. The current discharge permit TAC-
031-2011 was renewed on May 1, 2012, and expires on April 30, 2017; it will need to be
renewed during the next FYR cycle.
6.3.4.3 Groundwater Monitoring Program
Post-remediation groundwater monitoring has been occurring since March 2002, generally in
accordance with the 2002 Revised Water Quality Monitoring Program (DOF 2002). The monitoring
occurs quarterly (with some exceptions) during the months of March, June, September, and
December of each year. The consultant DOF performs the groundwater quality monitoring and
discharge reporting on behalf of PSE.
6.3.5. Remedy and O&M Costs
Costs associated with post-construction inspections and maintenance, O&M of the GWET
system, and water quality monitoring averaged $203,000 per year from 2009-2013.
6.4. Progress since the Last Five-Year Review
6.4.1. Previous Protectiveness Statement
The Tacoma Tar Pits protectiveness statement in the previous FYR (2009) stated:
"The results of this Five-Year Review indicate that the Tacoma Tar Pits remedy is
functioning as intended and is currently protective of human health and the environment
because 1) sources of contamination (e.g., waste materials and contaminated soils) have
been excavated, disposed of off-site or treated and contained on site, 2) low permeability
caps and surface water controls have been placed across critical areas of the site, 3)
institutional controls are in place, and 4) contaminated groundwater is not used as a
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drinking water source and does not appear to be discharging to the Puyallup River. In
order for the remedy to remain protective over the long-term, the follow-up actions
recommended in this report need to be performed which include 1) continuing
maintenance of the cap, cover and ancillary surface water drainage features, 2) continuing
operation and optimization of the groundwater extraction, treatment and monitoring
systems to reduce the size and concentration of the benzene plume, and 3) optimizing
property owner compliance with institutional control requirements."
6.4.2. Status of Recommendations
Table 6-1 below presents the issues and recommendations made for the Tacoma Tar Pits site in
the third FYR (2009) and provides a progress evaluation.
Table 6-1. Recommendations for Tacoma Tar
'its OU from the Third FYR and Progress
Issue
Recommendations /
Follow-Up Actions
Responsible
Party /
Oversight
Agency
Planned
Completion
Date
Progress
A small pavement failure was
observed in the asphalt road
leading to the top of the waste
pile, as shown in OU 3
Attachment 5, photo 8 [Note:
in 2009 FYR], This feature
represents a potential pathway
for surface water erosion of
the cap. (NOTE: this is a
separate pavement failure than
the one noted in - and repaired
after - the 2003 Five-Year
Review).
Repair the pavement
hole.
PSE / EPA
2009
Completed November
2009
Hydraulic conductivity testing
of asphalt pavement covers has
not been performed in
accordance with the Inspection
and Maintenance Manual. This
was recommended in the 2003
Five-Year Review Report.
Implement asphalt
pavement permeability
testing or develop and
conduct an alternative
way of systematically
assessing asphalt
pavement conditions
and permeability and
revise the Inspection
and Maintenance
Manual accordingly.
PSE / EPA
2010
Permeability testing
was completed in 2011
(DOF 2012 b); the
Inspection and
Maintenance Manual
still needs to be revised
to include regular
inspection,
maintenance, and
permeability testing.
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Table 6-1. Recommendations for Tacoma Tar Pits OU from the Third FYR and Progress
(continued)
Issue
Recommendations /
Follow-Up Actions
Responsible
Party /
Oversight
Agency
Planned
Completion
Date
Progress
The TTP-3M (East Branch)
Area benzene plume within the
site boundary has not
appreciably diminished in size
or concentration over the past
several years. In addition,
although this plume appears to
be contained especially when
looking at non-detect benzene
concentrations in
downgradient monitoring well
DOF-19, Figure 6-5 [Note: in
2009 FYR] shows a sewer line
trench in hydraulic connection
with the benzene plume which
may convey the plume away
from DOF-19.
Optimize the TTP-3M
(East Branch) Area
system and conduct a
capture zone analysis in
order to reach the ROD
groundwater cleanup
criterion for benzene
and reduce the size of
the plume. A
determination is also
needed on the fate and
transport of the benzene
plume and its hydraulic
relationship to the
sewer line trench along
the southern boundary
of the site.
PSE / EPA
2011
Trench line sampling
and evaluation occurred
near the buried sewer
lines on the
southeastern border of
the site to assess
benzene migration in
2012. Although benzene
was determined not to
be reaching the
Puyallup River along
this pathway, two new
wells (DOF-35M, DOF-
36M) were installed in
2013 to better assess
benzene migration
along the site's
southeastern boundary.
DOF-35M has had
minor ROD
exceedances in 2013
(DOF 2014b). See
Section 6.5.4.3 for
further discussion.
Optimization and a
capture zone analysis of
the East Branch Area
were not implemented
due to EPA resource
constraints. Issues with
the East Branch Area
are still evident in this
FYR.
See Table 7-1 for the
recommended follow-
up action for the entire
benzene plume over the
next 5YR period.
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Table 6-1. Recommendations for Tacoma Tar Pits OU from the Third FYR and Progress
(continued)
Issue
Recommendations /
Follow-Up Actions
Responsible
Party /
Oversight
Agency
Planned
Completion
Dale
Progress
The TTP-18M (North Branch)
Area benzene plume appears
to be contained or captured as
seen through decreasing
benzene concentrations;
however, the concentrations
are well above the ROD
groundwater cleanup
performance criterion for
benzene (53 |ig/L) and are also
outside the site boundary.
Optimize the TTP-18M
(North Branch) Area
system and conduct a
capture zone analysis in
order to reach the ROD
groundwater cleanup
criterion for benzene
and reduce the size of
the plume. An
additional monitoring
well may also be
needed just beyond the
stagnation point of
Extraction Well A to
help determine
effectiveness.
PSE / EPA
2011
Optimization and a
capture zone analysis of
the North Branch Area
were not implemented
due to EPA resource
constraints. Issues with
the North Branch Area
are still evident in this
FYR.
See Table 7-1 for the
recommended follow-
up action for the entire
benzene plume over the
next 5YR period.
The ROD groundwater remedy
and RAOs focused on
treatment and containment of
the contaminated plume, but
do not appear to have
considered groundwater
restoration.
Evaluate whether
groundwater restoration
at this site is feasible
and necessary to 1)
comply with ARARs,
CERCLA, and EPA's
CERCLA groundwater
policies, and 2) ensure
long-term
protectiveness.
EPA / EPA
2012
The recommendations
to address this issue
were not implemented
due to EPA resource
constraints. This issue
will be evaluated over
the next 5YR period.
Property owner compliance
with site institutional control
requirements is not optimal.
Request site property
owners to comply with
all Consent Decree
conveyance of
site/institutional control
requirements.
Voluntary compliance
with the state of
Washington's Uniform
Environmental
Covenants Act (UECA)
should also be
requested to ensure the
long-term effectiveness
of site institutional
controls.
Site property
owners /
EPA
2012
The recommendations
to address this issue
were not implemented
due to EPA resource
constraints. This issue
will be evaluated over
the next 5YR period.
In addition to the above recommendations/follow-up actions, the third FYR (2009) also
recommended that the following actions be considered to ensure the protectiveness of human
health and the environment. The status of each item is explained in italics:
• If EPA and PSE decide that a vegetative management plan is necessary for the site, control
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of Spotted Knapweed should be a component of that plan as it is designated for control in
the Tacoma CB/NT area. Determining the need to prepare a vegetative management plan
was not implemented during this FYR period due to EPA resource constraints. This action
will be implemented once resources become available.
• Include the Correctional Services Corporation (CSC)/GEO Group, Inc.-owned Northwest
Detention Center property, the City of Tacoma/CSC-owned parcel southeast of the
Detention Center, and the 1616 St. Paul parcel north of the Detention Center as part of the
Tacoma Tar Pits site on the City of Tacoma's GOV.ME GIS website. This action was not
implemented during the last FYR period due to EPA resource constraints. This action will
be implemented once resources become available.
6.5. Five-Year Review Process
This section describes the process taken to conduct this fourth FYR of the Tacoma Tar Pits site,
and provides an evaluation of the data and the progress made to ensure the protectiveness of the
remedy.
6.5.1. Administrative Components
The Tacoma Tar Pits site FYR team was led by Tamara Langton, the EPA RPM in Region 10.
Veronica Henzi (environmental engineer) and Karah Haskins (physical scientist) with USACE,
Seattle District, assisted with the review as representatives of the support agency.
By December 2013, the review team had been formed and the review schedule had been
established for the following activities:
• Interviews and community notification and involvement;
• Document collection and review;
• Data assessment/analysis;
• Site inspection;
• FYR report development and review; and
• Identification and evaluation of institutional controls
The FYR has a statutory completion date of December 23, 2014.
6.5.2. Community Involvement
On January 17, 2014, a display advertisement ran in the Tacoma News Tribune newspaper
providing notification and contact information for the FYR. In addition, on January 21, 2014,
EPA Community Relations staff sent postcards to stakeholders and neighbors included on the
CB/NT project mailing list (approximately 1,150 addressees), providing notification about the
FYR process. Both notifications requested that any information that people would like EPA to
consider during the review be provided to the EPA before April 15, 2014.
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One inquiry was received regarding the Tacoma Tar Pits site from a reporter with the Seattle
Globalist. The questions were answered by the EPA RPM for the Tacoma Tar Pits site (Tamara
Langton), as described in OU 3 Attachment 3.
6.5.3. Document Review
A review of reports pertinent to this FYR was conducted by the review team. The types of
documents reviewed included decision documents, water quality and discharge reports, I&M
reports, and technical memoranda. See OU 3 Attachment 1 for a complete list of documents
reviewed for the Tacoma Tar Pits site.
6.5.4. Data Review and Evaluation
Since the third FYR (2009), activities at the Tacoma Tar Pits site have been related to inspection,
operations, and maintenance of the remedy. Data in the following documents were evaluated,
and the results are presented in a detailed technical memorandum (see OU 3 Attachment 2):
• 2010-2011 Inspection and Maintenance (I&M) Report
2012-2013 I&M Report
Water quality monitoring reports (2009-2013)
Discharge reports (2009-2014)
Asphalt permeability testing technical memorandum
• Trench line sampling technical memorandum
Well installation technical memorandum
6.5.4.1 Inspection and Maintenance Activities - Soil Capping and Surface
Water Drainage
Table 6-2 below summarizes the facilities and areas that were inspected during this fourth FYR
period, and indicates the status as of 2013 (DOF 2012j; DOF 2014c).
Table 6-2. Tacoma Tar Pits Areas Subject to I&M, and Current Condition
Areas covered by I&M plan
Current condition
Covered stabilized waste pile, which
is 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.
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Table 6-2. Tacoma Tar Pits Areas Subject to I&M, and Current Condition (continued)
Areas covered by I&M plan
Current condition
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 and
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 in 2013 - see additional text below
this table.
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 BNRR 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 BNRR ditch that drains both
detention basins
Vegetation continues to grow in the BNRR 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.
Signs and fencing
The 2012-2013 Inspection and Maintenance Report did not discuss any
issues related to signs or fencing.
Because cracking had been observed in the detention basin asphalt, EPA requested that the
asphalt be investigated and repaired. In 2011, DOF performed asphalt permeability testing and
summarized the results in their 2012 Technical Memorandum for Results of Asphalt
Permeability Testing (DOF 2012b). Of particular interest to EPA had been cracking at location
DB1-KT2, where a crack of 1.5 inches deep had developed and the permeability was 2.3xl0"7
n
cm/sec, which slightly exceeded the performance criterion of 1x10" cm/sec. This crack, along
with several others, was repaired in August 2013 (DOF 2014c). Figure 6-3 is a photo showing an
example of the asphalt repair.
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In general, site observations made by DOF from 2010 to 2013 indicate that the remedial systems
installed at the Tacoma Tar Pits site are in acceptable condition and are functioning as intended.
The cracked asphalt has been repaired. However, it was not clear from the 2012-2013 Inspection
and Maintenance Report if DOF's 2006 Asphalt Repair/Maintenance Plan for the Detention
Basins or their 1995 Inspection and Maintenance Manual has been formally updated to
incorporate EPA's 2012 request to make "periodic observations of the integrity of the asphalt,
and [make] repairs where necessary" (EPA 2012a). During the site visit on June 12, 2014, DOF
indicated that they have not updated either their 2006 Plan or their 1995 Manual to incorporate
EPA's 2012 request.
6.5.4.2 Groundwater Extraction and Treatment (G WET) System
Performance
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 interest,
shown on Figure 6-4) is generally being contained by the extraction and treatment system (DOF
2014a; DOF 2014b). Over the review period (2009-2014), the system operated on average 93%
of the time. 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.
The City of Tacoma reviews and renews PSE's Industrial Wastewater Discharge Permit every
five years. The current discharge permit No. TAC-031-2011 was renewed on May 1, 2012 and
expires on April 30, 2017; it will need to be renewed during the next FYR cycle.
Since the containment system began operation (2002), benzene influent concentrations have
generally declined 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 (see the third FYR, Section 6.1.2, for a discussion of hydrogeology at
the Site, http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt). Regarding influent concentrations
from the East Branch wells, the data from 2009 to 2013 show a decreasing trend (see Figure 6-5)
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 6-5), with concentrations
ranging from approximately 480 |ig/L to 610 |ig/L. Four extraction (pumping) wells are used for
the GWET system (see Figure 6-6): wells A and B in the North Branch area, and wells C and
TW-1 in the East Branch area.
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The individual benzene effluent concentrations from the GWET system for all quarters (2009-
2014), except for the quarter ending March 2014, were less than 1.6 |ig/L which is significantly
less than the permit discharge criterion of 500 |ig/L. On February 26, 2014, a concentration of
550 |ig/L was detected in an effluent sample. This exceedance was duly reported to the
appropriate City of Tacoma authorities in accordance with the discharge permit and immediate
action to correct the problem was taken. The cause of the exceedance was traced to delayed
maintenance of the air-stripper due to winterization equipment that impeded access. Timely
corrective action was taken (i.e., the air stripper was cleaned) and the results for June and August
2014 effluent samples indicated benzene concentrations that fall within the normal range of less
than 1.6 |ig/L and well below the discharge criterion. The sanitary sewer authorities were
satisfied with the actions taken to report and rectify the problem, and a revised maintenance
schedule for the air stripper was developed and will be implemented as long as the treatment
system is in operation.
6.5.4.3 Groundwater Monitoring Results
The sections below provide sampling locations, results of monitoring, and recommendations. See
Figure 6-6 for locations of the monitoring wells, extraction (pumping) wells, the surface water
(SW) sampling site, and the Hygrade Well No. 2 for reference.
6.5.4.3.1 Sampling Locations
In May 2013 the groundwater monitoring program was expanded from 22 to 24 wells with the
installation of two new wells, DOF-35M and DOF-36M, on the southeastern border of the site.
The need for the wells was established based on push-probe and trench line sampling and
evaluation conducted in 2012 (DOF 2012a). The purpose of the new wells is to assess whether
benzene is migrating downgradient along the existing buried sewer line. The wells were
incorporated into the monitoring program starting in June 2013.
In general (but with some exceptions), all wells are monitored quarterly, and two other locations
are also sampled. The first location is a surface water location designated "SW" in the BNRR
ditch, and the second is the Hygrade well located outside the fence of the NWDC. 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 NWDC fencing. The exterior Hygrade well is an artesian well located approximately
20 feet to the west of Hygrade Well No. 2 (see Figure 6-6 for location of the SW sample location
and the Hygrade Well No. 2 location). 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, and 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 sampling in
September 2014. It should be noted that the exterior Hygrade well currently being sampled is not
shown on the figures in DOF's water quality monitoring reports; its location has to be inferred
from the location of Hygrade Well No. 2.
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6.5.4.3.2 Analysis of Monitoring Well Data
See Figure 6-7 for the current benzene plume data as of December 2013, where benzene
concentrations continue to exceed the ROD criterion of 53 |ig/L. See Figure 6-8 for groundwater
contours and estimated flow directions in the Sand Aquifer (the aquifer of concern) 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. Two extraction wells are located in the source area of this
Branch; TW-1 is upgradient of the site boundary and well C is closer to the southeastern site
boundary. These wells are designed to capture and contain East Branch groundwater
contamination.
The currently monitored East Branch wells are as follows:
• Within source 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) T
The wells near 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 trends. The results are provided below in Table 6-3.
Table 6-3. Mann-Kendall Test for Trends in East Branch Boundary & Downgradient
Wells (2009-2013)
Monitoring
Within Capture
Benzene Concentrations
B c nzc nc Co nee nt ra 1 i o n
Confidence in
Well
Zone?
above ROD Criterion (53
H#L)?
Trend
Trend (%)
TTP-2M
Yes
No
Decreasing
>99.9
TTP-3M
Yes
Yes
No Trend
63.8
DOF-19M
Yes
No
Probably Decreasing
94.6
DOF-20M
Yes
No
No Trend
70
DOF-24M
Yes
Yes
No Trend
63.8
DOF-25M
Yes
Yes
Increasing
95.4
DOF-34M
Yes
Yes
Probably Decreasing
91.3
As indicated in Table 6-3, the East Branch site boundary wells that exceeded the ROD criterion
for benzene are TTP-3M, DOF-24M, DOF-25M, and DOF-34M. These wells, however, are
within the East Branch area capture zone. Site boundary well TT-2M, also within the capture
zone, had non-detect concentrations of benzene or levels significantly below the ROD criterion.
For the newly installed boundary 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 exceeded the ROD benzene criterion;
however, this well is too new to analyze trends with any certainty. For the other newly installed
boundary well, DOF-36M, there were no detections (detection limit of 0.10 |ig/L) in June,
September, or December 2013.
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Downgradient wells DOF-19M and DOF-20M benzene concentrations were either non-detect or
significantly below the ROD criterion. The Puyallup River is located downgradient from all of
the aforementioned wells and there are no indications that the benzene plume from the East
Branch is reaching the River.
The North Branch area is located on the north part of the site and generally lies between wells
AGI-14M(R) and AGI-5M. Two extraction wells are located in the source area of this Branch;
well A is located in the northern lobe and well B is in the southern lobe. These wells are
designed to capture and contain North Branch groundwater contamination.
The currently monitored North Branch wells are as follows:
• Upgradient of source area (and covered waste pile): TTP-16M(R), TTP-17M
• Within source 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 the two lobes generally centered on wells DOF-33M and TTP-18M/DOF-31M,
respectively. The wells near and downgradient of the site boundary were evaluated using the
Mann-Kendall nonparametric test for trends. The results are provided below in Table 6-4.
Table 6-4. Mann-Kendall Test for Trends in North Branch Boundary & Downgradient
Wells (20C
9-2013)
Monitoring
Within Capture
Benzene Concentrations above
Benzene Concentration
Confidence in
Well
Zone?
ROD Criterion (53 ng/L)?
T rend
Trend (%)
TTP-18M
Yes
Yes since December 2011
Increasing
>99.9
DOF-27M
No
No
No Trend
78.4
DOF-28M
No
No except one instance (68
Hg/L) in March 2013 (1)
No Trend (1)
60.3
DOF-31M
Yes
Yes - since March 2011
Increasing
99.7
DOF-33M
Yes
Yes except once instance (0.1
Hg/L) in December 2013 (2)
Probably Decreasing (2)
93.2
MW-03
No
No
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.
As indicated in Table 6-4, the boundary wells with increasing benzene concentrations and above
the ROD criterion are TTP-18M and DOF-31M. DOF-33M also has benzene concentrations that
significantly exceed the ROD criterion but appears to have a decreasing or stable trend. These
wells are located just outside the North Branch area site boundary (see Figure 6-6, upper portion)
but are within the capture zone of this Branch.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Benzene has generally not been detected in wells DOF-27M, DOF-28M, and MW-03, which are
located downgradient of the site boundary. The Puyallup River is located downgradient from all
of the aforementioned wells and there are no indications that the benzene plume from the North
Branch is reaching the River.
The surface water (SW) location is supposed to be sampled in March and September, but the
BNRR ditch is frequently dry in September. The available sampling data indicate that the
benzene concentrations have been <1.0 |ig/L for this 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.
6.5.4.3.3 Water Quality Summary
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) in December 2013 appears generally similar to the shape of plume
in December 2009 (see Figure 6-7 for 2013 plume and Figure 6-9 for 2009 plume). With respect
to effluent discharges from the GWET system, there has been only one exceedance of the 500
|ig/L benzene criterion on February 26, 2014 where concentrations of 550 |ig/L were detected in
a sample. This exceedance was an isolated event due to a delay in maintaining the air-stripper,
and the necessary steps to avoid an exceedance in the future have been implemented.
With respect to the East Branch site boundary wells, the TTP-3M, DOF-24M, DOF-25M, and
DOF-34M have mixed results for benzene concentrations and trends; however, all are within the
capture zone of this Branch. Site boundary well TTP-2M, also within the capture zone, has non-
detect concentrations of benzene or levels significantly below the ROD criterion during this 5YR
period. Of the two East Branch boundary wells installed in 2013 near the sewer lines (DOF-35M
and DOF-36M), 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 site's southeastern
boundary. Downgradient wells DOF-19M and DOF-20M benzene concentrations were either
non-detect or significantly below the ROD criterion. The Puyallup River is located
downgradient from all of the aforementioned wells and there are no indications that the benzene
plume from the East Branch is reaching the River.
With respect to the North Branch wells located just outside the site boundary, wells TTP-18M
and DOF-31M have exceeded the ROD criterion at increasing values since 2011. DOF-33M,
also located just outside the site boundary, has had generally stable benzene concentrations but at
levels significantly above the ROD criterion. Other site boundary wells have mixed results for
benzene concentrations and trends. Although there are concerns about benzene exceedances,
these site boundary wells are within the North Branch capture zone and groundwater in this area
is estimated to flow west towards extraction wells A and B and the site's interior (see Figure 6-
8). Downgradient wells east of the North Branch boundary wells have generally been non-
detect for benzene (DOF-27, DOF-28, and MW-03). The Puyallup River is located
downgradient from all of the aforementioned wells and there are no indications that the benzene
plume from the North Branch is reaching the River.
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6.5.5. Site Inspection
A site inspection was conducted for the Tacoma Tar Pits component of the CB/NT Superfund
Site on June 12, 2014, to physically observe the conditions of the site and components of the
remedy. Participants included EPA and their support agency, USACE; PSE and their
remediation contractor, DOF; the City of Tacoma Public Works Department; and Simon Metals.
The site inspection team roster, site inspection checklist, and pertinent photographs, are included
as OU 3 Attachment 4.
6.5.6. Interviews
Interviews were performed informally during the site inspection on June 12, 2014, and the results
are documented in OU 3 Attachment 4. Parties were identified for the interviews based on the
following criteria:
• Parties directly or indirectly responsible for remedial O&M program
• Parties adjacent to the site or affected by site-related contaminants
• Utilities affected by operation of the remedy
Parties interviewed included the following:
• John Rork, PSE Proj ect Manager
• Matt Dal ton, DOF (Consultant for PSE)
• Dave Cooper, DOF
• Mark Stafford, City of Tacoma, Public Works
• Alan Aplin, City of Tacoma, Public Works
• Greg Barrowman, Simon Metals
In 2009, the following recommendations were made by the City of Tacoma Public Works
Department to PSE regarding the operation of the groundwater treatment plant during the site
inspection and in follow-up letters pursuant to PSE's Industrial Wastewater Discharge Permit
which discharges effluent to Tacoma's Central Treat Plant #1 (a publicly owned treatment works
[POTW]). PSE's contractor, DOF, provided responses on 6/27/14 (Dalton 2014), which are
shown below in italics:
• PSE must obtain approval from the City of Tacoma prior to modifying the pre-treatment
system. DOF, on behalf of PSE, re-submitted an engineering update to the discharge
permit that included a process flow diagram, which was approved by the City of Tacoma.
• A non-mechanical type flow meter should replace the existing flow meter to measure
discharge quantities of treatment water to the POTW to obtain greater accuracy. DOF
installed and the City of Tacoma approved the new meter in 2010.
• As required by the approved treatment plant design, a sequestering agent should be used to
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reduce precipitates or scale from forming. It was determined that a sequestering agent was
not needed based on approval of the process flow (first bullet above)
• Service bag filters 1 and 2 or replace the pressure gauges. The bag filters and pressure
gauges have been replaced, and the filters continue to be replaced as required.
• Determine the purpose of the 8-inch private storm line originating north of the capped
engineered waste pile area, then passing underneath it and terminating within the Simon
Metal's northwest detention pond. This pipe drained the local area and was plugged in
2009.
6.5.7. Identification of Institutional Controls
Information through 2009 for this section is in the third FYR, which is available online at
http://vosemite.epa.gov/rlO/cleanup.nsf/sites/cbnt.
As of 2014, the recommendations to address the issue with Institutional Controls were not
implemented due to EPA resource constraints. This issue will be evaluated over the next
5YR period.
These will be addressed once resources are made available.
6.6. Technical Assessment
Question A: Is the remedy functioning as intended by the decision documents?
Answer: Yes. The remedy is functioning as intended by the decision documents based on a
review of site data, interviews, and on observations made during the site inspection.
Soil and Surface Water (Capped Areas and Drainage Systems)
The cap and surface drainage features continue to be generally in good condition and
routinely inspected and repaired when required to maintain their intended functions. Surface
water cleanup criteria identified in the ROD have been achieved as measured ("SW" sample)
at the site boundary in the BNRR ditch.
Regarding the detention basins and asphalt, the PRP's remediation contractor, DOF,
conducted asphalt permeability coring and testing in 2011 and repaired cracks in the
detention basins. However, DOF indicated during the site visit on June 12, 2014 that they
have not updated either their 2006 Asphalt Repair/Maintenance Plan for the Detention Basins
or their 1995 Inspection and Maintenance Manual to incorporate EPA's 2012 request to
make "periodic observations of the integrity of the asphalt, and [make] repairs where
necessary" (EPA 2012a). DOF should inform EPA of their planned procedures for regularly
inspecting, repairing, maintaining, and doing permeability testing on the asphalt, and indicate
which of their documents will be updated to incorporate those activities. See Table 7-2 for
recommended future actions.
Groundwater
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Site groundwater has been monitored quarterly since 1991, and the GWET system has been
in operation since 2002. Monitoring data indicates that ROD cleanup criteria have been
achieved for all indicator contaminants in two of the site aquifers (the Fill and Lower
Aquifers). The ROD cleanup criteria for lead, PCBs and PAHs have also been achieved in
the Sand Aquifer; only benzene exceeds the ROD criterion of 53 (J,g/L. As such, benzene in
the Sand Aquifer continues to be the focus of the groundwater monitoring program.
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) in December 2013 appears generally similar to the
shape of plume in December 2009 (see Figure 6-7 and Figure 6-9).
With respect to the East Branch site boundary wells, the TTP-3M, DOF-24M, DOF-25M,
and DOF-34M have mixed results for benzene concentrations and trends; however, all are
within the capture zone of this Branch. Site boundary well TTP-2M, also within the capture
zone, has non-detect concentrations of benzene or levels significantly below the ROD
criterion during this 5YR period. Of the two East Branch boundary wells installed in 2013
near the sewer lines (DOF-35M and DOF-36M), 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 site's southeastern boundary. Downgradient wells DOF-19M
and DOF-20M benzene concentrations were either non-detect or significantly below the
ROD criterion. The Puyallup River is located downgradient from all of the aforementioned
wells and there are no indications that the benzene plume from the East Branch is reaching
the River.
With respect to the North Branch wells located just outside the site boundary, wells TTP-
18M and DOF-31M have exceeded the ROD criterion at increasing values since 2011. DOF-
33M, also located just outside the site boundary, has had generally stable benzene
concentrations but at levels significantly above the ROD criterion. Other site boundary wells
have mixed results for benzene concentrations and trends. Although there are concerns about
benzene exceedances, these site boundary wells are within the North Branch capture zone
and groundwater in this area is estimated to flow west towards extraction wells A and B and
the site's interior (see Figure 6-8). Downgradient wells east of the North Branch boundary
wells have generally been non-detect for benzene (DOF-27, DOF-28, and MW-03). The
Puyallup River is located downgradient from all of the aforementioned wells and there are no
indications that the benzene plume from the North Branch is reaching the River.
While the ROD groundwater cleanup criterion for benzene in the sand aquifer has not yet
been achieved at the Tacoma Tar Pits site, the groundwater remedy component (GWET
system) is functioning as intended by containing the majority of the contaminated
groundwater plume such that exposures are under control and human and ecological
receptors are not impacted. Specific recommendations to address the site-wide benzene issue
are provided in Table 7-1.
Institutional Controls
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Institutional controls, such as restrictions on the use of site groundwater, are in place across
the site and protect the remedy in the short-term. However, based on the preliminary title
search conducted by the PRP's remediation contractor, DOF, it does not appear that site
property owners have complied with all Consent Decree conveyance of site/institutional
control requirements. As of 2014, the recommendations to address this issue were not
implemented due to EPA resource constraints. This issue will be evaluated over the next
5YR period.
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy still valid?
Answer: Yes. There have been changes in the standards, exposure pathways, toxicity, and
land use since the 1987 ROD; however, those identified in the ROD are still valid and none
of the changes negatively impact the protectiveness of the remedy.
Changes in Standards and To Be Considered (TBCs). Applicable or relevant and
appropriate requirements (ARARs) cited in the ROD were reviewed to evaluate changes
since the third FYR. A summary table is presented in OU 3 Attachment 5. There were no
changes during the fourth FYR period; consequently, there were no changes that affect
protectiveness.
Spotted Knapweed, which was observed on top of the engineered waste pile cover during the
third FYR, is included on the Washington State Class B Noxious Weed List and is designated
for control in the Tacoma area. The third FYR recommended that if EPA and PSE consider a
vegetative management plan necessary for the site, the plan should include control of Spotted
Knapweed since Spotted Knapweed is designated for control in the Tacoma CB/NT area.
Determining the need to prepare a vegetative management plan was not implemented during
this FYR period due to EPA resource constraints. This action will be implemented once
resources are available.
Changes in Exposure Pathways, Toxicity and Other Contaminant Characteristics.
There have been no changes in exposure pathways (e.g., site receptors, sources) during the
fourth FYR period. There have also been no toxicity changes that would affect protectiveness
of the remedy. According to EPA's Integrated Risk Information System (IRIS), there have
been no changes to the oral reference dose, the inhalation reference dose, or the
carcinogenicity assessment for benzene.
Changes in Land Use. Although the City of Tacoma has a new vactor facility that is
partially on the site, there have been no changes in land use that would affect the
protectiveness of the remedy.
Remedial Action Objectives (RAOs). The RAOs in the 1987 ROD were not defined in
explicitly descriptive terms for the Tacoma Tar Pits site, and the ROD groundwater remedy
component did not appear to consider groundwater restoration. Instead, numerical maximum
allowable contaminant concentrations for indicator contaminants and affected media served
as the RAOs, and focused on excavation, treatment and containment (EPA 1987; ROD Table
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
2). The numerical RAOs for soil and surface water have been met and remain valid;
however, not all of the numerical RAOs for groundwater have been met (i.e., 53 |ig/L for
benzene in the sand aquifer). Recommendations to address issues with the GWET system
and the groundwater monitoring systems identified in the third FYR were not implemented
due to EPA resource constraints. However, given the exceedances of benzene across the site
over this and the previous 5YR period, it seems prudent to consider optimizing the GWET
system and the monitoring system during this next FYR period.
The recommendations to address the feasibility of a groundwater restoration RAO was not
implemented during the last 5YR period also because of EPA resource constraints. This
issue will be evaluated over the next 5YR period.
Question C: Has any other information come to light that could call into question the
protectiveness of the remedy?
Answer: No.
6.6.1. Technical Assessment Summary
The remedy is functioning as intended by the decision documents based on a review of site
data, interviews, and observations made during site inspections
The soil and surface water components of the remedy (capped waste piles; surface water
drainage systems and basins) were completed in 1995, and soil and surface water cleanup
criteria have been achieved. The remedy features continue to be monitored regularly as part
of inspection and maintenance activities. Asphalt permeability testing in the detention basins
occurred in 2011, and asphalt repairs were made in 2013.
Groundwater monitoring data indicate that the footprint of the benzene groundwater plume
(areas with concentrations greater than 53 |ig/L and greater than 1,000 |ig/L in the Sand
Aquifer) has not shrunk appreciably since the last FYR. In general, the footprint in
December 2013 footprint appeared similar to the footprint in December 2009 (see Figure 6-7
and Figure 6-9). While the groundwater containment system is functioning as intended and
the benzene plume is currently being contained, benzene concentrations in many wells across
the site are still significantly above the ROD criterion. Given the ongoing benzene
exceedances and negligible reduction in benzene plume size during the fourth FYR period, it
seems prudent to consider optimizing the GWET system and the groundwater monitoring
systems. See Table 7-1, which combines the 2009 FYR East and North Branch benzene
plume issues into one overall benzene issue for the entire site.
Institutional controls are in place across the site and protect the remedy in the short-term. To
ensure protectiveness in the long-term, property owners must at a minimum comply with all
Consent Decree conveyance of site/institutional control requirements. As of 2014, the
recommendations to address this issue were not implemented due to EPA resource
constraints. This issue will be evaluated over the next 5YR period.
No other information is known at the time of this fourth FYR that would call into question
the protectiveness of the site remedy.
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6.7. Issues and Recommendations/Follow-up actions
Issues and recommendations/follow-up actions that affect protectiveness for the Tacoma Tar Pits
site (OU3) are provided in Section 7, Table 7-1.
Action items for the Tacoma Tar Pits site that do not affect remedy protectiveness, but are
expected to require future action, are presented in Table 7-2.
6.8. Protectiveness Statement
The protectiveness statement for the Tacoma Tar Pits site (OU3) is provided in Section 8.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
7.Summary of Issues and
Recommendations/Follow-Up Actions
Issues and recommendations/follow-up actions that were identified during this fourth FYR and
affect protectiveness are summarized below in Table 7-1.
Action items that were identified during this fourth FYR and do not affect protectiveness, but are
expected to require future action, are summarized below in Table 7-2. These recommendations
are summarized herein to allow EPA to track this information, as suggested by FYR guidance
(EPA 2001).
Table 7-1. Summary of Issues and Recommendations/Follow-up Actions for the 2014 FYR
OU # Name,
Issue
Recommendations/
Responsible
Oversight
Planned
Affects
FYR Section
Follow-up Actions
Party
Agency
Completion
Protectiveness?
Date
(Y/N)
Current
Future
OUOl
Recent fish tissue
Develop and
EPA
EPA
December
N
Y
Site-Wide,
data for
implement a
2019
Section 4.8
bioaccumulative
Quality Assurance
chemicals have
Project Plan, which
not been collected
will include a
in Commencement
sampling plan for
Bay. Thus, it is
collection and
not known
analysis of bay-
whether
wide fish tissue
contaminant levels
data for
in fish tissues have
bioaccumulative
been reduced since
chemicals
the remedies have
(particularly for
been implemented,
PCBs, which have
particularly for
a human-health
PCBs (which have
based SQO).
a human-health
Provide results to
based SQO), and
appropriate state
whether fish
and local agencies
advisories should
to evaluate
be continued,
protectiveness of
modified, or
health-based fish
removed.
consumption
advisories for
Commencement
Bay.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Table 7-1. Summary of Issues and Recommendations/Follow-up Actions for the 2014 FYR
(continued)
OU # Name,
FYR Section
Issue
Recommendations/
Follow-up Actions
Responsible
Party
Oversight
Agency
Planned
Completion
Date
Affects
Protectiveness?
(Y/N)
Current
Future
OUOl
Hylebos
Waterway,
Section 4.2
Additional post-
construction
sediment sampling
needs to be
conducted
throughout the
entire Hylebos
Waterway to
determine the
status of the
remedy as
constructed.
Conduct sediment
sampling and
evaluate if the
remedy is meeting
performance
standards. Update
existing OMMP
based on results.
Mouth and
Head PRP
Groups:
Occidental;
Port of
Tacoma
EPA
December
2016
N
Y
OU 03
Tacoma Tar
Pits,
Section 6
Benzene
concentrations in
the groundwater
plume within the
sand aquifer
continue to exceed
ROD criterion
across the site.
Evaluate and
address issues
related to benzene
exceedances and
make
recommendations
for optimizing the
GWET system and
the groundwater
monitoring systems
to reduce the
benzene plume.
PSE
EPA
December
2019
N
Y
OU 03
Tacoma Tar
Pits,
Section 6
The ROD
groundwater
remedy and RAOs
focused on
treatment and
containment of the
contaminated
plume, but do not
appear to have
considered
groundwater
restoration.
Evaluate whether
groundwater
restoration at this
site is feasible and
necessary to 1)
comply with
ARARs, CERCLA,
and EPA's
CERCLA
groundwater
policies, and 2)
ensure long-term
protectiveness.
EPA
EPA
December
2019
N
Y
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Table 7-1. Summary of Issues and Recommendations/Follow-up Actions for the 2014 FYR
(continued)
OU # Name,
FYR Section
Issue
Recommendations/
Follow-up Actions
Responsible
Party
Oversight
Agency
Planned
Completion
Date
Affects
Protectiveness?
(Y/N)
Current
Future
OU 03
Tacoma Tar
Pits,
Section 6
Property owner
compliance with
site institutional
control
requirements is
not optimal.
Request site
property owners to
comply with all
Consent Decree
conveyance of
site/institutional
control
requirements.
Voluntary
compliance with
the state of
Washington's
Uniform
Environmental
Covenants Act
(UECA) should
also be requested to
ensure the long-
term effectiveness
of site institutional
controls.
Site
property
owners
EPA
December
2019
N
Y
NOTE: "FYR Section" refers to the section of this document in which the referenced OU or waterway is discussed.
Table 7-2. Action Items That Do Not Affect Remedy Protectiveness
OU # Name,
FYR Section
Action Item
Responsible
Party
Oversight
Agency
Planned
Completion Date
OU 01 Hylebos
Waterway, Section 4.2
Complete Occidental Site FS
pursuant to CERCLA AOC.
Occidental
EPA
2016
OU 01 Hylebos
Waterway, Section 4.2
Complete Arkema Site RI/FS
pursuant to state MTCA Agreed
Order, with EPA coordination and
oversight to complete source
control to ensure RA performance
standards are met.
Port of Tacoma
EPA
2016
OU 01 Sitcum
Waterway, Section 4.3
None.
OU01 St. Paul
Waterway, Section 4.4
None.
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Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Table 7-2. Action Items That Do Not Affect Remedy Protectiveness (continued)
OU # Name,
FYR Section
Action Item
Responsible
Party
Oversight
Agency
Planned
Completion Date
OU 01 Middle
Waterway, Section 4.5
MWAC will conduct another
round of monitoring in the
summer of 2014; EPA needs to
evaluate how the remedy is
performing based on the latest
round of data and in particular,
how the ARA is performing.
MWAC
EPA
2014
OU 01 Middle
Waterway, Section 4.5
Based on the 2014 monitoring
results, EPA needs to determine
future sampling frequency.
EPA
EPA
2015
OU 01 Middle
Waterway, Section 4.5
DNR should continue visual
monitoring at least every two
years as described in the Year 10
(2013) monitoring report (Hart
Crowser 2013b).
DNR
EPA
Ongoing.
OU 01 Middle
Waterway, Section 4.5
DNR should conduct another
round of sediment chemical
monitoring at least one year
before the next FYR (i.e., prior to
December 2019) so that data
results and analysis can be
included in the next review.
DNR
EPA
Prior to December
2019
OU 01 Middle
Waterway, Section 4.5
The Coast Guard Regulated
Navigation Area for Middle
Waterway must be completed.
The RNA will restrict certain
activities that could damage the
sediment cap. An Institutional
Control study should be
completed, in part to document
that easements and/or
environmental covenants have
been executed and entered into
Ecology's Uniform
Environmental Covenants Act
(UECA) registry in the Integrated
Site Information System (ISIS)
database and the City of Tacoma
govMe database.
EPA
EPA
2018
OU 01 Olympic View
Resource Area, Section
4.6
None.
150
-------
Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Table 7-2. Action Items That Do Not Affect Remedy Protectiveness (continued)
OU # Name,
FYR Section
Action Item
Responsible
Party
Oversight
Agency
Planned
Completion Date
OU 01 Thea Foss and
Wheeler-Osgood
Waterways, Section 4.7
Because recontamination is
occurring in the Thea Foss
Waterway, OMMP monitoring
should continue to evaluate
contaminant trends and assess
whether additional measures are
necessary to protect human health
and the environment.
City of Tacoma
EPA
Ongoing
OU 01 Thea Foss and
Wheeler-Osgood
Waterways, Section 4.7
Because recontamination is
occurring in the Thea Foss
Waterway, 1) OMMP monitoring
should continue to evaluate
contaminant trends and assess
whether additional measures are
necessary to protect human health
and the environment, and 2) the
City of Tacoma should continue
to implement its aggressive storm
water control and monitoring
program to further reduce
contaminant inputs to the
waterway.
City of Tacoma
WA
Department
of Ecology
Ongoing
OU 20 Asarco Smelter,
Section 5
EPA should repair the habitat
basin that was damaged in 2001,
to provide the required habitat.
EPA
EPA
December 2016
OU 22 Ruston/North
Tacoma Study Area,
Section 5
None.
OU 19 Asarco
Sediments, Section 5
None.
OU 03 Tacoma Tar Pits,
Section 6
Update the 1995 Inspection &
Maintenance Manual & Annual
Reports to include at a minimum:
1) Regular inspection,
maintenance, and permeability
testing of asphalt in the two
Detention Basins
2) Procedure to notify EPA when
all I&M activities are to be
conducted, and if any serious
issues are discovered.
PSE
EPA
December 2015
151
-------
Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Table 7-2. Action Items That Do Not Affect Remedy Protectiveness (continued)
OU # Name,
FYR Section
Action Item
Responsible
Party
Oversight
Agency
Planned
Completion Date
OU 03 Tacoma Tar Pits,
Section 6
Update Water Quality Monitoring
Reports to include at a
minimum:*
1) Monitoring wells are
accurately located, e.g., DOF-
26M is identified as within
remediation/source area but on
some figures it looks to be along
southeastern boundary.
2) Location of the exterior
Hygrade well to DOF figures and
include in DOF reports.
3) Figure that summarizes
effluent benzene concentrations to
help assess effluent trends.
*Notify EPA approx. 2-business
after incident if GWET is down, if
there are effluent exceedances or
unusual benzene samples from
any monitoring well.
PSE
EPA
December 2015
OU 03 Tacoma Tar Pits,
Section 6
Renew the City of Tacoma
Industrial Wastewater Discharge
Permit for the GETS system every
five years.
PSE
City of
Tacoma
April 2017
OU 03 Tacoma Tar Pits,
Section 6
Update GWET O&M Plan based
on outcome of optimization
evaluation.
PSE
EPA
December 2019
OU 03 Tacoma Tar Pits,
Section 6
Update Water Quality Monitoring
Program Plan based on outcome
of optimization evaluation.
PSE
EPA
December 2019
OU 03 Tacoma Tar Pits,
Section 6
Include the Northwest Detention
Facility on the City of Tacoma's
GOV.ME GIS website.
EPA
City of
Tacoma
December 2019
OU 03 Tacoma Tar Pits,
Section 6
Determine the need for a
vegetative management plan. If
needed, prepare plan.
PSE
EPA
December 2019
NOTE: "FYR Section" refers to the section of this document in which the referenced OU or waterway is discussed.
152
-------
Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
8.Summary of Protectiveness Statements
This section presents the protectiveness statements for each of the OUs (OU 01 CB/NT
Sediments; OU 19, OU 20, and OU 22 CB/NT Asarco Area; and, OU 03 CB/NT Tacoma Tar
Pits) for the CB/NT site. For OU 01 CB/NT Sediments, specific protectiveness statements are
also provided as supplemental information for each of the Problem Area waterways and the
removal action.
8.1. OU 01 CB/NT Sediments, OU-Wide
Taken as a whole, the remedies for the Sediments OU are expected to be protective when
completed. In the interim, remedial activities completed to date have adequately addressed all
exposure pathways that could result in unacceptable risks in those areas. Until site remedial
objectives are met (see Section 4.1.1), site use restrictions (i.e., fish and shellfish consumption
advisories) shall remain in effect to limit human exposure to contaminated seafood. The absence
of fish tissue contaminant data does not mean that the remedy is not protective (see EPA 2001, p.
4-14). Recent fish tissue data for bioaccumulative chemicals have not been collected in
Commencement Bay and evaluated, so it is not known whether contaminant levels in fish tissues
have been reduced since the remedies have been implemented, particularly for PCBs (which
have a human-health based Sediment Quality Objective). Future fish tissue sampling results will
be used along with other lines of evidence to evaluate protectiveness of the remedies in the
long-term.
8.1.1. OU 01 CB/NT Sediments, Hylebos Waterway
For the Hylebos Waterway, the remedy is expected to be protective of human health and the
environment upon completion. In the interim, remedial action construction completed to date
has adequately addressed all exposure pathways that could result in unacceptable risks in those
areas. Remedial action construction has been accomplished under the Head and Mouth of
Hylebos Waterway Consent Decrees, whereas work being performed pursuant to the Occidental
Site Administrative Order on Consent is at the end of Remedial Investigation and the beginning
of the Feasibility Study. Also, work being performed at the Arkema site pursuant to a state
MTCA Agreed Order is in the RI/FS phase, with EPA coordination and oversight.
8.1.2. OU 01 CB/NT Sediments, Sitcum Waterway
For the Sitcum Waterway, the remedial actions have been successfully completed, and all
required long-term monitoring efforts have been completed. The remedy remains protective of
human health and the environment, and the exposure pathways that could result in unacceptable
risks are being controlled.
8.1.3. OU 01 CB/NT Sediments, St. Paul Waterway
For the St. Paul Waterway, the remedial actions have been successfully completed, and all
required long-term monitoring efforts have been completed. The remedy remains protective of
human health and the environment, and the exposure pathways that could result in unacceptable
risks are being controlled.
153
-------
Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
8.1.4. OU 01 CB/NT Sediments, Middle Waterway
For the Middle Waterway, all remedial actions have been completed, the remedy is currently
protective of human health and the environment, and exposure pathways that could result in
unacceptable risks are being controlled. In order for the remedy to be protective in the long-term,
the Sediment Quality Objectives need to be met according to the timeframes established in the
Middle Waterway Explanation of Significant Differences (ESDs), or any exceedances need to be
shown to be biologically insignificant in all enhanced natural recovery (ENR) and natural
recovery areas, and ICs must be fully implemented.
8.1.5. OU 01 CB/NT Sediments, Olympic View Resource Area
For the Olympic View Resource Area, the remedy is protective of human health and the
environment. All long-term monitoring efforts have been completed, and exposure pathways that
could result in unacceptable risks are being controlled.
8.1.6. OU 01 CB/NT Sediments, Thea Foss and Wheeler-Osgood
Waterways
For the Thea Foss and Wheeler-Osgood Waterways, the remedy is protective of human health
and the environment. Sediment COC concentrations in the waterway have decreased since
completing the sediment remedial actions, indicating that the caps installed in the waterway are
stabilizing and performing as designed (no upward migration of contamination has been
documented). Cap integrity monitoring, which includes visual and hydrographic survey work,
indicates that capped and natural recovery areas are stabilizing and meeting performance criteria
in much of the waterway. The capped and natural recovery areas in a large portion of the
waterway are supporting benthic communities. Institutional controls have been put in place that
enhance the long-term integrity of the remedy. The City of Tacoma has implemented an
aggressive stormwater monitoring and source control program that has reduced contamination
entering the waterway. That program is expected to continue into the foreseeable future.
8.2. OU 20 Asarco Smelter, CB/NT Asarco Area
For the Asarco Smelter, the remedy is expected to be protective of human health and the
environment upon completion (i.e., once all redevelopment has been completed by Point Ruston
LLC). In the interim, remedial activities completed to date have adequately addressed all
exposure pathways that could result in unacceptable risks in those areas. Exposure pathways that
could result in unacceptable risks are being prevented because the site is being controlled by the
developer during construction using best management practices as described in the Development
and Occupancy Plan (Hydrometrics 2013b). For areas that have already been constructed, O&M
requirements to maintain protectiveness are described in the Operation, Maintenance and
Monitoring Plan (Hydrometrics 2013a). Within the next FYR period, EPA anticipates repairing
the habitat basin and completing the armoring of the remaining portions of the slag peninsula
shoreline that required armoring as part of the remedy in the ROD.
154
-------
Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
8.3. Oil 22 Ruston/North Tacoma Study Area, CB/NT Asarco Area
For the Ruston/North Tacoma Study Area, the remedy is protective of human health and the
environment. The Expedited Response Action in 1989-91 at 10 non-residential high-use areas
addressed immediate concerns. The subsequent removal/replacement of soils with concentrations
above the action level brought long-term risk exposures within EPA's acceptable risk range.
These cleanup actions were completed in 2012. Community protection measures, mostly
educational in nature, are in place for those areas that have soil arsenic concentrations between
the MTCA cleanup level of 20 ppm and the EPA action level of 230 ppm. Ecology has assumed
responsibility for all future work, including properties where owners have refused sampling or
cleanup.
8.4. OU19 Asarco Sediments, CB/NT Asarco Area
For the Asarco Sediments, the remedy is expected to be protective of human health and the
environment upon completion, once Point Ruston LLC and EPA have implemented the remedy
for the Yacht Basin sediments. In the interim, remedial activities completed to date in the capped
offshore sediments (i.e., where the remedy has been implemented) have adequately addressed all
exposure pathways that could result in unacceptable risks in those areas.
8.5. OU 3 CB/NT Tacoma Tar Pits
The results of this FYR indicate that the Tacoma Tar Pits remedy is functioning as intended and
currently protects human health and the environment in the short-term because 1) sources of
contamination (e.g., waste materials and contaminated soils) have been excavated, disposed of
off site or treated and contained on site, 2) low permeability caps and surface water controls have
been placed across critical areas of the site, 3) institutional controls that prohibit using site
groundwater are in place, and 4) the groundwater extraction and treatment system has contained
contaminated groundwater such that exposures are under control and there are no unacceptable
risks to humans or the environment, e.g. contaminated site groundwater is not being used as, or
migrating to, a drinking water source nor is it discharging to the downgradient Puyallup River.
However, in order for the remedy to remain protective over the long-term, the follow-up actions
recommended in this report need to be implemented which include 1) continuing maintenance of
the cap, cover and ancillary surface water drainage features, 2) optimizing all property owner
compliance with institutional control requirements, and 3) continuing operation and optimization
of the groundwater extraction, treatment and monitoring systems to reduce the size and
concentration of the benzene-contaminated groundwater plume across the site.
9. Next Review
The next FYR for the CB/NT Superfund site is required by December 2019, five years from the
date of this review.
155
-------
Commencement Bay Nearshore/Tideflats Superfund Site, Tacoma, Washington, Five-Year Review
Figures
-------
WDNR
Parcel 2
WDNR
Parcel 3
Yowkwala
Restoration
Project
Saltchuck
Skookum Wulge
WDNR
Parcel 1
Outer Hylebos
Mitigation Site
Area of Former
Intertidal Marsh,
Circa 1940s
Outer Hylebos
Conservancy Area
Squally Beach
Restoration
Site
PROPOSED: Puyallup
Tribal Terminal Mitigation
Site at Inner Hylebos
Inner Hylebos
Mitigation Site
Inner Hylebos
Aquatic Habitat -
Two Mitigation Sites
Synder
Sound
Refining Mudflats
Edman Holdings
Mitigation Site
1970's
Bay wide
Mitigation
Slip 5
aquatic habitat
Inner Hylebos
Peninsula
Mitigation Site
Tahoma
Salt
Marsh
Hylebos Creek Buffer
Pier
Expansion
Habitat Enhancement
Milwaukee
aquatic habitat
Hylebos Marsh and
W\ Id life Restoration
Fairliner
wetland
habitat
Spring Valley Ranch
Rhone-Poulenc
wetland
habitat
Peninsula
Habitat Area
Salmon
Enhancement
Beach
St. Paul Beach
Habitat Area
West Fork Hylebos
Creek Habitat
(Karileen)
Cooks
Marine
Dock
Middle Waterway
Corridor
Habitat Area
Olympic View
Resource Area
Middle Waterway
Tidef I at/Marsh
Mowitch Estuary
Restoration Site
OVRA
Triangle
Middle
V\feterway
Shore
SR 509 East-West
Corridor Hylebos
Creek Mitigation Site
West Milton
Salmon Habitat
Restoration
Middle Waterway
Estuarine Site
Hylebos Creek
Aquatic Wetland
Mitigation
Puyallup River
Side Channel
Habitat
Thea Foss
Settlement Misc.
Enhancement #1
Foss Waterway
Marina Restrictive
Covenants
Jordan
site
Log Step
Habitat Enhancement
Milgard
Restoration
Site
Consumer Central
Heating Beach
Enhancement
Gog-le-hi-te
I wetland
habitat
Johnny's
Dock Habitat
Enhancement
Gog-le-hi-te
II wetland
habitat
Habitat Area
Adjacent
to RA19A
SR 509
Erdahl
Ditch
Parcel 14
Mitigation
Site
Albers Mill
Pick's Cove Marina
(Restrictive Covenants)
SR 509 Esplanade
Riparian Habitat
Head of Thea
Foss Shoreline
Habitat
Clear Creek
wetland
habitat
Clear
Creek-Riverside
Site
Swan Creek
Habitat
Restoration
Potential Upper
Clear Creek
mitigation site
Pioneer Way
Property
Region 10
GIS Team
Kilometers
Figure 3-1. Mitigation and Restoration Projects (Source: EPA Region 10 GIS Team)
-------
Vashon
.Island
Puget Sound
efiance
Nearshore
Area
Ruston
Tideflats
Industrial
Area
Downtown
Tacoma.
Pacific Highway
Commencement Bay
Nearshore/Tideflats
Problem Areas
Puget Sound
Area Map
•s Point
Area Shown on
the Location Map
Problem Areas
Ruston Shoreline
(2) Mouth of CHy
(3) Head of City
Wheeler-Osgood
(7) Middle
(?) St Paul
© Sltcum
(T) Mouth of Hylebos
(T) Head of Hylebos
Miles
Figure 4-1. Commencement Bay Nearshore/Tideflats Vicinity Map (Source: Environmental Protection Agency, 1989)
-------
-i??°?4'3n"
-199093'3n"
" '
-199°99'3n"
-199°91'3n"
-------
"
SIMPSON TACOMA LAND COMPANY
AREACMj DRjYDOCK
"19b
GENERAL
CONSTRUCTION
(LEASED FROM FOSS
MARITIME CO.)|
FOSS MARITIME CO.
FORMERLY LEASED TO
CARLYLE TRUCKING
(FOSS MARITIME CO.)
MARINE INDUSTRIES NW, INC.
(LEASED FROM FOSS MARITIME CO.)
FORMERLY SUBLEASED
TO PIONEER PAINTS, INC.
(NOW LOCATED AT 303 E. D ST.)
CASCADE
PLYWOOD
HORIZONTAL DATUM: WA State Plane South Zone (NAD83)
VERTICAL DATUM: NOAA Mean Lower Low Water
SURVEY DATA:
YEAR 5 - Bathymetry and topography survey by Bluewater
Engineering, Inc. and Sitts & Hills Engineers, Inc. dated
August 2, 2009.
NOTES:
1. Property line information has been compiled from
multiple data sources, which have not been verified.
These data are to be used for reference purposes only.
LEGEND. Waterway Areas
SMU Boundaries ... .. ^
/\ Working Waterway Area
Central Tideflats
C
Scale in Feet
200
Figure 4-3. Sediment Management Unit (SMU) Locations for Middle Waterway, Areas A and B (Source: Anchor QEA 2013a) Figure 1
Sediment Management Units
Middle Waterway Problem Area - Areas A and B
-------
20
10
0
-10
-20
-30
-40
Hg (mg/kg)
uivivflmn
Hg (mg/kg)
Install Enhanced Natural Recovery
| Material Below Shore Protection
Material (Approximate Elevation
1-2 MLLW)
Hg (mg/kg)
Install Shore Protection
Material From Bench
(Approximate Elevation -2
MLLW) to Top of Slope
Hg (mg/kg) EF
Hg (mg/kg)
Fill in Depression for
Shoreline Access and Remove
Debris
Hg (mg/kg)
S5
us
r .
¥
i
n
j Hg (mg/kg)
EF*
! 3.6
6.1
~
~
E3
^7
>7
HORIZONTAL DATUM: WA State Plane South Zone (NAD83)
VERTICAL DATUM: NOAA Mean Lower Low Water
SURVEY DATA:
YEAR 5 - Bathymetry and topography survey by Bluewater
Engineering, Inc. and Sitts & Hill Engineers, Inc. dated
August 2, 2009.
NOTES:
1. Property line information has been compiled from
multiple data sources, which have not been verified.
These data are to be used for reference purposes only.
LEGEND:
Existing Thick-Layer Cap
Additional Response Action Area
Shore Protection Material
Enhanced Natural Recovery Material
SMU Boundaries
Contractor Selected Dredge Areas
Upland Access Area
MWW-316 - Composite samples taken along toe of slope in SMU
4c and 25 as approximate elevation -3 MLLW. Mercury
concentration is the same for both years.
Scale in Feet
20 40 60 80 100 120 140 160 180 200
Horizontal Distance in Feet
2x Vertical Exaggeration
Cross Section
Scale 1" = 40'
NOTES:
1. ENR Material is 1/2-inch minus gravel.
2. Filter gravel is 4-inch minus cobble/gravel.
3. Armor Stone is 3-inch to 21-inch rock.
4. Surficial Cap is 2-inch minus gravel.
PLACE SHORE
ELEVATIONS A
(APPROXIMATE
SECTION 354:
4301
'ROTECTION f
BOVE BENCH
ELEVATION ¦
10 PART 3.04
I ATE RIAL AT
! MLLW). SEE
NOMINAI
2-
16" LAYER OF
FT ARMOR STO
1-FT FILTER G
ALLOWABLE
SURFICIAL CAP
ME
RAVEL
OVERPLACEM
MATERIAL
ENT
ENR MATERIAL
6-INCH ALLOWABLE OVERPLACEf^
riENT
PLACE ENR
BELOW SH
SEE SECTIOI
MATERIAL AT
ORE PROTECTI
IN 354300 PAR
ELEVATIONS
ON MATERIAL.
T 3.04.
Figure 4-4. Additional Response Actions in Middle Waterway, Area A (Source: Anchor QEA 2013a)
Figure 1
Additional Response Action Area
Middle Waterway Problem Area - Areas A and B
-------
View from south shoreline looking north. (Before) View from south shoreline looking north. (After)
View form north shoreline looking south. (Before)
View from north shoreline looking south. (After)
Figure 4-5. Before and After Photos for Middle Waterway, Areas A (Source: Anchor QEA 2013a)
Figure 2
Additional Response Action Area Before and After Construction
Middle Waterway Problem Areas - Areas A and B
-------
ST. PAUL WATERWAY
SIMPSON TACOMA
WATERWAY LIN]
GENERAL
CONSTRUCTION
(LEASED FROM FOSS
MARITIME CO.J
Marine Railway
FOSS MARITIME CO,
LEGEND:
Dredge
Natural Recovery
No Action
Enhanced Natural Recovery with Surficial Cap
Dredge and Thick-Layer Cap
St. Paul Waterway Nearshore Facility Habitat Area
Dredge and Enhanced Natural Recovery
Enhanced Natural Recovery
Contractor Selected Dredge Areas
Backfill Areas
/ . Slope Protection Material
Waterway Areas
Working Waterway Area
B Central Tideflats
Scale in Feet
NOTE:
Property line information has been compiled from multiple data
sources, which have not been verified. These data are to be used
for reference purposes only.
HORIZONTAL DATUM: Washington State Plan South Zone
(NAD83)
VERTICAL DATUM: USACE Mean Lower Low Water
SURVEY INFORMATION:
Year 8: Bathymetric survey by Bluewater Engineering. Inc. and
Sitts & Hill Engineering, Inc. dated September 27, 2012.
Figure 2
Final EPA-Approved Remedies Applied to Areas A and B
Middle Waterway Problem Area
Year 8 Monitoring Report
Figure 4-6. Final EPA-Approved Remedies Applied to Middle Waterway, Areas A and B (Source: Anchor QEA 2013a)
COMMENCEMENT
BAY
i-dJ nih'U:
CASCADE
PLYWOOD
FORMERLY LEASED TO
CARLYLE TRUCKING
(FOSS MARITIME CO.) 1 1
MARINE INDUSTRIES NW, INC.
(LEASED FROM FOSS MARITIME CO.)
FORMERLY SUBLEASED
TO PIONEER PAINTS, INC.
(NOW LOCATED AT 303 E. D ST.)
-------
Site Plan
Middle Waterway Problem Area C
V
|
H9
SIMPSON TACOMA
LAND CO.
MIDDLE WATERWAY
^ SHORE RESTORATION SITE
(PREVIOUSLY COMPLETED
BY OTHERS) v
UPLAND AND—N-
SHORELINE \
52a PLANTING AREA
OUTFALL NO. 200—s.
DRAINAGE CHANNEL
1
CENTRAL MYLET
DRAINAGE CHANNEL
NORTHERN MYLET
DRAINAGE CHANNEL
f— SOUTHERN
MYLET
DRAINAGE
CHANNEL 51b
THIN-LAYER
CAPPING
100
200
Scale in Feet
Source: Aerial photograph from Google Earth, 2009.
SMU Number
— — — SMU Boundary (Within Area C)
Northern Extent of Area C
Figure 4-7. Prior Remedial Actions Completed in Middle Waterway, Area C (Source: HartCrowser 2013b)
hartCrowser
17947-00 6/13
Figure 2
-------
SIMPSON TACOMA LANETj
'Tin g p(gR
Marine Railway
MWW-30J
FOSS MARITIME CO.
LEGEND:
ca
Dredge
Natural Recovery
No Action
Enhanced Natural Recovery with Surficial Cap
Dredge and Thick-Layer Cap
St. Paul Waterway Nearshore Facility Habitat Area
Dredge and Enhanced Natural Recovery
Contractor Selected Dredge Areas
Backfill Areas
y*yK Slope Protection Material
Waterway Areas
J\ Working Waterway Area
B Central Tideflats
MWW-301 ~ Discrete Surface Grab Sample Location and Number
(collected from boat within Dredged with ENR and ENR Areas)
1* Transect Start and Stop Point Location and Number
I—I—I—I—I—I Potential Hand Core Transect Location
'¦ Diver Transect Lines
Transects that were evaluated in the dry during a low tide event
Enhanced Natural Recovery
NOTES:
1. Property line information has been compiled from multiple data
sources, which have not been verified. These data are to be
used for reference purposes only.
2. Bathymetry data not collected where ships and MINI dry-dock
blocked access.
HORIZONTAL DATUM; Washington State Plane South Zone
(NAD83)
VERTICAL DATUM: USACE Mean Lower Low Water
SURVEY INFORMATION:
Year 8: Bathymetric survey by Bluewater Engineering, Inc. and
Sitts & Hill Engineering, Inc. dated September 27, 2012.
Scale in Feet
CASCADE
PLYWOOD
ST. PAUL WATERWAY
h FORMERLY SUBLEASED
TO PIONEER PAINTS, INC.
(NOW LOCATED AT 303 E. D ST.)
-MARINE INDUSTRIES NW, INC.
(LEASED FROM FOSS MARITIME CO.)
GENERAL
CONSTRUCTION
(LEASED FROM FOSS
MARITIME CO.)[ |
FORMERLY LEASED TO
CARLYLE TRUCKING
(FOSS MARITIME CO.)
Figure 4-8. Surface Sample and Dive Transect Locations for Year 8 (2012) Sampling (Source: Anchor QEA 2013b)
Figure 10
Actual Surface Sample and Dive Transect Locations for Year 8
Middle Waterway Problem Area
Year 8 Monitoring Report
-------
Year 5 Excavated Areas with Backfill Sample Collection Locations (SMU 51a)
Middle Waterway Problem Area C
SMU 51b
SMU 52a
E-M-2009
CD-M-2009
Note: The iocation of SMU 51a in relation
to the rest of Middle Waterway can be
seen in Figure 4 of the Year 10 (2013)
Monitoring Report (prepared by Hart
Crowser for Washington State DNR; Hart
Crowser 2013b).
Outfall No. 200
50
100
®
A-2-M-2009 @
SMU 51a Boundary
SMU 51b Boundary
SMU 51a Excavation Limit
Sediment Verification Sampling
Grid and Designation
Year 5 Discrete Surface
Sample Location and Number
Relatively Unconsolidated Area
Scale in Feet
HARTCROWSER
7946-04 11/09
Figure 4-9. Excavated Areas with 2009 Backfill Sample Collection Locations (SMU
51a) (Source: HartCrowser 2010)
-------
Year 5 Thin-Layer Cap Sample Collection Locations (SMU 51b)
Middle Waterway Problem Area C
SMU 51a Boundary
SMU 51b Boundary
Channel Location
K-M-2009 @ Year 5 Thin-Layer Cap
Assessment/Observation
Location and Number
Sediment Sampling
Grid and Designation
Sediment Composite
Sampling Area
Notes:
1. Elevation contours outside SMU 51 a and SMU 51 b from Foster Wheeler and
Blue Water Engineering Survey, 1998.
2. Elevation contours within SMU 51a and SMU 51b from Baseline Engineering
Survey, October 2004.
Vertical Datum:
Datum: Corps of Engineers mean lower low water based on benchmark: BME406
1965 monument located on the south side of the east end of the East 11th Street
bridge elevation: 24.09"
Basis of Bearings:
100
200
Scale in Feet
Figure 4-10. Year 5 (2009) Sediment Cap Sample Locations in SMU 51b (Source: HartCrowser 2010) Washington State Plane coordinate system south zone, NAD83/1991
HartCrowser
7946-04 11/09
Figure 4
-------
Year 10 Excavated Areas with Backfill Sample Collection Locations (SMU 51a)
Middle Waterway Problem Area C
®
CD-M-2013 @
A-2-M-2013 @
SMU 51a Boundary
SMU 51b Boundary
SMU 51a Excavation Limit
Sediment Verification Sampling
Grid and Designation
Year 10 Discrete Surface
Sample Location and Number
Relatively Unconsolidated Area
Sample exceeded SQO and early warning triggers
Sample exceeded early warning triggers
/
J
50
100
Scale in Feet
Figure 4-11. Excavated Areas with 2013 Backfill Sample Collection
Locations (SMU 51a) (Source: HartCrowser 2013b)
HartCrowser
17947-00
Figure 3
-------
Year 10 Thin-Layer Cap Sample Collection Locations (SMU 51b)
Middle Waterway Problem Area C
SMU 51a Boundary
SMU 51b Boundary
Channel Location
®
Sediment Sampling Grid and Designation
Sediment Composite Sampling Area
(Sample exceeded SQO and early warning triggers)
K-M-2013 @ Year 10 Thin-Layer Cap
Assessment/Observation
Location and Number
Figure 4-12. Year 10 (2013) Sediment Cap Sample Locations in SMU 51b (Source: HartCrowser 2013b)
Notes:
1. Elevation contours outside SMU 51a and SMU 51b from Foster Wheeler and
Blue Water Engineering Survey, 1998.
2. Elevation contours within SMU 51a and SMU 51b from Baseline Engineering
Survey, October 2004.
Vertical Datum:
Datum: Corps of Engineers mean lower low water based on benchmark: BME406
1965 monument located on the south side of the east end of the East 11th Street
bridge elevation: 24.09'
Basis of Bearings:
Washington State Plane coordinate system south zone, NAD83/1991
100
200
Scale in Feet
HartCrowser
17947-00
Figure 4
6/13
-------
Vicinity Map
NOT TO SCALE
hartcrowser
7514 12/02
Figure U1 RACR
WASHINGTON
Figure 4-13. Olympic View Resource Area (Site) and Other Waterways (Source: EPA 2009)
-------
f govME Map - Windows Internet Explorer
0
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" X | Google
File Edit View Favorites lools Help
E|Convert t ^Select
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govME Map
m
govME
^governmentmade easy.!
FiTT Land Use Intensity
S CH P.lanuf. I Industrial Ctr
E CH McChord - Air Accident
Zone
+ ~ P.lcChord - Noise Zone
E Mixed Use Center (MUC)
+ ~ N'hood Bus. Dist.
E N'hood C. Dist. Area
+ EH N'hood C. Dist. Text
E ~ Parks
E Permit/Site History
+ EH Puyallup Tribe Boundar
+ EH Urban Growth Area
+ ED Water Bodies (County)
+ ED Wind Zones
CH Critical Areas
C] Critical Flood Data
CD Historic Areas (New)
01 Superfund Sites (Tac)
+i 0 Olympic View Area:
+ ~ Sitcum Cleanup
* ~ Thea Foss Cleanup
a Zoning
0t T © * liS'Page - j Tools -
S3MIB30EH
m
External
User
134.67.6.14
Related Links for ID
Double-Click on any
Object in the Map
Center of Map x: 1,160,056 y: 709,426 Lon: 122.434805° W Lat: 47.262523° N
Center of Map Location: Tacoma Power Srvc Area: Unknown Water Srvc Area: Unknown
Enar. Sc3le : 1 inch = 209 feet
I govME 2010 - Home - Contacts - Disclaimer
^ Internet
¦\ 100%
Figure 4-14. OVRA Government Made Easy Website
-------
THIS IS A REGULATED
NAVIGATIONAL AREA
Please DO NOT ANCHOR HERE
This is a Coast Guard-enforced Regulated Navigational
Area, meant to protect eelgrass meadows as well as the
sand cap below which helps to seal off contaminants.
Anchor damage to eelgrass affects habitat for whole
populations of fish (such as threatened salmon), waterfowl,
shellfish and other animals, as well as the stability of our
shorelines,
THIS IS A REGULATED
NAVIGATIONAL AREA
Please DO NOT ANCHOR HERE
This is a Coast Guard-enforced Regulated Navigational
Area, meant to protect eelgrass meadows as well as the
sand cap below which helps to seal off contaminants.
Anchor damage to eelgrass affects habitat for whole
populations offish (such as threatened salmon), waterfowl,
shellfish and other animals, as well as the stability of our
shorelines.
Figure 4-15. OVRA No Anchor Flyer (page 1)
-------
Why anchoring is not allowed in this area:
1) To protect eelgrass habitat located on-site.
2) To protect the 3-foot sand cap that was placed over
contaminated sediments as part of a cleanup by the
Environmental Protection Agency and the City ofTacoma.
Why protecting eelgrass habitat is important:
• Eelgrass meadows are a vital part of the nearshore
food web.
• Eelgrass provides important habitat for many fish and
shellfish.
• Eelgrass grows only in shallow, subtidal elevations
and is very susceptible to damage caused by
dredging, light availability and smothering sediments.
• Eelgrass communities prevent shoreline erosion by
softening wave action.
• Commencement Bay has very limited areas of
eelgrass habitat.
We understand that where there is eelgrass there are
usually fish. However, this is also why we should focus on
preserving this area by avoiding anchoring.
Washington state has lost about 33 percent of its eelgrass
habitat. Help protect the creatures that reside here by
protecting our eelgrass beds.
For more information about eelgrass:
www.ecy.wa.gov/programs/sea/pugetsound/species/
eelgrass.html
www. ptmsc. org/htm l/eelgrass.html
For more information about this site, contact Desiree Pooley
(253)502-2126.
Public Works
T Environmental Services
Surface Water Management
www.cityoftacoma.org/surfacewater
Why anchoring is not allowed in this area:
1) To protect eelgrass habitat located on-site.
2) To protect the 3-foot sand cap that was placed over
contaminated sediments as part of a cleanup by the
Environmental Protection Agency and the City ofTacoma.
Why protecting eelgrass habitat is important:
• Eelgrass meadows are a vital part of the nearshore
food web.
• Eelgrass provides important habitat for many fish and
shellfish.
• Eelgrass grows only in shallow, subtidal elevations
and is very susceptible to damage caused by
dredging, light availability and smothering sediments.
• Eelgrass communities prevent shoreline erosion by
softening wave action.
• Commencement Bay has very limited areas of
eelgrass habitat.
We understand that where there is eelgrass there are
usually fish. However, this is also why we should focus on
preserving this area by avoiding anchoring.
Washington state has lost about 33 percent of its eelgrass
habitat. Help protect the creatures that reside here by
protecting our eelgrass beds.
For more information about eelgrass:
www.ecy.wa.gov/programs/sea/pugetsound/species/
eelgrass.html
www.ptmsc.org/html/eelgrass. html
For more information about this site, contact Desiree Pooley
(253)502-2126.
Public Works
T Environmental Services
Surface Water Management
www.cityoftacoma.org/surfacewater
Figure 4-15. OVRA No Anchor Flyer (page 2)
-------
Wheeler-Osgood
Johnny's Dock
Until! j, i
Enhanc»ment
TltM Foil
snowline
H-1
Martinic
Shipyard
Fos* Landing
Marina
sa
Thea Foss
¦A4T4t1
Ip.k. W.tl
0ock Streal
Marina
Enhancement
Cable Ciduii^
Ann
19 Etptarttld*
iflan HjbilJl
m
'iaooma
Thea Foss and Wheeler-Osgood Waterways
OMMP
Figure 2-1 (Page 1 of 2)
Existing and Supplemental Sampling Locations
Legend
fTI
Completed Remedial Actions
N o Act ten
Naiutdi RffCuvflfy
Enhanced Natural Recover
| Hibn and ©Hvgr.ibon
Monument Northlno Easting
JM4 704fi5e 1161063
215 7Q3&SQ 1160953-
2T6 7SKK11 HBtQlO
FLOYD I SNIDER
fliiilfgY • * rrtf ||>e«r IM®
C*TE
WWW< WW
P iMid te
¦ |-1 W*mt)Q ma i
Figure 4-16. Thea Foss and Wheeler-Osgood Waterways (Source: EPA Year 7 OMMP 2009)
-------
Fig 4-17a. Thea Foss and Wheeler-Osgood Completed Remedial Action Areas - Part 1 of 2 (Source: City of Tacoma 2011)
-------
254
n
~L_
L Hrl
Cable Crossing
Area
Petric .
Marine
< i
H 1 t
Legend
Remedial Areas
Completed Remedial Actions:
No Action
k y i /
H. * -
Grout Mat Cap
Slope Rehabilitation
Sfc
Additional Cap Material Placement in Utilities Area
Natural Recovery
Transition Slope
Enhanced Natural Recovery
Quarry Spalls
Habitat Enhancement
Cap Placed by the Utilities
Backfill 881 @
City of Tacoma Outfall and Designation
Channel Sand Cap
@
Private Outfall (No Designation Provided)
¦
Slope Cap
Dredge to Clean
Base map generated from CAD drawings supplied by Walker
and Associates, based on a March 2006 aerial survey.
Outfall locations provided by City of Tacoma. Outfall numbers
provided by City of Tacoma or Tacoma-Pierce County Health
Department Figure E-1 (1995). Note: Outfalls monitored as part
of the City's Thea Foss stormwater monitoring program include
outfalls 230, 235, 237A, 237B, 243, 245, and 254.
Utilities Project Area
Subject to Long-Term Monitoring Under
Separate OMMP. (PacifiCorp, 2003)
r
E: dormfiytSf
Dock Marina
3 c gg n i ¦%
HEJ^LJe
©i ^ O" D
FT
w » ^
i'J'L,
//
Cable Crossing
Area
Log:-StepHabi ta t "Z
Enhancement ^ ^
Head <
Shoreline
Habitat
Foss Landing
Marina
-4 1
rock Street
Marina
!
Approximate Location
of Sheet Pile Wall
^.Qi+a Rniinrla
235
/i vncci i lie vva
(Site Boundary)
i
57A
—5fT"
FLOYD SNIDER
strategy ¦ sci e ¦ engineering
Thea Foss and Wheeler-Osgood Waterways
Annual OMMP Report
Figure 1-2 (Page 2 of 2)
Completed Remedial Actions
Fig 4-17b. Thea Foss and Wheeler-Osgood Completed Remedial Action Areas - Part 2 of 2 (Source: City of Tacoma 2011)
-------
Legend
Completed Remedial Actions:
No Action
Slope Rehabilitation
Natural Recovery
Enhanced Natural Recovery
Habitat Enhancement
Backfill
Channel Sand Cap
Slope Cap
Dredge to Clean
Benchmark Control Location and Designation
Monument Northing Easting
2018 706,952 1,160,509
Grout Mat Cap
Transition Slope
Quarry Spalls
Remedial Areas
^¦Sampli
le ID
r Enrichment
Ratio (ER)
NR-08-Y7
Cone. (|jg/kg)
ER
DEHP
1,510 J
1.16
-Analyte
nn n-i v? UJ Channel Sand Cap Performance Sample
CC-01-Y7 [± Locat.on gnd Designatjon
mr nf v7 ER Natural Recovery Performance Sample
l--y ¦ EE Location and Designation
rSC-01-Y7-I slope Cap Sample Locations
• (•) # and Designation
881 ® city of Tacoma Outfall and Designation
© Private (No Designation Provided)
Note: Enrichment ratios calculated by dividing the
sample concentration by the SQO criterion.
Notes:
• J - The analyte was analyzed and positively identified, but
the associated numerical value is an estimate.
- Base map generated from CAD drawings supplied by Walker and
Associates, based on a March 2006 aerial survey.
• For stations where both a parent and a duplicate sample were
collected, the higher detected concentrations from those
samples is reported.
• Outfall locations provided by City of Tacoma. Outfall numbers
provided by City of Tacoma or Tacoma-Pierce County Health
Department Figure E-1 (1995). Note: Outfalls monitored as part
of the City's Thea Foss stormwater monitoring program include
outfalls 230, 235, 237A, 237B, 243, 245, and 254.
• Sediment and cap performance and early warning monitoring
performed during Year 7 (May-June 2013).
Site Overview
1
t .. -
^2#
Q
No SQO Exceedances
NR-08-Y7
Cone. (|jg/kg)
ER
DEHP
1,510 J
1.16
Commencement
Raw Marino
y r~
Cable Crossing
l-Area-*"—
T~| R6(t?jc
i I M^rih
it-"'" s
SQO Exceedances
No SQO Exceedances
Commencement Bay
No SQO Exceedances
\l r
co ,"5
No SQO Exceedances
<•>
No SQO Exceedances
. No SQO Exceedances
TT
J22@
U is^
NR-11-Y7
DEHP
Cone, (kig/kg)
2,000
'
-sal-
eable Crossing -
; Area.
:oss Harbc
No SQO Exceedances
No SQO Exceedances
®fT\
:v.
C>^
N R-12-Y7/NR-12-Y7-2
Cone, (pg/kg)
ER
Benzo(a)anthracene
7,000
4.38
Benzo(a)pyrene
2,240 J
1.40
Benzofluoranthenes (total)
7,530 J
2.09
Benzo(g, h, i)perylene
1,070 J
1.49
Chrysene
34,000
12.14
Dibenz(a, h)anthracene
589 J
2.56
Fluoranthene
27,000
10.80
I ndeno(1,2,3-cd)pyrene
1,180 J
1.71
Pyrene
18,000
5.45
Total HPAH
98,600 J
5.80
DEHP
1,500
1.15
Thea's ; »' *•,
No SQO Exceedances
300
Scale in Feet
FLOYD I SNIDER
strategy ¦ science ¦ engineering
Thea Foss and Wheeler-Osgood Waterways
OMMP
Figure 2-4 (Page 1 of 2) Year
7 SQO Exceedances in
Performance Monitoring
Surface Samples (0-10 cm)
Figure 4-18a. SQO Exceedances in Year 7 (2013) - Part 1 of 2 (Source: City of Tacoma 2013)
-------
SR-13-Y7/SR-13-Y7-2
No SQO Exceedances
NR-20-Y7
Cone, (ng/kg)
ER
Dibenz(a, h) anthracene
231 J
1.00
DEHP
4,400 J
3.38
No SQO Exceedances
SR-10-Y7
Cone, (ng/kg)
ER
PCBs (total)
480
1.60
No SQO Exceedances
CC-RA9-Y7
Cone, (ng/kg)
ER
DEHP
2,670 J
2.05
No SQO Exceedances
Retried
Marine
T=*r
) Exceedances
(3
No SQO Exceedances
Legend
Remedial Areas
Completed Remedial Actions:
No Action
Slope Rehabilitation
Natural Recovery
Enhanced Natural Recovery
Habitat Enhancement
Backfill
Channel Sand Cap
Slope Cap
Dredge to Clean
Enrichment
Grout Mat Cap
Additional Cap Material Placement in Utilities Area
\\^ Transition Slope
Quarry Spalls
Cap Placed by the Utilities
rp Channel Sand Cap Performance Sample
- - t±J Location and Designation
B Natural Recovery Performance Sample
Location and Designation
9A-Y7~\ slope Cap Sample Locations
® • 9 anfJ Designation
r
W
^¦Sampli
le ID
Ratio (ER)
7
SR-13-Y7~>
881
CC-27-Y7
Cone, (ng/kg)
ER
DEHP
1,370 J
1.05
No SQO Exceedances
-Analyte
No SQO Exceedances
m
Slope Rehabilitation Sample Locations
and Designation
City of Tacoma Outfall and Designation
Private (No Designation Provided)
Note: Enrichment ratios calculated by dividing the
sample concentration by the SQO criterion.
\
Notes:
¦ J - The analyte was analyzed and positively identified, but
the associated numerical value is an estimate.
• Base map generated from CAD drawings supplied by Walker and
Associates, based on a March 2006 aerial survey.
For stations where both a parent and a duplicate sample were
collected, the higher detected concentrations from those
samples is reported.
• Outfall locations provided by City of Tacoma. Outfall numbers
provided by City of Tacoma or Tacoma-Pierce County Health
Department Figure E-1 (1995). Note: Outfalls monitored as part
of the City's Thea Foss stormwater monitoring program include
outfalls 230, 235, 237A, 237B, 243, 245, and 254.
• Sediment and cap performance and early warning monitoring
performed during Year 7 (May-June 2013).
Site Overview
n
X ^ f oSs
\
Martinac
Shipyard
N R-25-Y7/N R-25-Y7-2
Cone, (pg/kg)
ER
Anthracene
1,100
1.15
1 ndeno(1,2,3-cd)py rene
756 J
1.10
Pyrene
3,940 J
1.19
Butyl benzyl phthalate
1,190 J
1.32
DEHP
3,260 J
2.51
PCBs (total)
500 J
1.67
SC-20-Y7
Cone, (ng/kg)
ER
DEHP
1,500 J
1.15
Benzyl alcohol
120 J
1.64
,
<
i S
Pock Marina
CC-23-Y7
Cone, (ng/kg)
ER
Benzo(g, h, i)perylene
812 J
1.13
Dibenz(a, h) anthracene
239 J
1.04
I ndeno(1,2,3-cd)pyrene
889 J
1.29
DEHP
4,590 J
3.53
No SQO Exceedances
Cone. (|jg/kg)
Landing
ina
2,100 J
CC-27-Y7
Cone.
(pg/kg)
ER
DEHP
1,370 J
1.05
NR-12-Y7
See Page 1 for Data
Exceedances
4-
Cone. (Mg/kg)
1,400
Foss
No SQO Exceedances
S C-08B -Y7/S C-08B -Y7-2
No SQO Exc
'-f
Utilities
Project
Area
CC-33-Y7
Cone. (Mg/kg)
ER
DEHP
3,610 J
2.78
-SR 509 Esplanade
Riparian Habitat
235
Approximate Location
of Shoot Pile Wall
(Site Boundary)
No SQO Exceedances
;
J
'[ -ft J? —I
No SQO Exceedances
Tr
lg^ »—*
CC-32-Y7
Cone. (Mg/kg)
ER
\_
Phenanthrene
1,700
1.13
Dibenz(a, h)anthracene
261 J
1.13
DEHP
3,330 J
2.56
300
?!
=8fc
L-
Scale in Feet
FLOYD I SNIDER
strategy « science ¦ engineering
Thea Foss and Wheeler-Osgood Waterways
OMMP
Figure 2-4 (Page 2 of 2) Year
7 SQO Exceedances in
Performance Monitoring
Surface Samples (0-10 cm)
Figure 4-18b. SQO Exceedances in Year 7 (2013) - Part 2 of 2 (Source: City of Tacoma 2013)
-------
Thea Foss Waterway
GRAPH*: SCALE
s
TETRA reCH EC, INC.
Figure 3
OMMP M»ui'urnus Location Pldn
May £(~£)*
Heed of The Tfrieo Poss Wclcrvrey
Posl-Conmruclion Monitoring
RC P' "OWlr
WC iWW CAP
SC 5U - CAP
p nC-tticwiMn* (BEWiv.. srmM)
pact "iow &pf»
|! WBggWP
w ' • CO'.J'lO* i' S
y-;'.-.''; -.]¦ Cin Or —,cva .v;w APIA
SC 'UPU t.>.'t.'nG - 10? .CWU
sc sjt-- cowp :*ne.i crwwsi'E
(t-'Ocmi
A A^HrtWir CAP CO' uu; r
SHW'.f (0-10 em)
«< 1W..I **.-• «! J
SUBS'i««CE wr
SPI SMf» .
5i.fpp:"v"' 1 v* • i.'*.
'.V S „ I TO - 10 P •?; u=' B'i
' -t CITY M ' 'CO','
SPI urmm pwr 7 vgeri"
NOTES:
¦ri- »r S. -' ¦' n 1 WKJW +5 MLLW CC<
si li-. :¦> EC ON *,»r iu, 3006
re-'D-.mr, >•« sho*. wve +5 v.. ««ws ppgv^o *
M I IBM .!« UC, iWTC3 2/7/03, 1/8/07, 5/H/IH,
10/2/69 orj 10/1 :/M.
UPLMO >'•'»" I to .5 HI,
t I RFCC J n»
¦_ l-p! ,
Figure 4-19. Utilities' OMMP Monitoring Locations
-------
Blaine
PUGET SOUND RECREATIONAL
MARINE AREA NUMBERS
Used for recreational
Beiiingham fisheries management
Mount Vernon
Port Angeles
Everett
12
Seattle
o
o
Bremerton
3or
Tacoma
Olympia
10 20 40 Miles
_i I I I I I I
n
ItiatingfeR SWr drpmtment tf
'0 Health
TV» t'a%twi)tar. ttil* G»partr»rt itKM f Owrtwmv*
Nt KCVKi m of jn, «ftgnn*t 4fl thf
"KlfUHt frOTl W* ITHp KB* m« Oitft in*
Figure 4-20. Puget Sound Recreational Marine Areas (Source: DOH 2006)
Note: Commencement Bay occurs within Recreational Marine Area 11 (Tacoma-Vashon Area).
-------
®222
Corrmencement
Bay
©318
mmxWf
- JkrWA -W.,?
J' : -= V _
w, j
. • -|-
: • v-?I ?•.
*
W-,.' A ' -rt ^
iVi
Wil
ihr: *. •
**%¦ &
1 \ |i .1
7 A
? > &#•;A
Outer Bay
222
283
284
380
Central Bay
281
282
318
Southeast Bay
288
289
290
South Shoreline
285
286
287
East Bay
88
Northeast Bay
4
291
292
293
Thea Foss Waterway
294
295
296
Middle Waterway
297
298
299
Blair Waterway
300
301
302
Hylebos Waterway
303
304
305
Stations 4, 88, 222, 318, and 380 were sampled in 2008 only; all of the other stations were sampled in both 2008 (UWI)
and 1999 (PSAMP/NO.AA).
Figure 4-21. Station Locations for the 2008 Urban Waters Initiative Sediment Study
-------
Figure 5-1. Map of Asarco Area Sites (not including Ruston / North Tacoma Study Area).
-------
Defianc
sjtrtrsr:
Figure 5-2. Taxpayer Parcel Map (Source: Pierce County 2014)
Notes:
a. The taxpayer for the parcels within the green lines is the Metropolitan Park District
b. The taxpayer for the parcels (shown) within the black lines is Point Ruston LLC.
-------
-------
Study Area Zones
Tacoma Yacht Club
Point Oe fiance
LESfflfi
¦ Study Ares t
- Ruaton Town Limits,
Sell Reelflcsfnent Completed
Soli TsBlinfl fby request only)
Commencement Bay
Hale Sl
F'VeytCMfld
^1 N.4arh si
Dariert Dr
Ruby Si
R 41rti,£t
N. 41st
6L 4isl St.
N, 41stSL
WcjBnd<9_
,hU2Bth
Vaasault
Figure 5-4. Map of Ruston/North Tacoma Study Area Zones (Source EPA 2014)
-------
-------
Point
Defiance
Area of
breakwater
failure
Area to be capped by
Habitat Basin
Tacoma Yacht
Ciub building
Ferry terminal
Yacht basin
Smelter site
Limits of existing
armoring
Figure 5-6. Map of Slag Peninsula Showing Areas Where Work is Planned (Source: CH2M Hill 2013b)
Note: The area of breakwater failure will be repaired. Shoreline to be armored by EPA is shown by the
yellow-dashed line; the segment between the red arrows is not required by the ROD and may be done
by Metro Parks. Area to be capped by EPA in 2015 is shown by the yellow area with the orange border.
-------
Point
Defiance
Limits of existing
armoring
Area of
breakwater
failure
Habitat Basin
Tacoma Yacht
Club building
Ferry terminal
Approximate location of
shallow sediments to be
excavated by Point Ruston LLC
Smelter site
Figure 5-7. Approximate Location of Shallow Yacht Basin Sediments for Excavation
-------
-------
PT. DEFIANCE PARK
COMMENCEMENT BAY
[ DOWNTOWN TACOMA> ]
RUSTON WAY WATERFRONT >
& RESTAURANTS
POINT RUSTON
POINTRUSTON.COM
Figure 5-9. Map of Point Ruston Planned Development (Source: Point Ruston 2014).
© 2014 POINT RUSTON, LLC. ALL RIGHTS RESERVED
-------
LIMIT OF SEDIMENT CAP
CONSTRUCTED BY POINT
RUSTON IN 2006
NORTH DOCK
FUTURE SHORELINE
ARMORING (BY POINT
RUSTON)
ORE DOCK
FUTURE SEDIMENT
CAP (3' MINIMUM)
(BY POINT RUSTON)
COPPER DOCK
Figure 3-1
Design Capping Plan
Asarco Site Docks Demolition Project
Tacoma, WA
'arametrix
DATE: Jun 17, 2011 FILE: SU5783001p01t03F01
NOTES:
1. Bathymetric contours in feet, MLLW datum.
2. Contours from 2001 bathymetric survey,
supplemented with 2007 "post-cap"
bathymetric survey in area of sediment cap.
LEGEND
SCALE IN FEET
Figure 5-10. 2011 Former Dock Areas Capped by DNR (Source: Parametrix 2011)
2.5' Sand Cap: Flat slope area
1.0' Sand Cap: Steep Slope area
1.0' Quarry Spalls in Intertidal area with membrane pile caps
-------
Figure 6-1. Tacoma Tar Pits Site Vicinity Map (Source: EPA 2009)
-------
Figure 6-2. Tacoma Tar Pits Site Features (Source: EPA 2009)
-------
Figure 6-3. Photo of 2013 Asphalt Crack Repair in Detention Basin (Source: DOF 2014c)
-------
Figure 6-4. Aquifer Locations and Vertical Profile of Probe Sampling Results (Source: DOF 2012a)
-------
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
Figure 6-5. Benzene Influent Concentrations through 2013 (Source: DOF 2014b)
-------
AGI-13M(R)
© AGI-13S(R)
Legend
TTP-12M Monitoring Well Location
© and Designation
Note: All wells installed in
separate boreholes
©
DOF-28M
100 200
Scale in Feet
©
DOF-27M
©
MW-03
Site Boundary
Tacoma
Treatment
Plant
Surface Water Sampling Location
Refiweliocl updated 12-13.cdr
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.
Figure 6-6. Sampling Locations (Source: DOF 2014b)
-------
\ (S&'dfrK)
\ ®
TTP-18M Area *
(North Branch) \
Estimated Former Extant of
Benzene Plume I
JBwP-19
DOF-28M
<0.10(9-13)
0 150 300
Scale in Feet
E »WR-7
WP-14 1 rl
« ¦ WP-6
MW-03
/ DOF-27M <0.10(9-13)
L_/\y B J H
WP-#
SITE BOUNDARY
Legend
TTP--19U Monitoring Well Location
n c and Benzene Cone, (ug/l)
<0.5 Dec. 2013 unless otherwise
noted
Note: All wells installed in
separate boreholes
w\ VVP-13 Water Quality Probe Location
Feb. To Apr. 99
^ TW-1/P-1 Pumping Well Location
Tacoma
Treatment
Plant
r—i
V.J
i—i
v.j
Previous Estimated Area
Benzene > 53 ug/l
Estimated Area Benzene
> 53 ug/l
Estimated Area Benzene
»1000 ug/l
Approximate Trend
of Twin 48" Diameter
Sewer Lines
Refcbenejd 12_13.cdr
TTP-3M Area
(East Branch)
©
DOF-20M
<0.10(9-13)
Tacoma Historical Coal Gasification Site
Benzene Plume - December 2013
WNG-001-01 FIGURE 10 Mar. 2014
Dalton, Olmsted & Fuglevand, Inc.
Figure 6-7. Benzene Plume as of December 2013 and Data for DOF-35M, DOF-36M (Source: DOF 2014b)
-------
MW-03
&1.66
TTP-6M(R)
®2.62 1 7
100 0 100 200
Scale in Feet
Legend
® Monitoring Well Location
Note: All wells installed in
separate boreholes
© Ground Water Treatment
Well
3.39 Water Level Elevation, December 19,2013
In feet (National Geodetic Vertical Datum
- See Table 2
~ *¦' Ground-Water Contour
_—Estimated Ground-Water
Direction
SgwDec13.cdr
Tacoma
Treatment
Plant
DOF-34M
0.97
Approximate Trend
of Twin 48" Diameter
Sewer Lines
DOF-19M
yT ™*C
~ ®
DOF-20M
Tacoma Historical Coal Gasification Site
Groundwater Contours
Sand Unit - December 2013
WNG-001-01 FIGURE 7 Mar. 2014
Figure 6-8. Groundwater Contours in Sand Aquifer as of December 2013 (Source: DOF 2014b)
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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)
Figure 6-9. Benzene Plume as of December 2009 (Source: DOF 2010a)
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.
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