Inner Bellingham Bay Contaminated

Sediments

Total Maximum Daily Load

Submittal Report

September 2001

Publication No. 99-58-WQ

Bellingham Bay Contaminated Sediments

Total Maximum Daily Load

Submittal Report

Prepared by:

by

Pam Elardo, P.E.

Washington State Department of Ecology

Water Quality Program

September 2001

Publication No. 99-58-WQ
For additional copies of this document contact:

Department of Ecology

Publications Distribution Center

P.O. Box 47600

Olympia, WA 98504-7600

Telephone: (360) 407-7472

The Department of Ecology is an equal opportunity agency and does not discriminate on the

basis of race, creed, color, disability, age, religion, national origin, sex, marital status, disabled

veteran's status, Vietnam Era veteran's status, or sexual orientation.

If you have special accommodation needs or require this document in an alternative format,

please call Donna Lynch at (360) 407-7529. The TDD number is (360) 407-6006. E-mail can

be sent to dlyn461@ecy.wa.gov.
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Table of Contents

List of Tables .................................................................................................................................. ii

List of Figures................................................................................................................................. ii

Appendices...................................................................................................................................... ii

Glossary of Terms.......................................................................................................................... iii

Acknowledgements........................................................................................................................ iv

Introduction......................................................................................................................................1

Background......................................................................................................................................3

Description of Pollutant Sources .............................................................................................4

Applicable Criteria...........................................................................................................................7

Water Quality Standards..........................................................................................................7

Sediment Management Standards............................................................................................8

Model Toxics Control Act .......................................................................................................8

The 303(d) Listing Process ......................................................................................................9

Water Quality Impairments............................................................................................................13

Technical Analysis.........................................................................................................................19

Summary of Existing Conditions...........................................................................................19

Contaminated Sediment Evaluation.......................................................................................20

Sediment Recontamination Modeling Analysis.....................................................................22

Discharge Sources..................................................................................................................23

Loading Capacity...........................................................................................................................25

Load and Waste Load Allocations.................................................................................................27

Monitoring Plan Developed Under this Approach ................................................................29

Margin of Safety ............................................................................................................................31

Summary Implementation Strategy ...............................................................................................33

Overview................................................................................................................................33

Implementation Plan Development........................................................................................33

Implementation Activities......................................................................................................34

Monitoring Strategy...............................................................................................................41

Reasonable Assurance ...........................................................................................................41

Funding Sources ....................................................................................................................42

References Cited ............................................................................................................................45
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List of Tables

Table 1- Sediment Quality and Cleanup Screening Level criteria for contaminants of concern

in Inner Bellingham Bay............................................................................7

Table 2- 1998 303(d) parameter listings for Bellingham Bay (Inner) and Whatcom

Waterway by waterbody ID number (WBID), grid cell number, and site name...........12

Table 3- Comprehensive list of 303(d) grid cell numbers addressed in the Inner Bellingham Bay

TMDL (WA-01-0050)..............................................................................13

Table 4- The complete list of grid cells and parameters accounted for in this TMDL.............15

Table 5- Discharge Sources in Inner Bellingham Bay...................................................22

Table 6- 303(d) listed parameters recommended for de-listing based on analysis of data in the

development of the Bellingham Bay TMDL....................................................25

List of Figures

Figure 1. Bellingham Bay Vicinity Map

Figure 2. Generic depiction of a 303(d) listed grid cell and sediment contaminated site

Figure 3. Inner Bellingham Bay 303(d) grids, sediment sites, and outfall location

Figure 4. Potential Sediment Sources to Bellingham Bay

Figure 5. Sampling Location Plan

Figure 6. Sediment Mercury Concentrations

Figure 7. Sediment Bioassay Results

Figure 8. Sediments Exceeding Bioaccumulation Screening Level

Appendices

Appendix A: Supplemental Information

A-1: Chapter 173-204 WAC Marine Sediment Quality Standards (SQS), Puget Sound

Cleanup Screening Level (CSL), and Minimum Cleanup Levels (MCUL) -

Chemical Criteria

A-2: Complete 303(d) Contaminated Sediment Listings for Inner Bellingham Bay

A-3: Inner Bellingham Bay 1996-1998 303(d) sediment listings comparison

A-4: I&J Waterway Chemical and Biological Testing Results

A-5: Georgia Pacific Outfall, September 1999 Sediment Sampling Results

A-6: Estimated Maximum Impact/Mixing Zones near Identified Sources of Potential

Sediment Quality Concern in Bellingham Bay.

A-7: Review of Discharge Sources in Bellingham Bay

A-8: Loading Capacity Discussion for Each 303(D) Listed Grid Cell

A-9: 1998 DMMP Screening Level (SL), Bioaccumulation Trigger (BT) and Maximum

Level (ML) Guideline Chemistry Values (Dry Weight Normalized)

Appendix B: Public Participation Materials

Appendix C: Responses to Comments Received
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Glossary of Terms

BMPs- Best Management Practices

BT- Bioaccumulation Trigger

CAD- Confined Aquatic Disposal

CAP- Cleanup Action Plan

CSL- Cleanup Screening Level

CY- Cubic Yards

DMMP- Dredged Material Management Program

Ecology- Washington State Department of Ecology

EIS- Environmental Impact Statement

EPA- Environmental Protection Agency

LA- Load Allocation

MCUL- Minimum Cleanup Level

ML- Maximum Level

MTCA- Model Toxics Control Act

NPDES- National Pollutant Discharge Elimination System

PAH – Polynuclear Aromatic Hydrocarbons

PLP- Potentially Liable Parties

PSDDA- Puget Sound Dredged Disposal Analysis

PSWQMP- Puget Sound Water Quality Management Plan

RCW- Revised Code of Washington

RI/FS- Remedial Investigation/Feasibility Study

SEDQUAL - Sediment Quality Information System, an extensive database containing sediment

data from the state of Washington and other areas.

SIZ- Sediment Impact Zone

SL- Screening Level

SMS- Washington State Sediment Management Standards

SQS- Sediment Quality Standards

VCP- Voluntary Cleanup Program

WAC- Washington Administrative Code

WLA- Waste Load Allocation
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Acknowledgements

This report was created through the efforts of several people at the Department of Ecology.

Participants in Ecology’s contaminated sediment TMDL workgroup provided input and support

to this TMDL development. Steve Butkus, Rick Huey, Lucy Pebles, and Brenden McFarland

wrote key sections in their areas of expertise. More people provided vital input through

reviewing draft versions including Lucy Pebles, Sharon R. Brown, Karol Erickson, Dale Norton,

and Clay Patmont (Anchor Environmental). Other members of the contaminated sediment

TMDL workgroup (Brett Betts, Peter Adolphson, Dave Peeler, and Ron McBride) provided

essential input and project support. The primary author would also like to acknowledge those

from the public at large who provided comments on the review draft document. This provide

valuable input and contributed greatly to the final report.
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Introduction

Section 303(d) of the Federal Clean Water Act (CWA) mandates that states establish Total

Maximum Daily Loads (TMDLs) for surface waters that do not meet standards after application

of technology-based pollution controls. The U.S. Environmental Protection Agency (EPA) has

established regulations (40 CFR 130) and developed guidance (EPA, 1991) for establishing

TMDLs.

Under the Clean Water Act, every state has its own water quality standards designed to protect,

restore, and preserve water quality. Water quality standards consist of designated uses, such as

cold water biota and drinking water supply, and criteria, usually numeric, to achieve those uses.

When a lake, river or stream fails to meet water quality standards after application of required

technology-based controls, the Clean Water Act requires that the state place the water body on a

list of "impaired" water bodies and to prepare an analysis called a Total Maximum Daily Load

(TMDL).

The goal of a TMDL is to ensure impaired waters will attain water quality standards. A TMDL

includes a written, quantitative assessment of water quality problems and of the pollutant sources

that cause the problem. The TMDL determines the amount of a given pollutant, which can be

discharged to the water body and still meet standards, called the loading capacity, and allocates

that load among the various sources. If the pollutant comes from a discrete source (referred to as

a point source) such as an industrial facility’s discharge pipe, that facility’s share of the loading

capacity is called a waste load allocation. If it comes from a diffuse source (referred to as a

nonpoint source) such as a farm, that facility’s share is called a load allocation.

The TMDL must also consider seasonal variations and include a margin of safety that takes

into account any lack of knowledge about the causes of the water quality problem or its loading

capacity. The sum of the individual allocations and the margin of safety must be equal to or less

than the loading capacity.

The Washington State Department of Ecology (Ecology) is establishing a TMDL submittal for

Inner Bellingham Bay to address impairments due to potential toxic effects from contaminated

sediments in Bellingham Bay based on the 1998 Section 303(d) list of impaired waterbodies. The

list contains 31 separate parameters at several locations in Inner Bellingham Bay. The

contaminated areas addressed in this TMDL are those areas identified in the state’s 1998 303(d)

list and other areas that would have been included in the list if evaluated using current data.

This TMDL submittal documents new data that demonstrates meeting state standards for the

majority of the parameters on the current 303(d) list. The remaining parameters addressed in this

submittal are those currently violating state standards or those in need of establishing wasteload

allocations (see Table 4, Page 16).

As a summary, the five elements of the Bellingham Bay Contaminated Sediments TMDL as

required by the Clean Water Act are:

Loading Capacity
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The loading capacity for this TMDL is the combination of the waste load and load

allocations for the existing dischargers, which will fully meet the requirements of the

Sediment Management Standards for sediment quality. The loading capacity throughout

Inner Bellingham Bay is the mass loading (mg/kg) from historic and ongoing sources that

maintains compliance with the state Sediment Management Standards. For Inner

Bellingham Bay, the loading capacity is defined as the mass-based discharge that

maintains compliance with sediment quality standards (e.g., for mercury: 1.2 mg/kg;

phenol: 420 μg/kg; 4-methylphenol: 670μg/kg; wood debris: <50% by volume). The

implementation strategy employs cleanup, source control, and monitoring to achieve

compliance for all sediment quality parameters and to track potential recontamination

problems.

Waste Load Allocations

Georgia-Pacific West, Inc.- the Waste Load Allocation for the Georgia-Pacific West,

Inc. (G-P) wastewater discharge of total mercury to Bellingham Bay is 0.014 kg/day

average mass loading. This was based on the existing NPDES permit and detailed

receiving water modeling and monitoring presented in the Whatcom Waterway Final

Remedial Investigation/Feasibility Study (Anchor Environmental/Hart Crowser, 2000).

Other Point Sources- Wasteload Allocations are applied to the stormwater sources in

Inner Bellingham Bay. No ongoing sources have been documented as currently

contributing to the sediment quality impairments in Inner Bellingham Bay. Where the

discharge from any facility is not currently, nor expected to, result in sediment

contamination to the SQS criteria, a WLA is not calculated. If a WLA were provided up

to the SQS level, Ecology would in effect be allowing a greater mass loading of sediment

contaminants than is currently released from these facilities. Compliance with the state’s

Sediment Management Standards (SMS) for each potential source is assured through site

cleanups and long-term monitoring. The goal of this TMDL is to maintain compliance

with the chemical and biological criteria for sediment quality in the SMS rule.

Load Allocations

There are no identified non-point sources contributing to Inner Bellingham Bay. All

municipal and industrial stormwater sources are defined as point sources under NPDES

permit rules.

Margin of Safety

The margin of safety is implicit due to the conservative assumptions that have been used

throughout the analyses.

Seasonal Variation

Contaminated sediments in Bellingham Bay do not exhibit general variations related to

seasons. The identified implementation strategies are applicable year round.
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Background

Bellingham Bay is an urban bay in the heart of the city of Bellingham in northwest Washington

State. The bay is an essential feature for navigation, commerce, and recreation in the region.

Like many urban bays in Puget Sound, contaminated marine sediments are a legacy of past

industrial practices that can pose a present threat to marine life and public health.

The Department of Ecology has developed the Inner Bellingham Bay Contaminated Sediment

TMDL in response to the listing of contaminated sediments on the 1998 303(d) list. The purpose

of this TMDL is to assure the CWA requirements are satisfied to ensure the sediment quality in

the bay meet Washington State Standards.

The Inner Bellingham Bay Contaminated Sediment TMDL is designed to:

• Identify the portions of Bellingham Bay that are and designated on the 303(d) list as impaired

due to contaminated sediments;

• Summarize the degree of sediment contamination;

• Review the applicable standards and regulatory procedures for improving sediment quality;

• Provide information on the technical analysis and modeling approach used for sediment

remediation and source control;

• Identify direct dischargers to Inner Bellingham Bay;

• Identify sediment remediation (cleanup) and discharge source performance expectations

(wasteload allocations ) for Inner Bellingham Bay; and

• Document the implementation strategy for achieving compliance with the state Sediment

Management Standards.

The geographic area of the Bellingham Bay Project and this TMDL is given in Figure 1.

The Bellingham Bay Contaminated Sediment TMDL Submittal Report analyzes the existing data

and information to verify if the information is sufficient to satisfy the TMDL requirements. The

TMDL Submittal Report puts forth and overview of the information, data, analysis, available

regulatory tools, and implementation activities that will be used in Inner Bellingham Bay to

achieve compliance with the Washington State Sediment Management Standards. Assuring

compliance with the SMS is the goal of this TMDL submittal.

Over the past several years, the Bellingham Bay Demonstration Pilot Work Group has been

working pursuing a comprehensive approach to the contaminated sediment problems in

Bellingham Bay. The Pilot Work Group is an initiative of the Cooperative Sediment

Management Program and is made up of 15 federal, state and local entities charged with

addressing and coordinating contaminated sediment cleanup needs and other key management

issues. The Pilot Project is designed to expand opportunities for achieving multiple goals in

Bellingham Bay beyond sediment cleanup and sediment disposal to include source control,

habitat restoration, and aquatic land use.
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The Pilot Work Group members include:

• U.S. Army Corps of Engineers

• U.S. Fish and Wildlife

• U.S. Environmental Protection Agency

• National Marine Fisheries Service

• Washington State Department of Ecology

• Washington State Department of Natural

Resources

• Washington State Department of

Transportation

• Washington State Department of Fish and

Wildlife

• Puget Sound Water Quality Action Team

• City of Bellingham

• Port of Bellingham

• Whatcom County Health Department

• Lummi Nation

• Nooksack Tribe

• Georgia-Pacific West, Inc.

Sediment sampling in Bellingham Bay has found mercury and other contaminants at levels that

exceed the state Sediment Management Standards (SMS) chemical criteria. Through Ecology’s

contaminated site determination process, several areas in Bellingham Bay have been identified as

being in violation of the SMS and were subsequently placed on the 303(d) list. Table 2 (Page

12) gives the 1998 303(d) list for Inner Bellingham Bay. The contaminated areas identified in

the 303(d) list correspond with the priorities identified in the Bellingham Bay Pilot Project. This

TMDL does not address the Inner Bellingham Bay water column impairments on the 303(d) list

(fecal coliform and pH).

The Inner Bellingham Bay Contaminated Sediment TMDL draws heavily from the work

conducted by members of the Pilot Work Group, both individually and collectively, to meet the

requirements of the CWA. This contaminated sediment TMDL is one of the first of its kind

nationwide. It is designed to bring together the cleanup and source control efforts from sediment

remediation program and the source control and evaluation methods available through the state

water quality programs to improve and protect sediment quality in Inner Bellingham Bay and

ultimately meet state standards for sediment quality.

The sediment cleanup and source control activities for the parameters addressed in this TMDL

are conducted by the individual responsible parties through the Department of Ecology’s

authority under the Model Toxics Control Act (MTCA, Chapter 173-340 WAC), Water Quality

Standards for Surface Waters in the State of Washington (Chapter 173-201A), the National

Pollutant Discharge Elimination System Permit Program (NPDES, Chapter 173-220), and the

Sediment Management Standards (SMS, Chapter 173-204 WAC).

Description of Pollutant Sources

The purpose of this TMDL is to address the water quality concerns related to the existing

sediment contamination and to assess potential ongoing sources which may adversely impact

sediments.

The presence of contaminated sediments in Inner Bellingham Bay has been documented to be

due to historical practices. No ongoing sources have been identified as causing violations of

marine Sediment Quality Standards, however, some sources may affect small areas of the bay

immediately adjacent to outfall pipes (Anchor Environmental 1999). Source control and

monitoring activities are to be used to verify predictions about capability for stormwater sources
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to cause sediment contamination or recontamination. There are no non-stormwater point source

dischargers in Inner Bellingham Bay with the exception of Georgia-Pacific West.

The Bellingham Bay Demonstration Pilot Project generated and proposed for public comment a

Comprehensive Strategy that identifies a range of remedial alternatives for priority sediment

cleanup sites and provides guidance for cleanup activities that coincide with 303(d) listed areas

in Inner Bellingham Bay. However, the Comprehensive Strategy extends beyond TMDL needs

in area and scope. Nonetheless, this TMDL has been developed to be consistent with the broad

range of sediment cleanup plans and activities identified in the Bellingham Bay Comprehensive

Strategy.
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Applicable Criteria

Water Quality Standards

Within the State of Washington, water quality standards are published pursuant to Chapter 90.48

of the Revised Code of Washington (RCW). Authority to adopt rules, regulations, and standards

as are necessary to protect the environment is vested with the Department of Ecology. Under the

Federal Clean Water Act, the EPA Regional Administrator must approve the water quality

standards adopted by the state (Section 303(c)(3)). Through adoption of these water quality

standards, Washington has designated certain characteristic uses to be protected and the criteria

necessary to protect these uses [Washington Administrative Code (WAC), Chapter 173-201A].

These standards were last adopted in November 1997.

The characteristic uses designated for protection in Bellingham Bay are as follows:

"Characteristic uses. Characteristic uses shall include, but not be

limited to, the following:

(i) Water supply (domestic, industrial, agricultural).

(ii) Stock watering.

(iii) Fish and shellfish:

Salmonid migration, rearing, and harvesting.

Other fish migration, rearing, spawning, and harvesting.

Clam, oyster and mussel rearing and spawning,

Crustaceans and other shellfish rearing, spawning, and

harvesting.

(iv) Wildlife habitat.

(v) Recreation (secondary contact recreation, sport fishing,

boating, and aesthetic enjoyment).

(vi) Commerce and navigation."

[WAC 173-201A-030(3)]

The water quality standards incorporate the Sediment Management Standards by reference.

“Compliance with the surface water quality standards of the State of Washington require

compliance with...chapter 173-204 WAC, Sediment Management Standards.”

[WAC 173-201A-010(3)]

This TMDL is designed to address impairments of characteristic uses caused by toxic effects of

contaminated sediments. The Sediment Management Standards (SMS) define criteria for toxic

substances for the protection of characteristic uses. Twenty-five (25) toxic substances and

sediment bioassay failure are responsible for the original 303(d) listings in Inner Bellingham

Bay. However, recent data has revealed that there are only 10 parameters currently in

exceedance of the sediment quality standards. The reduction in parameters from the original

303(d) list will be discussed in more detail under the “Water Quality Impairments” section.

The following section provides background and discussion on the applicable criteria in the

Sediment Management Standards (SMS). The Model Toxics Control Act (MTCA) and how

SMS and MTCA work together under the 303(d) list and TMDL development are also presented

below. The SMS and MTCA rules are the primary tools for setting the standards and the

implementation mechanisms for this TMDL.
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Sediment Management Standards

In 1991, the Washington State Department of Ecology adopted the Sediment Management

Standards (SMS), Chapter 173-204 WAC, to identify and designate sediments that have adverse

effects on aquatic organisms or pose significant health risk to humans. The standards established

a sediment quality goal for Washington State. The standards also include the requirements for

how the standards are applied in source control and cleanup actions. The regulation includes

numeric chemical and biological standards to address ecological effects of impaired marine

sediment quality in Puget Sound. Sediment criteria for human health, freshwater, and other

marine areas must be addressed on a site-specific, case-by-case basis.

The narrative sediment quality goal of the SMS is defined as no acute or chronic adverse effects

to biological resources and no significant risk to humans (WAC 173-204-100). The Sediment

Quality Standards (SQS) (WAC 173-204-320) include the Puget Sound marine numeric

chemical and biological standards based on the goal of no acute or chronic adverse effects. The

chemical standards are sufficient to identify priority areas and define areas warranting further

investigation. The framework in the SMS establishes that the biological tests override the

chemical results under WAC 173-204-310(2), confirmatory designation, which states “Sediment

samples that pass all the required confirmatory biological tests are designated as passing the

applicable sediment quality standards of WAC 173-204-320”. Therefore, for example, when

sediments do not meet quality criteria based on numerical chemical results, but do demonstrate

compliance with biological standards, then the sediments are considered in compliance with

SMS based on the principle of biological override.

The SMS also contain provisions for managing exceedances of the SQS (hence, the regulation is

titled the "Sediment Management Standards" instead of simply the Sediment Quality Standards).

The substantive requirements for how the SQS exceedances will be addressed for source control

and cleanup are described Parts IV and V, respectively, of the SMS (WAC 173-204-400 through

590). Key to both Parts IV and V is the concept of the maximum allowable level for sediment

concentrations, known as the Sediment Impact Zone Maximum Level (SIZmax) (WAC 173-204-

420), the Cleanup Screening Level (CSL) (WAC 173-204-520), and the Minimum Cleanup

Level (MCUL) (WAC 173-204-520). The standards for SIZmax, CSL, and MCUL are

equivalent. Appendix A-1 describes the numeric criteria for SQS and CSL from the Sediment

Management Standards.

The parameters addressed in this TMDL are those that currently exceed the applicable sediment

standards in parts of Inner Bellingham Bay. Although the 1998 303(d) list for Inner Bellingham

Bay includes a limited area as defined by grid cells, this TMDL submittal expands the area to

include all grid cells that contained impaired sediments even if not currently on the 303(d) list.

In other words, it includes areas that would be on the 303(d) list if they were evaluated using

current data. The 1998 303(d) list is presented in detail in Table 2 of the following section and in

Appendix A-2. Appendix A-3 contains a comparison of the 1996 and 1998 303(d) listings for

Inner Bellingham Bay. This TMDL submittal address all 303(d) parameter listings and grid cells

through either demonstrating compliance with standards by review of current data or defining a

wasteload allocation. The compete list of parameters addressed in this TMDL is given in Table

4 (page 17).

Table 1- Sediment Quality and Cleanup Screening Level criteria for

selected sediment contaminants in Inner Bellingham Bay.
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SMS Parameter

Marine Sediment

Quality Standards (SQS)

Marine Cleanup Screening

Level (CSL)

mg/kg dry weight mg/kg dry weight

Mercury 0.41 0.59

Copper 390 390

Zinc 410 960

Lead 450 530

Arsenic 57 93

mg/kg carbon mg/kg carbon

PCBs 12 65

μg/kg dry weight μg/kg dry weight

Phenol 420 1200

4-methylphenol 670 670

Sediment bioassay (1) (2)

Wood waste 50% by volume3

1. The biological effects criteria under SQS are based on the premise of “no adverse effects on biological

resources”, defined by specific test results for any one of five marine sediment biological tests. The

specific tests and target endpoints can be found in WAC 173-204-320(3). Under the SMS, if a sediment

sample exceeds the numeric criteria, but pass the confirmatory biological tests, the sample location is

considered “clean” or in compliance with the SQS.

2. The biological effects criteria under CSL are based on “minor adverse effects in marine biological

resources” and are designed to screen sediment station clusters to define clusters of potential concern

using the results of two acute and one chronic effects tests. The specific tests and target endpoints for

CSL biological effects criteria for Puget Sound marine sediments can be found in WAC 173-204-520(3).

3. The Sediment Management Standards provide authority in WAC 173-104-520(5) to require cleanup of

“other deleterious substances” on a case-by-case basis. The Department of Ecology has determined that a

50% wood waste by volume criteria is a level below which only minor adverse effects may result in

marine sediments (Kendall and Michelsen, 1997).

Some of the key concepts of the Sediment Management Standards applicable to contaminated

sediments and TMDLs in general include:

• Sediment Impact Zones (WAC 173-204-415) are sediment quality dilution zones that

may be authorized around outfalls for ongoing sources predicted to cause sediment

quality to exceed the SQS. Levels must not exceed SIZmax (equivalent to CSL). Under

WAC 173-204-410(1)(b), one of the goals of the SMS is to minimize or eliminate the

existence of SIZs whenever practicable. Nonetheless, SIZs remain a tool to be used

under SMS if absolutely necessary. No SIZs are recommended under the Inner

Bellingham Bay TMDL submittal.

• Cleanup Site Identification Process (WAC 173-204-530) – The numeric CSL values

provide the basis for defining contaminated sediment “sites”, which are typically

addressed by either the Department of Ecology’s Toxics Cleanup Program under the

Model Toxics Control Act (see section below) or the EPA under federal authority. The

average of three adjacent stations must exceed the CSL in order to be designated as a

cleanup site. If concentrations exceed the SQS, but a group of stations are not designated

as a cleanup site, it is termed a "station cluster of low concern" and not subject to cleanup

actions (WAC 173-204-510(4)).
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• Sediment Recovery Zones (WAC 173-204-590) are sediment quality dilution zones that

may be granted for a limited time (10 years or less) to cleanup actions where the selected

remedy leaves sediment that exceeds the SQS in place if the area is predicted to recover

through natural processes.

• Sediment Quality Inventory (WAC 173-204-350)- The Sediment Quality Information

System (SEDQUAL) was developed by the state to gather available data on sediments

and produce an inventory of sediment sampling stations which pass or fail applicable

standards.

The goal of the Bellingham Bay Comprehensive Strategy is to carryout cleanup actions and

implementation activities that meet and maintain sediments in compliance with the SQS criteria.

Therefore, this TMDL and associated cleanup and source control activities will not be requesting

the authorization of Sediment Recovery or Impact Zones for any sediment area or discharger,

respectively.

Model Toxics Control Act

The Model Toxics Control Act (MTCA) is the administrative/implementation component of the

Sediment Management Standards used to address contaminated sediment remediation in

Washington State. The state’s Water Pollution Control Law (Chapter 90.48 RCW) can also be

used by the Department of Ecology to compel sediment cleanup. The responsibility for

implementing MTCA rests with Ecology’s Toxic Cleanup Program.

Through MTCA, the Department of Ecology has the legal authority to force a responsible party

to cleanup a contaminated site. However, Ecology prefers to achieve cleanups through

cooperative means with potentially liable parties (PLPs). Therefore, the MTCA rules are

designed to encourage PLPs to initiate cleanup actions, provide an open public process, and

facilitate cooperative agreements rather than Ecology-initiated enforcement orders.

Negotiated agreements are one way in which Ecology and PLPs can work cooperatively in

reaching cleanup solutions. Formal agreements under MTCA include consent decrees and

agreed orders. A consent decree is a formal legal agreement filed in court and constitutes a

settlement with the Department of Ecology. The work requirements in the decree and the terms

under which it must be done are negotiated and agreed to by the PLP, Ecology, and the state

Attorney General’s office. An agreed order, unlike a consent decree, is not filed in court and is

not a settlement. Rather, it is a legally binding, administrative order issued by Ecology and

agreed to by the PLP. Agreed orders are available for remedial investigations, feasibility studies,

and final cleanup actions. Both consent decrees and agreed orders must undergo a public review

and comment process.

Under Ecology’s Voluntary Cleanup Program (VCP) responsible parties can request technical

assistance from Ecology to address contaminated sites. This informal consultation arrangement

is non-binding for both the responsible parties and Ecology, however, it is an effective

mechanism to provide greater assurance that actions are likely to occur and meet state

requirements.

The rules that guide the cleanup process lay out each step of the process to ensure that cleanup

actions are thorough and protective of human health and the environment. The following is a

description of the steps typically taken for the cleanup of contaminated sediment sites.
DRAFT

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Screening and Evaluation of Contaminated Sites under MTCA

1. Sediment quality standards inventory (WAC 173-204-350) is an identification process that

screens all sediment station clusters. A cluster is a collection of contiguous stations.

Ecology analyzes the sediment sampling data to identify station clusters of potential concern

and station clusters of low concern per the standards of this section. Station clusters of

potential concern are further evaluated using the hazard assessment standards of WAC 173-

204-530. Station clusters of low concern remain on the inventory and no further cleanup

action determinations are taken by Ecology, but the stations are to be reexamined at a future

date.

2. Hazard assessment and site identification (WAC 173-204-530)- A hazard assessment is

performed to gather existing and available information to further characterize each station

cluster of potential concern.

3. Identification of cleanup sites – when the average chemical concentration of the three

highest stations from a station cluster of potential concern exceeds the CSL, the cluster is

defined as a cleanup site.

4. Sediment site ranking process (SEDRANK)- Ecology prepares and maintains a list of

contaminated sediment sites in the order of their relative health and environmental risk

(hazard ranking, WAC 173-204-540). This information is used as a planning and evaluation

tool to direct cleanup resources.

5. Remedial investigation/feasibility studies (RI/FS)- a state RI/FS defines the nature and

extent of contamination at a site, provides information to establish a cleanup target, and

evaluates potential remedial alternatives.

6. Determining the cleanup target- while the Sediment Management Standards maintain SQS

criteria as the cleanup goal, site specific cleanup targets are developed using a multiple-step

process. Information from the RI/FS is analyzed to determine the potential for natural

recovery and to establish the volumes or areal extent of sediments requiring remediation.

Next, factors affecting the net environmental benefit, costs, and technical feasibility of a full

range of cleanup options are evaluated. Human health and ecological risk assessment tools

are then used to weigh the benefits, costs, and feasibility to determine an optimal cleanup

standard, typically ranging between the SQS value and the higher minimum cleanup level

(MCUL) standard.

7. Selection of cleanup action- based on the RI/FS, a cleanup action plan is developed. The

plan identifies a preferred cleanup alternative and specifies cleanup standards at the site.

8. Site cleanup- actual cleanup begins when, following public comment, the cleanup action

plan is approved by Ecology. This includes design, construction, operation and monitoring

of cleanup actions as well as long term environmental monitoring to assure continued

compliance with standards.

9. Delisting- a sediment site can be taken off the contaminated site list after cleanup is

completed and Ecology determines cleanup standards have been met.

The 303(d) Listing Process

The Department of Ecology established a system of grids throughout Puget Sound to identify

water quality impaired areas. In 1996, Ecology’s Sediment Management Unit identified
Page 10 Bellingham Bay ContSediments TMDL

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contaminated sediment sites throughout Puget Sound in the Sediment Management Standards

Contaminated Site List (Ecology, 1996). The 1998 303(d) list for the State of Washington then

identifies the impaired sediment areas in the Contaminated Site List using the 303(d) grid system

and lists the associated parameters of impairment. The grid system does not necessarily conform

to the shape of a contaminated site defined in the SMS process. Furthermore, the data used to

develop the sediment site list, including the 1996 list, is intended to identify areas of potential

contamination (station clusters of concern). These data may not be comprehensive in nature and

therefore, confirmation of contamination and/or the extent and severity of contamination can

only be identified after a Sediment Remedial Investigation process has been completed.

Although an entire grid cell may be listed on the 303(d) list, the Remedial Investigation (RI) may

result in the determination of the site as clean, or confirmation of site contamination. The RI

would then be used to establish the boundaries of contamination by examining all sediment data

within the grid cell as well as adjacent grid cells. If a site is confirmed as being contaminated,

and the site boundaries established, the contaminated site boundaries may represent the only

portion of a 303(d) grid cell that is identified as contaminated on the 303(d) list. The remainder

of the 303(d) grid cell that is outside the boundary of a contaminated site is not considered

contaminated under SMS. There may, however, be individual data points that exceed SMS

numeric and/or bioassay contamination criteria within a listed grid area. If these data points are

not contiguous with a minimum of 2 other data points that also exceed SMS contaminant criteria,

these non-contiguous, individual data points do not constitute a station cluster. These occasional

data outliers are therefore not considered in exceedance of SMS numeric and/or bioassay criteria

and are not targeted for cleanup. Ecology examines the whole breadth of available data at each

station to define areas of contamination. Figure 2 (next page) provides an illustration of

contaminated sites within the structure of the 303(d) water grid system.
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 Figure 2- Generic depiction of a 303(d) listed grid cell and sediment contaminated sites.
Page 12 Bellingham Bay ContSediments TMDL

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Water Quality Impairments

The key areas of Inner Bellingham Bay on the 303(d) list are identified as Whatcom Waterway,

I&J Waterway, G-P Outfall, and Harrison Avenue Shipyard. Four “water grid cells” are

identified on the 303(d) list for impairments due to contaminated sediment. The 303(d) grid cell

identification numbers, common site names, and the sediment quality impairment parameters are

given in Table 2. A more detailed 303(d) list for Inner Bellingham Bay can be found in

Appendix A-2. The Inner Bellingham Bay water column listings and Outer Bellingham Bay

sediment listings are not addressed in this TMDL.

Table 2- 1998 303(d) parameter listings for Bellingham Bay (Inner) and Whatcom

Waterway by waterbody ID number (WBID), grid cell number, and site name.

WBID Grid cell #1 Cleanup site name Parameters

WA-01-0050 H4E8 Whatcom Waterway Sediment bioassay

H4E9 Whatcom and I&J Waterways 2,4-Dimethylphenol

2-Methylnaphthalene

Acenapthene

Anthracene

Arsenic

Benz(a)anthracene

Benzo(a)pyrene

Benzo(b,k)fluoranthenes

Benzo(ghi)perylene

Bis(2-ethylhexyl)phthalate

Chrysene

Copper

Dibenz(a,h)anthracene

Dibenzofuran

Fluoranthene

Fluorene

Indeno(1,2,3-cd)pyrene

Mercury

Pentachlorophenol

Phenanthrene

Phenol

Pyrene

Zinc

H5D12 G-P Outfall Mercury

H5C1 Harris Avenue Shipyard PCBs

Phenol

Zinc

Copper

Mercury

Arsenic

Lead

1

 In the actual grid classification system, the numbers 48122 precede each grid cell number.

 Therefore, “H4E9” is actually “48122H4E9”.

2 Cell number H5D1 was incorrectly identified as H5D0 in the 1998 303(d) list for the G-P Outfall.
Page 14 Bellingham Bay ContSediments TMDL

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The 303(d) list for Inner Bellingham Bay contains 31 separate parameters and locators. When

comparing the 303(d) listed grid cells to the contaminated sites in Inner Bellingham Bay, it was

discovered that the grid cells present on the 303(d) list do not encompass all the sediment

impaired areas identified in the Bay. Therefore, water grid cell numbers H4F9, H4D9, and

H5D0 have been added and addressed in this TMDL. These additions include impaired sediment

areas adjacent to Cornwall Avenue Landfill and Starr Rock, a former sediment disposal facility.

Figure 3 depicts the location of each grid cell and site. Table 3 provides the comprehensive list

of 303(d) grid cells and associated site names addressed in this TMDL. The parameters and

grids cells on the 1998 303(d) list as well as additional grid cells and parameters are subject to

the cleanup and monitoring activities identified in this TMDL.

Table 3- Comprehensive list of 303(d) grid cell numbers addressed in

the Inner Bellingham Bay TMDL (WBID=WA-01-0050).

Grid cell # Cleanup site name1 Grid cell listed

on the 1998 303(d) list?

Additional cell-parameters

addressed in this TMDL if

not included in 1998 list

H4E8 Whatcom Waterway yes

H4F92 Whatcom and I&J

Waterways

no (same as Whatcom

Waterway)

H4E9 Whatcom Waterway3 yes

H5E04 Whatcom Waterway no (same as Whatcom

Waterway)

H5D1 G-P Outfall yes

H5D05 Whatcom Waterway

(Starr Rock)

no (same as Whatcom

Waterway)

H4D95 Whatcom Waterway and

Cornwall Avenue Landfill

no mercury, phenol, 4-

methylphenol, PCBs, wood

waste

H5C1 Harris Avenue Shipyard yes

1. All the cleanup sites are within the identified gird cells being address by the TMDL. Cleanup site

areas are the footprints addressed by the remediation process and do not necessarily correspond

exactly to the 303(d) grid system

2. H4F9 is grid cell within the Whatcom Waterway that was identified as containing a contaminated

area in the Whatcom Waterway RI/FS. It is an additional grid cell for this TMDL. The parameters

addressed include those originally identified for Whatcom Waterway.

3. H4E9 is exclusively in Whatcom Waterway, not “Whatcom and I&J Waterways” as originally

identified in the 303(d) list.

4. Grid cell H5E0 was characterized extensively in the Whatcom Waterway RI/FS and is considered

part of this TMDL evaluation. This grid cell is not on the 1998 303(d) list, but was originally present

on the list developed in 1996.

5. H5D0 and H4D9 are grid cells within Whatcom Waterway that were identified as containing

contaminated footprints in the RI/FS, but not included on the 1998 303(d) list.

The following section describes each of the 303(d) listing water gird cells and the sediment

parameters responsible for the listing. The physical location of each grid cell is illustrated in

Figure 3. In the following and subsequent analysis, I&J Waterway is dealt with separately from

Whatcom Waterway. The parameters of concern and cleanup boundaries are distinct between

the two areas and are treated accordingly.

Water grid cells # H4F9, H4E8, H4E9, H4D9, H5D0, H5E0- Whatcom Waterway
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Sediment Parameters: 2,4-Dimethylphenol, 2-Methylnaphthalene, Acenapthene, Anthracene,

Arsenic, Benz(a)anthracene, Benzo(a)pyrene, Benzo(b,k)fluoranthenes, Bis(2-

ethylhexyl)phthalate, Chrysene, Copper, Dibenz(a,h)anthracene, Dibenzofuran, Fluoranthene,

Fluorene, Indeno(1,2,3-cd)pyrene, Mercury, Pentachlorophenol, Phenanthrene, Phenol, Pyrene,

Zinc and sediment bioassay.

Recent (1996 and 1998) sampling in Bellingham Bay revealed that all the 303(d) parameters in

the Whatcom Waterway meet SQS chemical criteria in WAC 173-204-320, except for mercury,

phenol, and sediment bioassay (Anchor Environmental/Hart Crowser, 2000). Due to natural

recovery processes, the list of contaminants in the 303(d) list are not consistent with the recent

characterization of the area. Furthermore, sampling has shown 4-methylphenol to exceed the

SQS chemical criteria and wood debris to exceed a derived standard based on narrative criteria at

some locations within the Whatcom Waterway study area. Neither 4-methylphenol nor wood

debris are currently on the 303(d) list for Bellingham Bay.

This TMDL addresses all 303(d) parameters in Whatcom Waterway. Five parameters (mercury,

phenol, 4-methylphenol, sediment bioassay, wood debris) are part of active cleanup activities

and addressed in the implementation activities of this TMDL. The remaining listed parameters

(2,4-dimethylphenol, 2-methylnaphthalene, acenapthene, anthracene, arsenic, benz(a)anthracene,

benzo(a)pyrene, benzo(b.k)fluoranthenes, benzo(ghi)perylene, bis(2-ethylhexyl)phthalate,

chrysene, copper, dibenz(a,h)anthracene, dibenzofuran, fluoranthene, fluorene, indeno(1,2,3-

cd)pyrene, pentachlorophenol, phenanthrene, phenol, pyrene, and zinc) have been shown to be in

compliance with the SQS criteria of WAC 173-204-320 in Whatcom Waterway due to the

natural deposition of clean sediments. (Anchor Environmental/Hart Crowser, 2000). The

sampling data are sufficient to de-list these parameters in the next 303(d) listing cycle.

Water grid cell # H4F9 - I&J Waterway

Sediment Parameters: none.

Surface sediment sampling in I&J Waterway demonstrates consistent compliance with WAC

173-204-320 for all listed parameters on the 303(d) list. Occasionally, levels of mercury have

exceeded the state SQS numerical criteria, however, all confirmatory biological testing data

demonstrate compliance with the state SQS biological effects criteria. Appendix A-4 shows the

I&J Waterway analytical and biological data. The Sediment Management Standards under WAC

173-204-310(2), confirmatory designation, states “Sediment samples that pass all the required

confirmatory biological tests are designated as passing the applicable sediment quality standards

of WAC 173-204-320”. The data from I&J Waterway therefore demonstrates compliance with

SQS criteria. The recent sampling data are sufficient to de-list all parameters in the next 303(d)

listing cycle. This is presented in more detail in the following Technical Analysis section of this

report.
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Water grid cell # H5D1- Georgia Pacific Outfall

Sediment parameters: mercury.

Mercury was the sediment parameter original responsible for listing this grid cell on the state’s

303(d) list. However, surface sediment sampling at the G-P Outfall (Anchor Environmental,

2000A) demonstrates that a mercury sediment cleanup site no longer exists as defined under

WAC 173-204-530. Therefore, the area is in compliance for mercury under the Sediment

Management Standards and no cleanup actions will be taken. More detail on the G-P Outfall is

presented in the Technical Analysis section.

Water grid cell # H4D9 – Cornwall Avenue Landfill (Whatcom Waterway)

Sediment Parameters: mercury, phenol, 4-methylphenol, PCBs, and wood waste.

Cornwall Avenue Landfill is a site that was not originally identified in the 1998 303(d) list.

However, in 1996, the Port of Bellingham, City of Bellingham, and Washington State

Department of Natural Resources performed an expanded site investigation and determined the

landfill is actively eroding into Bellingham Bay. The investigation revealed that the nearshore

sediments are composed mostly of solid waste debris and contain elevated levels of metals and

organics.

Water grid cell # H5C1- Harris Avenue Shipyard

Sediment parameters: PCBs, phenol, zinc, copper, mercury, arsenic, lead.

All seven parameters for Harris Avenue Shipyard are being addressed in the RI/FS work

conducted by the Port of Bellingham. Sampling data and planned cleanup activities are

sufficient to de-list these parameters in the next 303(d) listing cycle.

For summary purposes, Table 4 provides a complete description of the grid cells and parameters

addressed in this TMDL. As noted above, many parameters will be proposed for de-listing in the

next cycle, while some will be addressed directly through the TMDL process (e.g., mercury,

phenol, 4-methylphenol, sediment bioassay, and wood debris in Whatcom Waterway).
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Table 4- The complete list of grid cells and parameters accounted for in this TMDL.

WBID Grid cell #’s Cleanup site name Parameters

WA-01-0050 H5D0* Whatcom and I&J Waterways Sediment bioassay

H5E0* (includes Cornwall Avenue 2,4-Dimethylphenol

H4D9* Landfill) 2-Methylnaphthalene

 H4E8 4-Methylphenol*

 H4E9 Acenapthene

H4F9* Anthracene

Arsenic

Benz(a)anthracene

Benzo(a)pyrene

Benzo(b,k)fluoranthenes

Benzo(ghi)perylene

Bis(2-ethylhexyl)phthalate

Chrysene

Copper

Dibenz(a,h)anthracene

Dibenzofuran

Fluoranthene

Fluorene

Indeno(1,2,3-cd)pyrene

Mercury

Pentachlorophenol

Phenanthrene

Phenol

Polychlorinated biphenyls*

Pyrene

Zinc

Wood waste*

H5D1 G-P Outfall Mercury

H5C1 Harris Avenue Shipyard PCBs

Phenol

Zinc

Copper

Mercury

Arsenic

Lead

Asterisk (*) indicates grid cell and parameter additions not on the 1998 303(d) list.

Bold font indicates parameters directly subject to the TMDL submittal. For the remaining parameters

(not bold), sufficient data exist for de-listing in the next 303(d) listing cycle.
Page 18 Bellingham Bay ContSediments TMDL

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Technical Analysis

Summary of Existing Conditions

The following summary is based on the Whatcom Waterway Final RI/FS (Anchor

Environmental/Hart Crowser, 2000) and 1999 sampling results (Anchor Environmental, 2000A).

Sediment Quality

Of the more than 50 chemicals analyzed, only three were regularly detected at concentrations

that exceed current state Sediment Quality Standards (SQS) chemical criteria. These chemicals

include mercury, phenol, and 4-methylphenol. In addition, accumulations of wood material

exceeding 50 percent by volume were also identified in the Whatcom Waterway area, and were

often correlated with elevated phenol and 4-methylphenol concentrations.

Surface concentrations of mercury, 4-methylphenol, and wood material in the Whatcom

Waterway area were significantly lower than concentrations detected several feet below the

mudline. These patterns correspond to decreasing surface sediment concentrations over the past

25 years, due to source controls implemented at the G-P facility and in other areas of Bellingham

Bay beginning in the early 1970’s. This process of natural recovery is also a result of the gradual

incorporation of clean sediment deposits primarily from the Nooksack River.

Sediment Toxicity

In 1996 through 1998, sediment samples from over 40 site locations were submitted for

confirmatory biological testing to verify or refute sediment toxicity predicted on the basis of

sediment chemical concentrations. The Sediment Management Standards utilize biological

effects criteria to confirm the presence or absence of adverse effects on biological resources

(WAC 173-204-320(3)). Sixty percent of these samples, collected from 24 locations were

determined to be non-toxic, meaning they did not exceed the SQS minor biological effect

criteria. The remaining 40 percent of the locations exceeded SQS minor adverse biological

effects criteria. Sediment toxicity was not correlated with the concentration of mercury or other

chemical parameters.

Most of the surface sediments located within the Whatcom Waterway navigation channel did not

exceed SQS biological effects criteria, even though underlying subsurface sediments within the

channel contained some of the highest concentrations of the contaminants of concern at the site.

These data confirm the protectiveness of the natural sediment cap that has formed in the channel

as the result of source controls and natural recovery. Sediments exceeding the SQS biological

effects criteria were restricted to a small portion of the Whatcom Waterway Area. The areal

extent of biological effects was significantly smaller than that represented by sediment

chemistry.

Bioaccumulation

In addition to ecological risks, bioaccumulation of mercury in certain fish and shellfish

populations within Inner Bellingham Bay (e.g., Dungeness crab caught within the Whatcom

Waterway) may also have potential human health implications. Tissue mercury concentrations

within the Whatcom Waterway area are currently elevated as much as three times above regional
Page 20 Bellingham Bay ContSediments TMDL

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background levels. However, even the maximum tissue concentrations reported in this area are

below conservative benchmark concentrations calculated to protect tribal fishers and sensitive

wildlife that may consume relatively large amounts of seafood (Anchor Environmental/Hart

Crowser, 2000).

In order to address the potential for localized exposures, a sediment screening level was

developed for mercury that is conservatively protective of potential bioaccumulation risks to

human health and to high trophic level wildlife receptors. The screening level utilized the

observed relationship between tissue concentrations and surface sediment concentrations within

the sampled species’ home range. Using screening-level risk assessment methods approved by

Ecology, a conservative tissue benchmark mercury level was calculated to protect tribal fishers

and wildlife that may consume relatively large amounts of seafood from Bellingham Bay. The

sediment screening level determined using these methods was 1.2 milligrams per kilogram

(mg/kg; dry weight basis) mercury (Anchor Environmental/Hart Crowser, 2000). For the

Whatcom Waterway Area, sediments exceeding this health-based screening level generally

corresponded to those areas of the site also targeted for cleanup to address sediment toxicity

concerns.

Contaminated Sediment Evaluation

The contaminated sediment evaluation shall be presented using the project components

consistent with the Bellingham Bay Demonstration Pilot Project. The known contaminated

sediment sites and potential contaminant sources are given in Figure 4. The contaminated

sediment components addressed in this TMDL are those listed on the state’s 1998 303(d) list

including I&J Waterway, Whatcom Waterway, G-P outfall, and Harris Avenue Shipyard. Grid

cells and parameters associated with Cornwall Avenue Landfill is also addressed, although it is

not included in the 1998 303(d) list.

For the following discussion, Figure 5 shows the sampling location plan, which can be correlated

to the sampling sites described in the text and in analytical data tables. It is important to note

that the cleanup site areas are the footprints addressed by the remediation process. They do not

correspond directly to the 303(d) grid system, which is an arbitrary locator method used to

identify areas in marine waters. Consequently, some sites correspond with more than one 303(d)

grid cell and, likewise, some grid cells identify more than one contaminated site (refer to Figure

3).

Grid Cell Number H4F9- I&J Waterway

Surface sediment sampling in I&J Waterway has demonstrated consistent compliance with WAC

173-204-320 for all listed parameters on the 303(d) list. Occasionally, levels of mercury have

exceeded the state SQS numerical criteria, however, all confirmatory biological testing data

demonstrate compliance with the state SQS minor biological effects criteria. Appendix A-4

shows the I&J Waterway analytical and biological data. Sample locations for I&J Waterway and

throughout the Bellingham Bay project are given in Figure 5. The Sediment Management

Standards under WAC 173-204-310(2), confirmatory designation, states “Sediment samples that

pass all the required confirmatory biological tests are designated as passing the applicable

sediment quality standards of WAC 173-204-320”.

Grid Cells numbers H4F9, H4E8, H4E9, H4D9, H5D0, H5E0- Whatcom Waterway

Whatcom Waterway has been characterized through chemical and biological assay

determinations, and through bioaccumulation analysis. Figure 6 describes the sediment mercury
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chemical concentrations in the Whatcom Waterway area. Figure 7 presents the sediment

bioassay results, while Figure 8 provides the results of the bioaccumulation screening level

analysis. The contaminant footprint for mercury encompasses the areas violating SQS criteria

for phenol and 4-methylphenol. The union of the areas encompassing the SQS biological effects

criteria failures and the areas with concentrations greater than the bioaccumulation screening

level constitute the total area slated for active sediment remediation.

The major sediment cleanup areas of the Whatcom Waterway site include:

h Whatcom Waterway Federal Navigation Channel

h G-P Log Pond

h G-P Aerated Stabilization Basin (ASB)

h Port Log Rafting Area

h Former Starr Rock Disposal Area

Grid Cell Number H5D1- Georgia-Pacific Outfall

The G-P Outfall area was identified as a 303(d)-listed contaminated sediment site in Bellingham

Bay due to levels of mercury above the cleanup screening level. A detailed contaminant

transport analysis was carried out to evaluate the sediment recontamination potential for mercury

for the current discharge levels of the G-P Outfall. The steps involved in this evaluation

included: 1) TSS-normalize effluent monitoring data; 2) evaluation of initial outfall mixing in a

near-field model; and 3) utilization of the WASP model with current data for far-field analysis.

More details on the modeling effort are available in Whatcom Waterway Final RI/FS (Anchor

Environmental/Hart Crowser, 2000). The modeling process predicts the current G-P Outfall

discharge will not cause mercury sediment contamination to SQS levels in Bellingham Bay.

Furthermore, the dynamic model showed that existing sediments within the immediate outfall

area were predicted to recover to below the mercury SQS chemical criteria prior to 1999. Recent

(1999) sampling data confirmed model predictions and demonstrated that the sediments within

the vicinity of the G-P outfall comply with SQS cleanup criteria for mercury (Anchor

Environmental, 2000A, Appendix A-5). In addition, the G-P chlor-alkali plant (the mercury

discharge source) has been closed and pulping operations have terminated, which will improve

the discharge quality from the outfall.

Sampling conducted in 1999 showed for the first time concentrations of 4-methylphenol above

SQS chemical criteria at 8 stations in the vicinity of the G-P outfall. Biological confirmatory

tests were run on the samples from the three highest-concentration stations in the station cluster.

All biological tests passed SQS biological screening criteria. Therefore, the confirmatory

biological testing procedures under SMS do not qualify this station cluster as a contaminated

sediment site and demonstrates compliance with the Sediment Management Standards SQS

criteria through the principal of biological override (Appendix A-4) (Anchor Environmental,

2000A). This has not been identified as a trend of contamination from G-P and is likely

associated with historic deposits of wood debris in the vicinity of the outfall. The assumption

regarding the association between wood waste and 4-methylphenol distribution will be

confirmed by further monitoring of the G-P discharge and receiving water sediments under their

current NPDES permit. In addition, since G-P has closed their chlor-alkali facility and ceased

the pulping operations at the plant, the contaminant discharge rate associated with current

discharge to the cluster area is not likely to result in a cleanup site in the future.
Page 22 Bellingham Bay ContSediments TMDL

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Grid Cell Number H5C1- Harris Avenue Shipyard

An expanded site investigation has been completed at the Harris Avenue Shipyard. This

information will be used to complete a RI/FS for the site, which will define the cleanup

boundaries and derive protective standards for cleanup. Since PCBs are the primary

contaminants of concern, human health criteria must be considered for the final cleanup goals.

Grid Cell Number H4D9- Cornwall Avenue Landfill

The Cornwall Avenue Landfill was used for the disposal of municipal solid waste between 1953

and 1965. In 1996, the Port of Bellingham, City of Bellingham, and Washington State

Department of Natural Resources performed an expanded site investigation and determined the

landfill is actively eroding into Bellingham Bay. The investigation revealed that the nearshore

sediments are composed mostly of solid waste debris and contain elevated levels of metals and

organics. A focussed RI/FS for Cornwall Avenue Landfill has been completed for the site.

Sediment Recontamination Modeling Analysis

The Bellingham Bay contaminated sediment TMDL draws from two modeling efforts to assess

ongoing source inputs and sediment recontamination potential.

As mentioned previously, modeling was conducted as part of the Whatcom Waterway remedial

investigation for the G-P outfall site. The objective of this analysis was to determine if ongoing

contaminant discharges from G-P were being delivered to Bellingham Bay in quantities

significant enough to cause violation of state Sediment Quality Standards. The recontamination

evaluation utilized the EPA code WASP5 (a 3-dimensional far-field contaminant transport

model) and a near-field dilution zone mixing model. The models were used to perform mass

balance and mass transfer calculations for contaminants in the water column and sediments. The

models incorporate mixing and chemical partitioning phenomena and include local currents, tidal

dispersion, sedimentation and resuspension. A detailed discussion can be found in Chapter 8 of

Anchor Environmental/Hart Crowser, 2000.

This modeling work provides the primary tool used in this TMDL to define the Waste Load

Allocation for the Georgia Pacific facility.

The second modeling effort was designed as a screening and evaluation tool for other potential

ongoing sources in Bellingham Bay in order to identify, plan, and prioritize source control

activities. In this analysis, sediment concentrations resulting from identified Bellingham Bay

sources were estimated using a model that incorporated receiving water dispersion and

sedimentation processes (Anchor Environmental 1999). The model conservatively evaluated

sediment recontamination potential using measured flows and maximum concentrations from

each source and the gross sedimentation rate measured in Inner Bellingham Bay. Local

background concentrations of chemicals in incoming sediments were also used as inputs. The

results of this recontamination modeling indicates that for all sources for which input data are

available, SQS chemical criteria are not likely to be exceeded beyond short distances from the

shoreline discharge location (tens of feet). A summary of this analysis is provided in Appendix

A-6.

This analysis predicts that sediment quality impairment or recontamination from existing sources

is relatively localized near a potential source and should not hinder the large-scale sediment

remediation plans. In fact, the total area of the Whatcom Waterway site that may be affected by

ongoing discharges is less than 1 acre, or 0.5%, of the 140 acre area exceeding the SQS criteria.
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Although the areal extent of potential recontamination is small, source control concerns are

carried forward in the cleanup process and through other source control venues. This is

discussed in more detail in the Summary Implementation Strategy under “Source Control

Activities”.

Discharge Sources

In addition to the sediment quality investigations in Bellingham Bay, the Pilot Project has

compiled and evaluated a considerable amount of information on water quality and potential

pollution sources (Pacific International, et al, 1999 and Anchor Environmental, 1999). Through

these efforts, available information on point source, surface water, groundwater, and other nonpoint sources of sediment contamination and potential near-field water quality concerns were

compiled and evaluated. This evaluation found no specific ongoing discharge sources for

mercury, phenol, 4-mehtylphenol, wood debris, or other sediment contaminants.

Table 5 below provides a tabular summary discussion on the facilities that have a direct release

to Inner Bellingham Bay. The details of the discharge sources by each grid cell location is

presented in Appendix A-7. The detailed discussion of potential sources in Bellingham Bay was

collected from facility and project managers at the Department of Ecology and from the

“Bellingham Bay Demonstration Pilot Sediment Site and Source Control Documentation Report”

(Anchor Environmental, 1999). Source locations are depicted in Figure 2.
Page 24 Bellingham Bay ContSediments TMDL

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Table 5- Discharge Sources in Inner Bellingham Bay.

Sources in Bellingham Bay Summary Discussion

NPDES Permittees

Bornstein Seafoods All process wastewater is treated and discharged to the

sanitary sewer. Control of stormwater releases from the

Bornstein facility is being performed under Ecology’s

NPDES program.

Bellingham Marine Industries Surface sediment sample collected within the vicinity of

the site do not exceed SQS biological effects criteria.

C Street Stormwater and Combined Sewer

Overflow (CSO)

The C-street CSO is regulated under the NPDES permit

for the Bellingham Post Point Wastewater Treatment Plant

(Ecology, 2000). Department of Ecology records show

that there has not been a CSO discharge event in the past

10 years.

Georgia-Pacific Outfall Sampling data confirmed that the sediments at the G-P

outfall comply with SQS criteria for mercury. G-P

NPDES permit requires compliance and sediment

monitoring.

Harris Avenue Shipyard All process wastewater is collected and treated prior to

discharge to the sanitary sewer. The facility is planing to

collect industrial stormwater run off, provide treatment

and discharge it to the sanitary sewer.

Urban Stormwater Runoff

(includes primary storm drains and all other

flow)

Technical studies do not currently identify city stormwater

sources as an on-going contributor to the sediment

contamination problems in Bellingham Bay. This was

demonstrated in the “Final Data Compilation and

Analysis”, Pacific International Engineering and Anchor

Environmental, 1999; and “Sediment Source Control

Documentation Report”, Anchor Environmental, 1999.

Upland Remediation Sites

Roeder Avenue Landfill Ecology is overseeing upland cleanup and redevelopment

work under the Voluntary Cleanup Program.

G-P Log Pond Ecology is currently overseeing upland cleanup activities,

which include isolation of the log pond from the bay.

Boulevard Park Surface sediment samples collected adjacent to the site do

not exceed SQS biological effects criteria.

Chevron Bulk Fuels Facility Surface sediment samples collected within the vicinity of

the site did not exceed SQS biological effects criteria.

Independent remedial actions have been implemented at

the site.

R.G. Haley Surface sediment samples collected in the vicinity of the

site do not exceed SQS chemical criteria. Emergency

actions have been taken to control seepage from the site

under Ecology oversight.

Cornwall Avenue Landfill Control of seepage and erosion is occurring through

emergency actions. The source control and cleanup work

are being addressed under Ecology’s Voluntary Cleanup

Program.
DRAFT

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Loading Capacity

Identification of the loading capacity is an important step in developing TMDLs. The loading

capacity is the amount of pollutant a water body can receive and still meet water quality

standards. By definition, a TMDL is the sum of the allocations. An allocation is defined as the

portion of a receiving water's loading capacity that is assigned to a particular source. EPA

defines the loading capacity as "the greatest amount of loading that a water can receive without

violating water quality standards."

The loading capacity for this TMDL is the combination of the waste load and load allocations for

the existing dischargers, which will fully meet the requirements of the Sediment Management

Standards for sediment quality. Historic contaminant loadings to sediments in Inner Bellingham

Bay have been responsible for the 303(d) listings. Cleanup activities and source control to

prevent sediment recontamination will be implemented to achieve compliance with the state

Sediment Management Standards with the goal of maintaining sediment quality that satisfies

SQS criteria.

The loading capacity throughout Inner Bellingham Bay is the mass loading (mg/kg) from historic

and ongoing sources that maintains compliance with the state Sediment Management Standards.

The loading capacity will be achieved through sediment remediation activities and setting load

and/or wasteload allocations for sources, where necessary, to achieve SMS compliance.

For many 303(d) listed parameters in Bellingham Bay, natural attenuation and recent source

control activities has resulted in compliance with the loading capacity (meeting SMS). The SQS

criteria for these parameters in sediment is not currently exceeded from historic contamination or

ongoing sources. For this reason, all the parameters in areas meeting the standards should be

removed from the 303(d) list in the next listing cycle. Table 6 provides an inventory of the

303(d) listed parameters recommended for de-listing based on analysis of the recent sediment

data.

For Whatcom Waterway, mercury, phenol, 4-methylphenol, sediment bioassay, and wood debris

remain as parameters requiring action. The sediment cleanup will remediate the historical

contaminant loadings that were responsible for the 303(d) listing. Future recontamination from

these parameters have not been identified as a potential from ongoing sources in Inner

Bellingham Bay. The loading capacity is therefore designed as the mass loading that maintains

compliance with the state Sediment Quality Standards Criteria for mercury, phenol, 4-

methylphenol, sediment bioassay, and wood debris (mercury: 1.2 mg/kg; phenol: 420 μg/kg; 4-

methylphenol: 670μg/kg; wood debris: <50% by volume; sediment bioassay: “no adverse effects

on biological resources”). The mass loading from any source or combination of sources is not to

exceed the SQS criteria.

For upland sources, sediment cleanup is designed to remediate the historical contaminant loading

responsible for the 303(d) listing. On-going impacts to sediments are controlled through source

control activities, namely, upland isolation and remediation. Current sources of sediment

contamination have not been identified in the bay. All activities are designed to provide
Page 26 Bellingham Bay ContSediments TMDL

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assurance against recontamination and to maintain compliance with the state Sediment

Management Standards with the goal of maintaining sediment quality that satisfies SQS criteria.

Appendix A-8 provides more detail on the loading capacity definition for each 303(d) listed grid

cell.

Table 6- 303(d) listed parameters recommended for de-listing based on analysis of recent data used

in the development of the Bellingham Bay TMDL.

WBID Grid cell # Cleanup site name De-listed Parameters Proposed

WA-01-0050 H4E9 Whatcom and I&J Waterways 2,4-Dimethylphenol

2-Methylnaphthalene

Acenapthene

Anthracene

Arsenic

Benz(a)anthracene

Benzo(a)pyrene

Benzo(b,k)fluoranthenes

Bis(2-ethylhexyl)phthalate

Chrysene

Copper

Dibenz(a,h)anthracene

Dibenzofuran

Fluoranthene

Fluorene

Indeno(1,2,3-cd)pyrene

Pentachlorophenol

Phenanthrene

Pyrene

Zinc

H5D1 G-P Outfall Mercury
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Load and Waste Load Allocations

The objective of the Bellingham Bay Contaminated Sediment TMDL is to meet Washington

State’s Sediment Management Standards in Bellingham Bay. The wasteload allocations in

Bellingham Bay can be described in terms of “Load Reduction”, meaning the physical removal

and/or isolation of historic contaminated sediments, and the “Waste Load Allocation” (WLA) or

“Load Allocation” (LA) to each existing point or nonpoint source, respectively. There are no

non-point discharge sources in Bellingham Bay, therefore, no load allocations apply. Historic

sediment contamination is the reason for the sediment quality impairment and subsequent 303(d)

listing in Inner Bellingham Bay. The Load Reduction is achieved through the implementation of

the cleanup strategies that will bring all areas of the Bay in compliance with the Sediment

Management Standards. The Wasteload for each source is the required discharge load that

ensures the standards are met at any outfall or upland source. In other words, Waste Load

Allocations for each potential source is the discharge concentration or loading at which

sediments will not be recontaminated above applicable standards.

Georgia Pacific (Grid Cell Number H5D1)

Waste Load Allocations apply to point sources in Bellingham Bay. One point source that

requires a Waste Load Allocation is the G-P outfall. Sampling results from 1999 demonstrate

that this area no longer exceeds SQS criteria for mercury (Anchor Environmental, 2000A). The

recent data also confirm model predictions of source control and natural recovery. Further

discharge controls have been implemented at G-P, including the closure of the chlor-alkali plant,

which will only improve the discharge quality from the G-P outfall. For the purposes of this

TMDL, a Waste Load Allocation to G-P for mercury should remain consistent with the input

parameters selected in the WASP modeling exercise and the effluent limitation calculated for the

NPDES permit. The WASP analysis showed a mass loading of 0.043 kg/day mercury would be

protective of sediment quality. This mass loading for the model input was derived from the

actual sampling record 1995 to 1997 treating all non-detect values as at the detection limit of 0.2

μg/L (The average mass loading using one-half detection for non-detectable data was 0.033

kg/day). During that same discharge period, the mercury average concentration in the discharge

was 0.24 μg/L.

The current average permit limit of 0.03 lbs/day (0.014 kg/day) (Ecology, 2001) is below the

mass loading from the model results for the chlor-alkali plant effluent. Final closure and

remediation of the chlor-alkali plant is expected to eliminate the discharge of mercury entirely

from the G-P outfall. The effluent limitation is more restrictive than the allowable mercury

release determined in the WASP model. The current permit limit of 0.014 kg/day will be the

WLA for G-P in this TMDL, which provides a margin of safety of about 0.03 kg/day. Due to

process changes at the G-P facility, future permits will reflect reduced industrial activities and

may result in lowering the WLA for mercury to zero.

Other Discharges

The sediment contamination in Bellingham Bay is due to historic releases. All current sources

discharging to Inner Bellingham Bay have gone through a multiphase process of evaluation to

assess compliance with the state’s Sediment Management Standards. No ongoing sources have
Page 28 Bellingham Bay ContSediments TMDL

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been documented as currently contributing to the sediment quality impairments in Inner

Bellingham Bay. Therefore, wasteload Allocations are not necessarily required for the

remaining discharging sources. Where the discharge from any facility is not currently, nor

expected to, result in sediment contamination to the SQS criteria, a WLA is not calculated.

If a WLA were provided up to the SQS level, Ecology would in effect be allowing a greater mass

loading of sediment contaminants than is currently released from these facilities. Where upland

sources are or should be controlled or eliminated, WLAs are not established.

The following describes the applicable WLAs for each 303(d)-listed grid cell in Bellingham Bay:

Grid Cell Number H4F9- I&J Waterway

• Bornstein Seafoods- no WLA is given.

• Roeder Avenue Landfill- WLAs are not established for the 303(d) listed parameters. The

previous impact to sediments from this source have been effectively controlled to result in no

discharge of contaminants to criteria levels.

Grid Cells numbers H4F9, H4E8, H4E9, H4D9, H5D0, H5E0- Whatcom Waterway

• Bellingham Marine Industries- no WLA is given.

• G-P Log Pond- a WLA is not established for mercury since the discharge source is

effectively eliminated.

• “C” Street Stormwater and Combined Sewer Overflow (CSO)- 4-methylphenol in nearshore

sediments within the outfall area may be more closely tied to historical deposits of woody

debris and not to CSO discharges. Nonetheless, the WLA for this source is the discharge

level that does not exceed a level of 670μg/kg for 4-methylphenol and 420 μg/kg for phenol

in receiving water sediments.

• Boulevard Park- WLAs are not established for the 303(d) listed parameters.

• Chevron Bulk Fuels Facility- WLAs are not established for the 303(d) listed parameters.

• R.G. Haley- WLAs are not established for the 303(d) listed parameters.

Grid Cell Number H4D9- Cornwall Avenue Landfill

WLAs are not established for the 303(d) listed parameters (mercury, phenol, 4-methylphenol,

PCBs, and wood waste). The impact to sediments from this source is effectively controlled to

result in no discharge of contaminants adversely affecting sediments.

Grid Cell Number H5C1- Harris Avenue Shipyard

Discharge sources from the shipyard are currently effectively controlled through NPDES Permit

No. WA-003134-8 (Ecology, 1994. Harris Avenue Shipyard was formerly known as “Maritime

Contractors, Inc.”). The current stormwater discharges from this facility have not been

documented to result in levels that cause exceedances of SQS levels for the 303(d) listed

parameters. Under the next NPDES permit, Ecology plans to require the collection and

treatment of all industrial stormwater prior to discharge to the sanitary sewer system. The

shipyard’s NPDES permit is and will continue to require meeting local limitations established for

the protection of the Bellingham Post Point Treatment Plant for the discharge to the sanitary

sewer. Limitations for the sanitary sewer discharge are currently established for copper, lead,

zinc, and arsenic. After the facility completes the project to tie all industrial stormwater sources

to the sanitary sewer system, the WLAs for the discharge to surface water for these metals will

be zero.
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Bay-wide Sources

City of Bellingham Stormwater- no WLAs are calculated. The stormwater program and

monitoring of city stormwater and in-water sediments is discussed in the “Summary

Implementation Strategy” below.

The goal of this TMDL is to maintain compliance with the chemical and biological criteria for

sediment quality in the SMS rule. This goal will be enforceable through: 1) the individual and

general NPDES permits in the Bay; 2) the implementation of the BMPs identified in the

stormwater programs of the City and Port of Bellingham; and 3) the sediment and upland

remediation activities under MTCA.

Narrative effluent limitations may be used in NPDES permits, such as specific BMPs, to define

compliance with the State Sediment Management Standards as a permit condition. The use of

narrative effluent limitations for stormwater is consistent with written EPA policy (EPA, 1996).

Furthermore, the Sediment Quality Standards provide a monitoring trigger, or action level, for

surface sediments in the Bay. If monitoring demonstrates that the Bay does not comply with the

standards in the future, additional source investigation and control and/or remediation activities

will be required.

Compliance with the sediment standards will be assured through the development and state

oversight of local stormwater pollution prevention programs, NPDES permits, remediation

activities, and sediment monitoring in Bellingham Bay. This is discussed in more detail in the

Summary Implementation Strategy section.

Monitoring Plan Developed Under this Approach

Monitoring provides a measure as to whether the control activities achieve the expected load

reductions to maintain compliance with the Sediment Management Standards. Compliance

monitoring is a required component of remedial actions under the MTCA rule. Discharge

monitoring is also a requirement in individual NPDES permits. The monitoring approach in this

TMDL will be consistent with the monitoring plans for all the individual cleanup and source

control strategies in Bellingham Bay.

Sediment monitoring in Bellingham Bay is designed to: 1) measure contaminants in the surface

sediments where they exists; 2) evaluate the effectiveness of control actions (e.g. sediment and

upland remediation, stormwater BMPs, etc.); and 3) determine the need for additional pollutant

controls through a process of adaptive management. More details on the monitoring approach

are given below under “Summary Implementation Strategy”.
Page 30 Bellingham Bay ContSediments TMDL

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Bellingham Bay Contaminated Sediments TMDL Page 31

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Margin of Safety

The statute requires that a margin of safety be identified to account for uncertainty when

establishing a TMDL. The margin of safety can be explicit in the form of an allocation, or

implicit in the use of conservative assumptions in the analysis. Several conservative assumptions

and critical conditions used in the analysis and modeling of the Bellingham Bay Contaminated

Sediments TMDL provide an inherent margin of safety as required by the statute.

In most cases for this TMDL, the margin of safety is not strictly calculated or allocated. Rather,

the margin of safety is implicit due to the conservative assumptions that have been used

throughout the analyses.

Conservative assumptions that have been used include:

• Delineating cleanup footprints beyond the cleanup boundaries defined strictly by the data;

• Using upper-bound (worst case) flows and concentrations in recontamination modeling

analyses for potential sources;

• Using high seafood consumption rates and assuming all mercury is in a bio-available form

for the bioaccumulation assessment in the Whatcom Waterway RI/FS Study (Anchor

Environmental/Hart Crowser, 2000);

• Conservative assumptions in the G-P outfall WASP model including:

- Input values for mercury assumed all non-detectable data to be at the full detection value;

- High-end literature and empirical values were taken for the mercury partitioning

coefficient;

- Conservative dispersion coefficients were used to predict a more concentrated plume at

the outfall; and

- Ambient mercury concentrations were assumed to be the highest value sampled in

background locations.

The margin of safety for the G-P outfall wasteload allocation is explicitly calculated based on

the difference between the permitted discharge and the allowable discharge calculated from

mathematical modeling and sampling. The actual mass loading for mercury from the G-P

Outfall and established in the NPDES permit is expected to be about a third of the mass loading

allowed from the WASP modeling effort. The calculated margin of safety is 0.03 kg/day.
Page 32 Bellingham Bay ContSediments TMDL

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Summary Implementation Strategy

Overview

The Bellingham Bay Demonstration Pilot Work Group was established to address the need for

sediment cleanup and to expedite remedial actions. The Pilot Work Group brought together a

cooperative partnership of agencies, tribes, local government, and businesses to develop an

approach to source control, sediment cleanup and associated habitat restoration in Bellingham

Bay. The Pilot Work Group developed a Comprehensive Strategy that considered contaminated

sediments, sources of pollution, habitat restoration, and land-use from a baywide perspective.

The Bellingham Bay Comprehensive Strategy developed by the Pilot Work Group includes the

cleanup actions and source controls measures that comprise the TMDL implementation strategy.

An Environmental Impact Statement (EIS) was prepared to describe the approach and evaluate

the potential environmental impacts of implementing the strategy (Anchor 2000B). The final

EIS for the Comprehensive Strategy was issued in October 2000.

Implementation Plan Development

The Bellingham Bay Demonstration Pilot Project is an initiative of the Cooperative Sediment

Management Program designed to meet the challenge of coordinating navigation needs with

contaminated sediment and habitat management issues in Bellingham Bay. The participants

involved in the Pilot Project include:

• U.S. Army Corps of Engineers

• U.S. Fish and Wildlife

• U.S. Environmental Protection Agency

• National Marine Fisheries Service

• Washington State Department of Ecology

• Washington State Department of Natural

Resources

• Washington State Department of

Transportation

• Washington State Department of Fish and

Wildlife

• Puget Sound Water Quality Action Team

• City of Bellingham

• Port of Bellingham

• Whatcom County Health Department

• Lummi Nation

• Nooksack Tribe

• Georgia-Pacific West, Inc.

The Department of Ecology provided grant dollars for local government to help fund the Pilot

Project. The Port of Bellingham and Ecology carry out the day-to-day management of the

project. In the Comprehensive Strategy, the Pilot Work Group identifies a range of near-term

remedial action alternatives that address high priority sediment cleanup/source control sites

(Anchor 1999B). The high-priority sites identified in the Comprehensive Strategy include all the

303(d) listed areas of Inner Bellingham Bay. The cleanup and source control activities

associated with a particular priority site are conducted by the individual parties responsible for

the contamination. The Department of Ecology oversees, regulates and enforces the cleanup

processes through the authority under the Model Toxics Control Act (Chapter 173-340 WAC).

The approaches used to meet the load allocations include the sediment cleanup projects,

associated source control activities, and NPDES permits, where appropriate. The success of the
Page 34 Bellingham Bay ContSediments TMDL

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TMDL implementation will be assessed through meeting milestone dates for cleanup as well as

through monitoring plans.

Implementation Activities

Implementation activities planned as part of the remediation and source control process in

Bellingham Bay will attain compliance with Sediment Management Standards. Based on

monitoring and evaluation, adaptive management principles will be used to track and target

future activities in the Bay to assure compliance with Sediment Management Standards.

Implementation activities for each 303(d) listed grid cell in Inner Bellingham Bay are provided

below.

Grid Cells numbers H4F9, H4E8, H4E9, H4D9, H5D0, H5E0- Whatcom Waterway

Sediment Remediation

Georgia- Pacific, with oversight from Ecology, has conducted an RI/FS in accordance with a

MTCA Agreed Order. The Whatcom Waterway Final RI/FS (Anchor Environmental/Hart

Crowser, 2000) includes technical information and evaluates a range of potential remedial

actions for the Whatcom Waterway site. In addition, the waterway is a high priority site as

defined in the Bellingham Bay Comprehensive Strategy. The Comprehensive Strategy Final

EIS (Anchor Environmental, 2000) identifies and evaluates a range of potential near-term

remedial action alternatives that address several high priority sites including the Whatcom

Waterway site.

Both the RI/FS and the final EIS will inform Ecology’s preparation of a draft Cleanup Action

Plan (CAP) that is issued for public review. The CAP will be implemented through a MTCA

Consent Decree with Ecology and a draft is scheduled to be available in 2001.

The proposed cleanup strategies include treatment, removal, and in-water containment of

contaminated sediment to meet the SQS criteria throughout the Whatcom Waterway site. In

areas where containment through capping is proposed as the remedial action, clean capping

material would meet or exceed standards for quality established by the Puget Sound Dredged

Disposal Analysis (PSDDA) program. The PSDDA process created the Dredged Material

Management Program (DMMP) to manage dredged material activities. This includes the

development of evaluation procedures to characterize the suitability of sediments for disposal

and capping. The DMMP provides screening level (SL), bioaccumulation trigger (BT) and

maximum level (ML) guideline chemistry values for 62 chemicals or classes of chemicals in

marine sediments (Appendix A-9). The screening levels are at least as stringent as the SQS

criteria in the state’s Sediment Management Standards, and represent concentrations below

which adverse biological effects are considered to be unlikely.

Ecology expects that the actual cleanup of the Whatcom Waterway site will begin in 2002

and continue until 2004-2005.

Upland Remediation

- G-P Log Pond

G-P and Ecology are currently evaluating additional source control and cleanup actions to

ensure that sediments within the Log Pond remain below SQS chemical criteria following the
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cleanup action under MTCA.

- R.G. Haley

Soil and groundwater at this upland contaminated site contain concentrations of

pentachlorophenol and PAHs that exceed water quality and sediment protection criteria,

respectively. Groundwater seeps from the site to the Bay were recently discovered.

Emergency actions to control seepage from the site were in place by fall 2000. Following

emergency activities, an RI/FS will be conducted under Ecology’s VCP.

NPDES Permits

- “C” Street stormwater and CSO

The C Street CSO is regulated under the Bellingham Post Point NPDES Permit (No. WA002374-4). The CSO is designed to meet, and has met, the state standard of not more than

one discharge event per year. Department of Ecology records show that there has not been a

single CSO event in at least the past 10 years. The C Street stormwater discharge will be

identified as an outfall of concern in the development of the City of Bellingham

Comprehensive Stormwater Program and under the NPDES general stormwater program.

The Puget Sound Water Quality Plan contains minimum elements that the city of Bellingham

will include in its Comprehensive Stormwater Program by June 30, 2000. Bellingham is also

a “Phase II” city in the federal stormwater NPDES permitting program, which will require

stormwater programs meeting the federal requirements to be in place by March 2003.

Through the Department of Ecology’s stormwater program review and approval process,

source control activities and potential sediment cap sampling in the vicinity of the “C” Street

outfall will become components of the city’s stormwater program.

Grid Cell Number H4F9- I&J Waterway

NPDES Permits

- Bornstein Seafoods

Bornstein Seafoods carries a State Waste Discharge Permit (ST7304) for the discharge of

screened seafood processing wastewater to the Bellingham Post Point WWTP. They have a

Baseline General Permit for Industrial Stormwater (SO3-000679). The Washington State

Department of Ecology administers both permits. Although, Bornstein Seafoods is not

identified as an ongoing source of contaminated sediments, water quality investigations will

be conducted as part of Ecology’s permit management activities and the TMDL

implementation.

Upland Remediation

- Roeder Avenue Landfill

The Port of Bellingham is currently conducting an RI/FS at the site under Ecology’s VCP.

Cleanup activities will occur under a MTCA order or decree in 2001/2002.

Grid Cell Number H5D1- Georgia-Pacific Outfall

NPDES Permit

- Georgia Pacific

NPDES Permit No. WA-000109-1 includes effluent limitations for mercury, a mercury
Page 36 Bellingham Bay ContSediments TMDL

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source evaluation sampling plan, as well as sediment monitoring requirements in Bellingham

Bay. The current NPDES permit (Ecology, 2001) contains effluent mass limitations that

satisfies the WLA in this TMDL (see the discussion in the “Load and Waste Load

Allocations” section above). The permit is the mechanism for enforcement of the WLA for

this TMDL.

The NPDES permit also requires further sediment evaluation beginning with sediment

monitoring within one year of the Department of Ecology’s approval of the sampling plan.

G-P conducted baseline sediment sampling in 1999. Another round of sediment sampling

will be performed within approximately 5 years to characterize sediment in the vicinity of the

G-P outfall after sediments have responded to the closure of the chlor-alkali facility. The

NPDES permit will also require G-P to evaluate potential 4-methylphenol sources in the

outfall area surface sediments.

Grid Cell Number H5C1- Harris Avenue Shipyard

Sediment Remediation

The Port of Bellingham is currently conducting an RI/FS of the sediment component of the site

under the Department of Ecology’s Voluntary Cleanup Program (VCP) to address all the

parameters on the 303(d) list (PCBs, Phenol, and metals). In addition, the Harris Avenue

Shipyard is a high priority site as defined in the Bellingham Bay Comprehensive Strategy EIS.

The RI/FS, and the EIS will inform Ecology’s development of a draft Cleanup Action Plan

(CAP) for public review. Implementation of the CAP will be under a MTCA consent decree

with Ecology.

The RI/FS was complete in 2001. The consent decree and Cleanup Action Plan are expected to

be complete in 2001 with the final cleanup complete in 2004. The cleanup action will bring

sediments in compliance with sediment quality criteria in the state’s Sediment Management

Standards.

NPDES Permit

The NPDES permit (No. WA-003134-8) for the shipyard operations is designed to control

shipyard activities to prevent sediment recontamination. The sediment contamination in the Bay

is due to historic releases, and the current discharge from the shipyard does not pose a threat to

sediment recontamination. The shipyard is inspected regularly by Ecology. Best Management

Practices are in place to eliminate releases to the Bay during dry dock operations. Under the next

NPDES permit all stormwater runoff from the site will collected and treated prior to discharge to

the sanitary sewer. The NPDES permit also requires extensive sampling, chemical and

biological testing, and sediment monitoring in Bellingham Bay. The next NPDES permit is

scheduled to be issued for Harrison Avenue Shipyard in the winter of 2002. Conditions and

monitoring requirements for stormwater and sediment in the NPDES permit will be reviewed in

the context of this TMDL upon renewal.

Grid Cell Number H4D9- Cornwall Avenue Landfill

Sediment Remediation

The Port of Bellingham in conjunction with the City of Bellingham and Washington State DNR

has completed a Remedial Investigation and Feasibility Study (Landau, 2000) of this site under

Ecology’s Voluntary Cleanup Program. In addition, the Cornwall Avenue Landfill site is

identified as a high-priority in the Bellingham Bay Comprehensive Strategy EIS. The RI/FS and
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the EIS will inform Ecology’s development of a draft Cleanup Action Plan for public review.

The CAP will be implemented under a consent decree with Ecology.

The consent decree and Cleanup Action Plan are expected to be complete in 2001 with the final

cleanup complete in 2004-2005. The cleanup action will bring sediments in compliance with

sediment quality criteria in the state’s Sediment Management Standards.

Bay-wide Activities

As part of developing the Bellingham Bay Comprehensive Strategy, all potential sources

discharging to Bellingham Bay have gone through a multiphase process of evaluation for

sediment recontamination potential. In this process, the evaluation tools included:

• Sediment quality screening and characterization in the receiving environment to

determine the presence of SQS excursions at all sources;

• Contaminant transport analysis using the maximum predicted loading at each source

to determine the potential for sediment recontamination after the cleanup process is

complete;

• Source control evaluation based on the recontamination potential for each source.

The source control evaluation utilized a tiered approach by placing each potential source in one

of three categories. The categories are in order of potential detrimental impact, and each

category is assigned an appropriate monitoring scheme:

1. No potential to recontaminate sediments - the area will be monitored through existing

programs;

2. Potential to recontaminate sediments, but the source can be adequately controlled to remove

that potential to recontaminate – these sources will be controlled through the remedial design

and a sediment monitoring program will be put in place;

3. Potential to recontaminate a small area after full implementation of source control- this will

not hinder the cleanup strategy for the Bay. These will be controlled to AKART standards

and will be monitored to confirm if there is an impact to sediments. Further source controls

may be applied, and a Sediment Impact Zone (WAC 173-204-415) of limited area will be

requested only as a last resort. A long term monitoring program consistent with SIZ

requirements will be put in place.

The source control categories will be implemented on a case-by-case basis for all ground and

surface water sources in the Bay through upland remedial actions, individual or general permits,

or local stormwater management programs. The summary list of sources in Bellingham Bay,

their water quality concerns, and planned control mechanisms are listed in Appendix A-7.

City of Bellingham NPDES Stormwater General Permit and Comprehensive Stormwater

Program

The technical studies developed as part of the remedial activities in Bellingham Bay did not

identify city stormwater sources as an on-going contributor to the sediment contamination

problems in Bellingham Bay. Nonetheless, the city is participating in the Bellingham Bay

Source Control Action Team that will track on-going source control programs and activities in

Bellingham Bay to ensure there are not gaps that could result in sediment contamination or

recontamination.
Page 38 Bellingham Bay ContSediments TMDL

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The City of Bellingham originally developed a local stormwater program and submitted it to the

Department of Ecology in 1999. It included an extensive source cleanup program, which

incorporated vactor waste activities, and a comprehensive plan. After review of the program,

Ecology recommended that the city concentrate on improvements in following two areas: 1)

coordinate the stormwater program with the planned sediment cleanup in Bellingham Bay; and

2) improve the stormwater plan requirements for redevelopment. Many of the City of

Bellingham’s storm drains discharge to Bellingham Bay. City has been implementing their

comprehensive stormwater program with existing resources and is pursuing local funding

sources to implement a more extensive program in 2001.

The Puget Sound Water Quality Management Plan (PSWQMP) also requires all cities and

counties to adopt and implement a basic stormwater program. The content of Bellingham’s

Comprehensive Program is consistent with PSWQMP and includes:

1. Adoption of local Stormwater Ordinances which-

• Control off site water quality and quantity effects

• Require the use of BMPs for source control and treatment

• Protect Beneficial Receiving water uses

• Control erosion and sedimentation from new construction and redevelopment projects

• Provides for local enforcement of these stormwater controls

2. Development and enforcement of operation and maintenance programs

3. Adoption of the Stormwater Technical Manual

4. Public education programs for citizens, businesses, and industries

5. Adoption of comprehensive land use plans

6. Identification and ranking of significant pollutant sources

7. Investigation and correction of illicit discharges into stormwater systems

8. Programs for the proper O&M of stormwater conveyance and treatment systems

9. A water quality response program to investigate complaints

10. Source of adequate local funding for the SW program

11. Local watershed coordination agreements

12. Ordinances requiring implementation of stormwater controls for new development and

re-development

13. Inspection, compliance and enforcement program

14. Implementation schedule

The stormwater program requirements for the City of Bellingham under the PSWQMP

Comprehensive program are substantively the same as the requirements under the Phase I

Municipal NPDES stormwater permits. The City of Bellingham will be covered under the Phase

II municipalities stormwater NPDES permit in 2003. However, the requirements under the city’s

current comprehensive program exceed the minimum control measures required under the Phase

II permits.

Under the Phase II NPDES general municipal stormwater permit, the city’s comprehensive

program will contain components consistent with the implementation of this contaminated

sediment TMDL. The Department of Ecology will review Bellingham’s stormwater program

and may require stormwater/sediment monitoring and source control activities aligned with

MTCA monitoring and source control requirements for the various cleanup sites in Inner

Bellingham Bay.
DRAFT

Bellingham Bay Contaminated Sediments TMDL Page 39

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Specifically, to minimize the potential for sediment recontamination in the Bay, Ecology

recommends the following TMDL implementation strategy activities be incorporated in future

NPDES stormwater permit and programmatic reviews:

1. Identify all city stormwater outfall discharges into the areas subject to sediment

remediation in Bellingham Bay.

2. Develop an enhanced BMP program for the drainage areas associated with the

stormwater outfalls identified above. This may include BMPs such as: increased

frequency of catch basin cleaning; system maintenance; catch basin sediment monitoring;

and other activities that affect the quality of receiving water sediments.

3. Develop a sediment sampling and analysis plan for these or selected representative

outfalls within 12 months after the issuance of the NPDES Phase 2 stormwater permit.

This shall include the outfall identification and recommendations for in-water sediment

and/or catch basin sediment sample locations and frequency, as necessary.

Along with bay-wide source control efforts, the stormwater program conditions for parameters of

concern in the Bay are designed to assure that stormwater does not recontaminate sediment areas

that have been remediated. If stormwater sources are identified as having an impact on local

sediments in the receiving water, the compliance and enforcement components of the program

can be used to target specific source control efforts. Ecology’s oversight of the stormwater

program provides assurance that source control activities will be carried out and be consistent

with this TMDL.

Port of Bellingham Stormwater Program

The Port of Bellingham leads environmental protection efforts at its properties around

Bellingham Bay. As part of this role, the Port recently created a Stormwater Master Plan for

Squalicum Harbor (David Evans, 2000). The Plan conforms to the City of Bellingham’s

stormwater requirements as well as the Department of Ecology’s Puget Sound Stormwater

Technical Manual for all development and redevelopment activities in the Harbor. The

Stormwater Master Plan includes a series of pollution prevention operational and structural

BMPs and treatment alternatives to reduce or eliminate adverse impacts from Port activities on

stormwater and receiving waters. The planned efforts for Squalicum Harbor and Marina is

intended to provide a model for Port source control activities throughout Bellingham Bay.

The Port also carries three baseline general stormwater NPDES permits for facilities that drain to

or otherwise potentially impact Bellingham Bay. One general permit is for the Bellingham

Airport. The Port also has coverage for the maintenance shop near the shipping terminal on

Whatcom Waterway and for the Alaska ferry terminal in Fairhaven. Data for these facilities

covered under the general permit does not show they are a source of sediment contamination.

The Port has developed stormwater pollution prevention plans and programs in conformance

with Bellingham’s and Ecology’s stormwater requirements.

Other stormwater sources

There are no current discharge sources in Inner Bellingham Bay identified as likely to cause

sediment contamination. Nonetheless, the tiered analysis (described in “Source Control

Activities” above) was applied to all sources. If in the future a stormwater source is identified as

a concern, the response will be implemented through agreements or requirements made under
Page 40 Bellingham Bay ContSediments TMDL

 11/06/01

MTCA and/or the City of Bellingham NPDES stormwater general permit and Comprehensive

Stormwater Program.

Meeting Standards

In summary, the planned activities outlined in Inner Bellingham Bay Contaminated Sediment

TMDL Submittal are designed to bring all the 303(d)-listed sediments into compliance with state

sediment standards in the years 2004-2005. Meeting state sediment standards satisfies state

Water Quality Standards under Chapter 173-201A, and in turn meets the requirements of section

303(d) of the Federal Clean Water Act.

Public Involvement

Public Activities regarding the Bellingham Bay Demonstration Pilot Project to date include:

• November 1997 – a public information fair was held to introduce the Bellingham Bay

Demonstration Pilot Project.

• June/July 1998 – a 30-day public comment period regarding the SEPA scoping for the

project and a public meeting were held.

• July/September 1999 – a 60-day public comment period for the Bellingham Bay

Comprehensive Strategy Draft Environmental Impact Statement and a public meeting

were held.

• June 2000 – public information meeting was held to update the public on the project

• All Pilot Workgroup meetings have been open to the public. Beginning September 2000,

Ecology increased public outreach efforts to increase public participation in the

Workgroup meetings

Ecology also conducted various community outreach activities throughout the life of the project.

Examples include briefings to the city council, neighborhood associations, the Port commission,

the chamber of commerce, and local environmental groups.

The Whatcom Waterway site and the Cornwall Avenue Landfill cleanup sites have also had

public involvement opportunities:

• July/September 1999 – a 60-day public comment period on the Whatcom Waterway

RI/FS

• August/September 1999 - a 30-day public comment period on the Cornwall Avenue

Landfill RI/FS

Future public involvement activities will be conducted as part of implementing the Bellingham

Bay Comprehensive Strategy. In addition, for each individual cleanup site, Ecology will prepare

draft orders or decrees, and associated draft cleanup action plans for public review. The public

review periods are typically 30 days, and Ecology will likely conduct a public meeting for each

site.

Public review is also a required under the NPDES program. Established review processes will

be followed during the re-issuance of all NPDES permit as well as for municipal and industrial

stormwater permits in Bellingham Bay.
DRAFT

Bellingham Bay Contaminated Sediments TMDL Page 41

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Future public involvement activities will include reference to the contaminated sediment TMDL

for Bellingham Bay. A public meeting specifically addressing this TMDL will be conducted

independently or in conjunction with other Bellingham Bay public outreach efforts.

Monitoring Strategy

Discharge and sediment monitoring will assess compliance with the Sediment Management

Standards. Monitoring is a required element of a cleanup design for contaminated sediments.

For each individual cleanup site, a Cleanup Action Plan (CAP) is developed that contains

provisions for monitoring. The implementation of an Ecology-approved CAP, including

monitoring, is mandated through a consent decree. In the CAP development process, Ecology

determines the sediment monitoring schedule, frequency, parameters, and locations, as well as

source monitoring, and additional site specific monitoring needs. The draft consent decree and

draft CAP are also subject to public review and comment. Post remediation monitoring is

designed to ensure activities are successful in maintaining long-term compliance with the state’s

Sediment Management Standards. Ecology will use monitoring data and SQS criteria to trigger

further source control actions or remediation as necessary.

In addition, the Department of Ecology enforces the monitoring requirements of individual and

general NPDES permits. Permits in Bellingham Bay will be reviewed for consistency with this

TMDL upon re-issuance.

Reasonable Assurance

Reasonable assurance is defined as a demonstration that the WLAs for point sources, or load

reductions for historic sediment releases, derived in the TMDL will be implemented. For point

source, assurances can be demonstrated by enforceable NPDES permits, which include effluent

limits based on WLAs and/or include specific procedures and mechanisms that ensure the

sources will be monitored and controlled. For load reductions, remediation activities are

required to bring contaminated sediments into compliance with standards. The reasonable

assurance standard requires the procedures apply to the pollutants for which the TMDL is

established, be implemented expeditiously, and be supported by adequate funding.

The many activities related to implementation of the Bellingham Bay Comprehensive Strategy

and the issuance of NPDES permits provide the reasonable assurance that the requirements for

this contaminated sediment TMDL will occur.

Cleanup Actions

The contaminated sediment and upland cleanup sites in Bellingham Bay are carried out under the

Department of Ecology’s regulatory authority. While Ecology prefers to remediate contaminated

sites through cooperative means, the enforcement provisions in the Model Toxics Control Act

Cleanup Regulations (Chapter 173-340 WAC) ultimately assure cleanup and monitoring of the

contaminated areas in the Bay. Ecology imposes an enforceable schedule for cleanup actions at

each site. The expected schedule for each sediment remediation cleanup site in the Bay is given

above under “Cleanup sites”.
Page 42 Bellingham Bay ContSediments TMDL

 11/06/01

The cleanup actions are coupled with monitoring to assure the remedial actions have been

adequately implemented and potential sources adequately controlled. Not only is this a legal

requirement, but also there is a strong economic and environmental incentive to monitor and

maintain the sediment quality standards in the long-term after remediation (capping, dredging,

etc.) is complete.

NPDES Permits

Individual and general permits will be reviewed for consistency with this TMDL and linked to

pollutant-specific wasteload allocations or sediment monitoring and BMPs as appropriate.

Ecology also provides reasonable assurance for stormwater impacts through the oversight of the

City’s stormwater management program. Through linkage with the TMDL and long term

monitoring efforts, Ecology can identify potential areas of concern and potential problem

stormwater outfalls. Ecology can then oversee the city’s source control efforts in problem areas.

Adaptive Management

“Adaptive management” is often defined as the reliance on scientific methods to test the results

of actions taken, thereby allowing the management and related policies to be changed promptly

and appropriately. Adaptive management logically requires focus on the elements with the

greatest uncertainty or risks.

Sediment cleanup techniques have been widely used and proven successful at many

contaminated sediment cleanup sites. Potential sources of sediment contamination must be

identified in conjunction with cleanup projects. However, the variability of sources, particularly

stormwater, necessitates targeted follow-up long-term monitoring to measure the future success

of the cleanup and source control activities.

The TMDL process accommodates the ability to track and refine activities, assumptions and

processes in the implementation phase. This TMDL for Inner Bellingham Bay contaminated

sediments allows for future changes in loading capacities and implementation tactics in the event

that monitoring demonstrates the necessity for change in order to attain and maintain compliance

with Sediment Management Standards.

Furthermore, the Department of Ecology performs a cyclical watershed scoping process for the

whole state on a five-year cycle. Every 5 years, Ecology examines all the TMDLs in the

Nooksak basin to assess the effectiveness of management activities and to institute changes as

necessary. This TMDL evaluation process is a comprehensive review and is conducted in

addition to the on-going evaluation that occurs as part of the sediment remediation and source

control processes that proceeds under the Model Toxics Control Act and the NPDES programs.

Funding Sources

At each cleanup site, the liable parties are responsible to fund the remediation activities required

to bring their respective sites into full compliance with the Sediment Management Standards.

Where responsible parties do not fully fund remediation activities the Department of Ecology

maintains the legal authority to carry out remediation activities and subsequently recover the

cleanup costs from liable parties.
DRAFT

Bellingham Bay Contaminated Sediments TMDL Page 43

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NPDES permit holders are required to fund the activities necessary to maintain compliance with

their respective permits and state water quality regulations.
Page 44 Bellingham Bay ContSediments TMDL

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DRAFT

Bellingham Bay Contaminated Sediments TMDL Page 45

11/06/01

References Cited

Anchor Environmental, 1999. Bellingham Bay Demonstration Pilot Project Sediment Site and

Source Control Documentation Report. July 1999.

Anchor Environmental, 2000A. Data Report: Marine Sediment Sampling and Analysis,

Georgia-Pacific West Outfall 009, Bellingham Bay, Washington. April 2000.

Anchor Environmental, 2000B. Bellingham Bay Comprehensive Strategy Final Environmental

Impact Statement. October 1999.

Anchor Environmental/Hart Crowser, 2000. Whatcom Waterway Final RI/FS, July 2000.

Cubbage, 1994. Drainage Basin Tracing Study: Phase II Chemicals Found in Storm Drains,

Whatcom Creek, and Squalicum Harbor in Bellingham Washington. Ecology Publication

No. 94-90. May 1994.

David Evans and Associates, Inc., 2000. Squalicum Harbor, Port of Bellingham Draft

Stormwater Management Master Plan. April 2000.

Ecology, 1994. Maritime Contractors, Incorporated, NPDES Permit No. WA-003134-8 (Revised).

Ecology, 2000. City of Bellingham, NPDES Permit No. WA-002374-4.

Ecology, 2001. Georgia Pacific West, Inc. NPDES Permit No. WA-000109-1.

Kendall, D., T. Michelsen, 1997. Management of Wood Waste under Dredged Material Management

Programs and the Sediment Management Standards (SMS) Cleanup Program. September 1997.

Landau, 2000. Final Report, Focused RI/FS, Cornwall Avenue Landfill, Bellingham, Washington.

Prepared by Landau Associates, Inc. for the Port of Bellingham, the City of Bellingham, and the

Washington State Department of Natural Resources. October 2000.

Pacific International Engineering and Anchor Environmental, 1999. Final Data Compilation and

Analysis, Bellingham Bay Demonstration Project. March 1999.

PTI Environmental Services, 1991. Drainage Basin Source Tracing Study, Phase 1 Technical

Memorandum. February 1994.

U.S. Environmental Protection Agency, 1991. Guidance for Water Quality-based Decisions:

The TMDL Process. EPA 440/4-91-001. Washington, DC.

U.S. Environmental Protection Agency, 1996. Interim Permitting Approach for Water QualityBased Effluent Limitations in Stormwater Permits. August 1996.
Page 46 Bellingham Bay ContSediments TMDL

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Bellingham Bay Contaminated Sediments TMDL Page Figure 1

11/06/01

Figures

Figure 1. Bellingham Bay Vicinity Map

Figure 2. Generic depiction of a 303(d) listed grid cell and sediment contaminated site (see page

11 of text)

Figure 3. Inner Bellingham Bay 303(d) grids, sediment sites, and outfall location

Figure 4. Potential Sediment Sources to Bellingham Bay

Figure 5. Sampling Location Plan

Figure 6. Sediment Mercury Concentrations

Figure 7. Sediment Bioassay Results

Figure 8. Sediments Exceeding Bioaccumulation Screening Level
Page Figure-2 Bellingham Bay ContSediments TMDL

 11/06/01
Bellingham Bay Contaminated Sediments TMDL Page Figure 3

11/06/01

Figure 1: Bellingham Bay Vicinity Map
Page Figure-4 Bellingham Bay ContSediments TMDL

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Bellingham Bay Contaminated Sediments TMDL Page Figure 5

11/06/01

Figure 4
Page Figure-6 Bellingham Bay ContSediments TMDL

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Bellingham Bay Contaminated Sediments TMDL Page Figure-7

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Page Figure-8 Bellingham Bay ContSediments TMDL

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Bellingham Bay Contaminated Sediments TMDL Page Figure-9

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Page Figure-10 Bellingham Bay ContSediments TMDL

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Bellingham Bay Contaminated Sediments TMDL Page A-1

11/06/01

Appendix A- Supplemental Information

A-1: Chapter 173-204 WAC Marine Sediment Quality Standards (SQS), Puget Sound

Cleanup Screening Level (CSL), and Minimum Cleanup Levels (MCUL) -

Chemical Criteria

A-2: Complete 303(d) Contaminated Sediment Listings for Inner Bellingham Bay

A-3: Inner Bellingham Bay 1996-1998 303(d) sediment listings comparison

A-4: I&J Waterway Chemical and Biological Testing Results

A-5: Georgia Pacific Outfall, September 1999 Sediment Sampling Results

A-6: Estimated Maximum Impact/Mixing Zones near Identified Sources of Potential

Sediment Quality Concern in Bellingham Bay.

A-7: Review of Discharge Sources in Bellingham Bay

A-8: Loading Capacity Discussion for Each 303(d) Listed Grid Cell

A-9: 1998 DMMP Screening Level (SL), Bioaccumulation Trigger (BT) and Maximum

Level (ML) Guideline Chemistry Values (Dry Weight Normalized)
Page A-2 Bellingham Bay ContSediments TMDL

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Bellingham Bay Contaminated Sediments TMDL Page A-3

11/06/01

Appendix A-1

Chapter 173-204 WAC Marine Sediment Quality Standards (SQS), Puget Sound Cleanup

Screening Level (CSL), and Minimum Cleanup Levels (MCUL) - Chemical Criteria

CHEMICAL PARAMETER SQS CSL and MCUL

MG/KG DRY WEIGHT

(PARTS PER MILLION(PPM) DRY)

MG/KG DRY WEIGHT

(PARTS PER MILLION (PPM) DRY)

ARSENIC 57 93

CADMIUM 5.1 6.7

CHROMIUM 260 270

COPPER 390 390

LEAD 450 530

MERCURY 0.41 0.59

SILVER 6.1 6.1

ZINC 410 960

MG/KG ORGANIC CARBON

(PPM CARBON)

MG/KG ORGANIC CARBON

(PPM CARBON)

LPAH 370 780

NAPHTHALENE 99 170

ACENAPHTHYLENE 66 66

ACENAPHTHENE 16 57

FLUORENE 23 79

PHENANTHRENE 100 480

ANTHRACENE 220 1200

2-METHYLNAPHTHALENE 38 64

HPAH 960 5300

FLUORANTHENE 160 1200

PYRENE 1,000 1400

BENZ(A)ANTHRACENE 110 270

CHRYSENE 110 460

TOTAL BENZOFLUORANTHENES 230 450

BENZO(A)PYRENE 99 210

INDENO (1,2,3,-C,D) PYRENE 34 88

DIBENZO (A,H) ANTHRACENE 12 33

BENZO(G,H,I)PERYLENE 31 78

1,2-DICHLOROBENZENE 2.3 2.3

1,4-DICHLOROBENZENE 3.1 9

1,2,4-TRICHLOROBENZENE 0.81 1.8

HEXACHLOROBENZENE 0.38 2.3

DIMETHYL PHTHALATE 53 53

DIETHYL PHTHALATE 61 110

DI-N-BUTYL PHTHALATE 220 1700

BUTYL BENZYL PHTHALATE 4.9 64

BIS (2-ETHYLHEXYL) PHTHALATE 47 78

DI-N-OCTYL PHTHALATE 58 4500

DIBENZOFURAN 15 58

HEXACHLOROBUTADIENE 3.9 6.2

N-NITROSODIPHENYLAMINE 11 11

TOTAL PCB'S 12 65

UG/KG DRY WEIGHT

(PARTS PER BILLION (PPB) DRY)

UG/KG DRY WEIGHT

(PARTS PER BILLION (PPB) DRY)

PHENOL 420 1200

2-METHYLPHENOL 63 63

4-METHYLPHENOL 670 670

2,4-DIMETHYL PHENOL 29 29
Page A-4 Bellingham Bay ContSediments TMDL

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PENTACHLOROPHENOL 360 690

BENZYL ALCOHOL 57 73

BENZOIC ACID 650 650
Bellingham Bay Contaminated Sediments TMDL Page A-5

11/06/01

Appendix A-2

Complete 303(d) Contaminated Sediment Listings for Inner Bellingham Bay

Water number: 390KRD

Water body ID Number: WA-01-0050

Water grid cell

number

Cell

Lat.

Cell

Lon.

Parameter BASIS MEDIUM Action

Needed

48122H5D0 48.735 122.505 Mercury Georgia-Pacific Outfall site exceeds sediment

quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H5C1 48.725 122.515 Total PCBs Harris Avenue Shipyard site exceeds sediment

quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H5C1 48.725 122.515 Phenol Harris Avenue Shipyard site exceeds sediment

quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H5C1 48.725 122.515 Zinc Harris Avenue Shipyard site exceeds sediment

quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H5C1 48.725 122.515 Copper Harris Avenue Shipyard site exceeds sediment

quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H5C1 48.725 122.515 Mercury Harris Avenue Shipyard site exceeds sediment

quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H5C1 48.725 122.515 Arsenic Harris Avenue Shipyard site exceeds sediment

quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H5C1 48.725 122.515 Lead Harris Avenue Shipyard site exceeds sediment

quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 2,4-

Dimethylp

henol

Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 2-

Methylnap

hthalene

Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Acenaphth

ene

Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Anthracene Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Arsenic Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Benz(a)ant

hracene

Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Benzo(a)py

rene

Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL
Page A-6 Bellingham Bay ContSediments TMDL

 11/06/01

Appendix A-2 (continued)

Complete 303(d) Contaminated Sediment Listings for Inner Bellingham Bay

Water grid cell

number

Cell

Lat.

Cell

Lon.

Parameter BASIS MEDIUM Action

Needed

48122H4E9 48.745 122.495 Benzo(b,k)fluor

anthenes

Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Benzo(ghi)peryl

ene

Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Bis(2-

ethylhexyl)

phthalate

Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Chrysene Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Copper Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Dibenz(a,h)anth

racene

Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Dibenzofuran Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Fluoranthene Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Fluorene Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Indeno(1,2,3-

cd)pyrene

Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Mercury Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Pentachlorophe

nol

Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Phenanthrene Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Pyrene Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E9 48.745 122.495 Zinc Whatcom and I&J waterways site exceeds

sediment quality standards in 1996 Sediment

Management Standards Site List.

Sediment TMDL

48122H4E8 48.745 122.485 Sediment

bioassay

Confirmatory designation (added to the state's

303(d) list by EPA)

Sediment TMDL
Bellingham Bay Contaminated Sediments TMDL Page A-7

11/06/01

Appendix A-3

Inner Bellingham Bay

1996-1998 303(d) sediment listings comparison

WA-01-0050

390KRD

WB name grid cell # LAT LON PARAMETER 1998 LIST? 96list?

Whatcom and 48122H4E8 48.745 122.485 Sediment Bioassay Yes- EPA add Yes

I&J Waterways 48122H4E9 48.745 122.495 2,4-Dimethylphenol Yes Yes

48122H4E9 48.745 122.495 2-Methylnaphthalene Yes Yes

48122H4E9 48.745 122.495 Acenaphthene Yes Yes

48122H4E9 48.745 122.495 Anthracene Yes Yes

48122H4E9 48.745 122.495 Arsenic Yes Yes

48122H4E9 48.745 122.495 Benz(a)anthracene Yes Yes

48122H4E9 48.745 122.495 Benzo(a)pyrene Yes Yes

48122H4E9 48.745 122.495 Benzo(b,k)fluoranthenes Yes Yes

48122H4E9 48.745 122.495 Benzo(ghi)perylene Yes Yes

48122H4E9 48.745 122.495 Bis(2-ethylhexyl) phthalate Yes Yes

48122H4E9 48.745 122.495 Chrysene Yes Yes

48122H4E9 48.745 122.495 Copper Yes Yes

48122H4E9 48.745 122.495 Dibenz(a,h)anthracene Yes Yes

48122H4E9 48.745 122.495 Dibenzofuran Yes Yes

48122H4E9 48.745 122.495 Fluoranthene Yes Yes

48122H4E9 48.745 122.495 Fluorene Yes Yes

48122H4E9 48.745 122.495 Indeno(1,2,3-cd)pyrene Yes Yes

48122H4E9 48.745 122.495 Mercury Yes Yes

48122H4E9 48.745 122.495 Pentachlorophenol Yes Yes

48122H4E9 48.745 122.495 Phenanthrene Yes Yes

48122H4E9 48.745 122.495 Pyrene Yes Yes

48122H4E9 48.745 122.495 Zinc Yes Yes

Harris Ave 48122H5C1 48.725 122.515 Total PCBs Yes No

Shipyard 48122H5C1 48.725 122.515 Phenol Yes No

48122H5C1 48.725 122.515 Zinc Yes No

48122H5C1 48.725 122.515 Copper Yes No

48122H5C1 48.725 122.515 Mercury Yes No

48122H5C1 48.725 122.515 Arsenic Yes No

48122H5C1 48.725 122.515 Lead Yes No

G-P Outfall 48122H5D1 48.735 122.505 Mercury Yes Yes
Page A-8 Bellingham Bay ContSediments TMDL

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Whatcom WW 48122H5E0 48.745 122.505 Mercury No Yes
Bellingham Bay Contaminated Sediments TMDL Page A-9

11/06/01

Appendix A-4

I&J Waterway Chemical and Biological Testing Results

Table A-4.1 - I&J Waterway Surface Sediment Sample Results

Sample-ID Date Arsenic

(mg/kg)

Cadmium

(mg/kg)

Chromium

(mg/kg)

Copper

(mg/kg)

Lead

(mg/kg)

Mercury

(mg/kg)

Zinc

(mg/kg)

HC-SS-15 9/96 0.67(b)

HC-SS-16 9/96 0.47(a)

HC-SS-17 9/96 0.58(a)

HC-SS-18 9/96 0.38

HC-SS-27 9/96 0.23

HC-SS-41 9/96 3 0.7U 10E 10 4.2U 0.13U 20

HC-SS-41(dup) 9/96 2.6 0.66U 9.5E 8.6 3.9U 0.13U 19

HC-SS-42 9/96 0.42(a)

HC-SS-43 9/96 0.15U

HC-SS-44 9/96 0.59(a)

HC-SS-45(c) 9/96 11E 1.6 71 73 19 0.36 130

HC-SS-46 9/96 0.36

HC-SS-48(c) 9/96 3.2E 0.59U 17 16 11 0.13U 51

HC-SC-83(c) 9/96 12E 1.3U 69 55 14 0.72(b) 97

HC-SC-84(c) 9/96 12E 1.3 71 62 15 0.5(a) 110

AN-SC-84(c) 10/98 1U 0.45(a) 106

HC-VC-94-C1(c) 7/97 11 1.1 58 44 15 1.3(b) 83

HC-VC-95-C1(c) 7/97 5.8 0.85U 41 39 12 0.68(b) 69

(a) exceeds SQS numeric criteria

(b) exceeds CSL numeric criteria

(c) additional organic sampling results at these stations can be found in Anchor Environmental/Hart

 Crowser, 1999, Appendices B and L.

Data qualifiers “U” means the analyte was not detected and reported as the sample quantitation limit; and “E” means the analyte is an estimated value between the detection and quantitation limit.

Table A-4.2 - I&J Waterway Biological Testing Results

Sample-ID Date screening level

(basis)

E.

estuarius

D.

excentricus

N.

arenaceodentata

Mytilus

edulis

HC-SS-15 9/96 SQS (SMS) Pass Pass Pass

CSL (SMS) Pass Pass Pass

HC-SS-17 9/96 SQS (SMS) Pass Pass Pass

CSL (SMS) Pass Pass Pass

HC-SS-41 9/96 SQS (SMS) Pass Pass Pass

CSL (SMS) Pass Pass Pass

HC-VC-94-C1 7/97 one-hit (PSDDA) Pass Pass Pass

two-hit (PSDDA) Pass Pass Pass

HC-VC-95-C1 7/97 one-hit (PSDDA) Pass Pass Pass

two-hit (PSDDA) Pass Pass Pass

AN-SC-84 9/96 SQS (SMS) Pass Pass Pass

CSL (SMS) Pass Pass Pass

(Anchor Environmental/Hart Crowser, 1999)
Page A-10 Bellingham Bay ContSediments TMDL

 11/06/01

Appendix A-5

Georgia Pacific Outfall, September 1999 Sediment Sampling Results

Sample Stations

Parameter

SS-A2 SS-B1 SS-B2

Mercury (mg/kg) 1.4 0.52 0.27

4-Methylphenol (ug/kg)

1 week after sampling 6,000 840 1,700

5 weeks after (Neanthes start) 7,400 2,000 5,600

9 weeks after (Neanthes end) 5,200 970 2,000

Amphipod Bioassay

Unpurged Pass Exceeded SQS Pass

Purged (to remove high NH3) Pass

Pass Pass

Mytilus Larvae Bioassay Pass Pass Pass

Neanthes Growth Bioassay Pass Pass Pass

(Anchor Environmental, 2000)
Bellingham Bay Contaminated Sediments TMDL Page A-11

11/06/01

Appendix A-6

Estimated Maximum Impact/Mixing Zones near Identified Sources of Potential Sediment Quality 

Water Quality Sediment 

Identified Source

Parameters of

Potential Concern

Max Measured

Concentration

(ug/L)

Water

Quality

Criterion

(ug/L)

Measured

Peak Flow

(m3/sec)

Estimated Max

Impact/Mix Zone

Radius

(feet)

Measured

Peak Flow

(m3/sec)

Suspended

Sediment

Conc.

(mg/L)

Ave

Particu

Conc, (m

dry w

Bellingham Marine Dissolved Copper 6.7 2.5 0.0003 < 1 0.0001 - - Stormwater Runoff Total Copper 1,100 - - - 0.0001 290 - 

Total Mercury 0.2 0.025 0.0003 < 1 0.0001 290 - 

Bornstein Seafoods Total Arsenic 350 36 0.0003 2 0.0001 - - Area Drainage Outfall Diss/Tot Cadmium 32 8 0.0003 < 1 0.0001 - - 

Diss/Tot Copper 1,600 2.5 0.0003 30 0.0001 - - 

Diss/Tot Silver 28 1.2 0.0003 10 0.0001 - - 

Diss/Tot Zinc 830 77 0.0003 2 0.0001 - - 

"C' Street Outfall Dissolved Copper 34 2.5 0.050 7 0.029 - - City Stormwater and CSO Particulate Phenol 0.02 - 0.050 - 0.029 38 0.66 

Particulate 4-

Methylphenol

0.08 - 0.050 - 0.029 38 2.0 

Cornwall Landfill Dissolved Copper 12 2.5 0.002 1 0.002 - - Seepage and Dissolved Lead 9.9 5.8 0.002 < 1 0.002 - - Shoreline Erosion Fec. Colif. (#/100

ml)

230 14 0.002 1 0.002 - - 

Solid Waste - - N/A - N/A - - 

G-P Log Pond(groundwater)

Total Mercury 9.4 0.025 0.00004 10 0.00004 - - 

G-P Outfall Particulate Mercury 0.29 0.025 1.6 10 1.6 96 3.0 (wastewater) (historic releases)
Page A-12 Bellingham Bay ContSediments TMDL

 11/06/01

Appendix A-6 (continued)

Estimated Maximum Impact/Mixing Zones near Identified Sources of Potential Sediment Quality 

Water Quality Sedime

Identified Source

Parameters of

Potential Concern

Max Measured

Concentration

(ug/L)

Water

Quality

Criterion

(ug/L)

Measured

Peak Flow

(m3/sec)

Estimated Max

Impact/Mix Zone

Radius

(feet)

Measured

Peak Flow

(m3/sec)

Suspended

Sediment

Conc.

(mg/L)

A

Parti

Conc, 

dry 

Harris Ave. Shipyard Source control within this area is being addressed as part of the ongoing Harris Avenue Shipyard Site indeR.G. Haley Dissolved Copper 33 2.5 0.030 8 0.019 - City Stormwater Runoff Particulate Phenol 0.02 - 0.030 - 0.019 32 0

Particulate 4-

Methylphenol

0.06 - 0.030 - 0.019 32 2

Roeder Avenue Landfill Source control within this area is being addressed as part of the ongoing Roeder Avenue Landfill Site indep

Anchor Environmental, 1999.
Bellingham Bay Contaminated Sediments TMDL Page A-13

11/06/01

Appendix A-7

Review of Discharge Sources in Bellingham Bay

The following is a review of available information on point source, groundwater, and other nonpoint sources that may affect sediments or carry potential near-field water quality concerns in

Inner Bellingham Bay. The detailed discussion of potential sources in Bellingham Bay was

collected from facility and project managers at the Department of Ecology and from the

“Bellingham Bay Demonstration Pilot Sediment Site and Source Control Documentation Report”

(Anchor Environmental, 1999). Source locations are depicted in Figure 2. A summary of the

active discharge permits administered by ecology in the larger Bellingham Bay watershed is

given in Table A-7.

Grid Cell Number H4F9- I&J Waterway

• Bornstein Seafoods. All process wastewater from this facility is treated and discharged to

the sanitary sewer. Stormwater runoff samples collected from the site have contained

concentrations of metals that exceeded water quality criteria (Anchor Environmental/Hart

Crowser, 2000). However, a surface sediment sample collected within the vicinity of the site

(HC-SS-45) did not exceed SQS chemical criteria for metals. Bis(2-ethylhexyl) phthalate

has been also detected in sediments near the Bornstein Seafoods outfall, however, this is

most likely related to historic releases from the former Olivine facility and/or other upland

sources and not from the active Seafood operation. Control of releases from the Bornstein

facility is being performed under Ecology’s NPDES program.

• Roeder Avenue Landfill. This historic municipal landfill is located between Whatcom and

I&J Waterways. Groundwater quality monitoring performed at locations adjacent to the

landfill detected levels of chromium above marine water quality criteria migrating towards

Bellingham Bay. However, surface sediment samples collected within the vicinity of the site

(HC-SS-45 and -47) did not exceed SQS chemical criteria for chromium, indicating that if

sediment contamination exists, it may be localized. Releases from the Roeder Avenue site

are being addressed through an integrated upland cleanup and redevelopment plan. Ecology

is overseeing the work under Ecology’s Voluntary Cleanup Program.

Grid Cells numbers H4F9, H4E8, H4E9, H4D9, H5D0, H5E0- Whatcom Waterway

• Bellingham Marine Industries (grid cell H4E8). A stormwater sample collected from this

site contained concentrations of metals that exceeded water quality protection criteria

(Anchor Environmental/Hart Crowser, 2000). However, no sediment contamination

problems have been found as a surface sediment sample collected within the vicinity of the

site (AN-SS-37) did not exceed SQS biological effects criteria.

• G-P Log Pond. A potential source for localized recontamination in Whatcom Waterway

was ground water seepage containing mercury from the upland area adjacent to the G-P log

pond. Low level concentrations have been detected in upland soil and groundwater and

shoreline seepage may contain similar or lower concentrations due to tidal mixing and

chemical attenuation (Anchor Environmental, 1999). Ecology is currently overseeing upland

cleanup activities, which include isolation of the log pond from the bay. Furthermore,

source control and cleanup actions will be implemented to ensure that sediments within the

Log Pond remain below SQS chemical criteria following the cleanup action under MTCA.
Page A-14 Bellingham Bay ContSediments TMDL

 11/06/01

• “C” Street Stormwater and Combined Sewer Overflow (CSO). The C-street CSO is

regulated under the NPDES permit for the Bellingham Post Point Wastewater Treatment

Plant. Department of Ecology records show that there has not been a CSO discharge event in

the past 10 years. However, wet and dry season water samples collected from the C-street

CSO site area contained concentrations of copper that exceeded water quality protection

criteria. Particulate fraction analysis of the sediment in the CSO conveyance system (not in

the discharge) showed phenol and 4-methylphenol at concentrations above the CSL chemical

criteria. A surface sediment sample collected within the vicinity of the site (sample station

HC-SS-35) exceeded the CSL chemical criteria for mercury and phenol as well as the CSL

biological effects criteria (Anchor Environmental/Hart Crowser, 2000). Localized biological

toxicity and the accumulations of phenol and 4-methylphenol in nearshore sediments within

the outfall area may be partly attributable to stormwater sources, but also appear to be closely

tied to historical deposits of woody debris and discontinued mercury discharges. The

contaminated sediments in the C Street CSO outfall area will be remediated as part of the

Whatcom Waterway remediation. Further analysis of source control for this outfall is

discussed in the Summary Implementation Strategy section below.

• Wood Waste and Woody Debris. Accumulations of bark and associated woody debris near

the G-P Log Pond and in other areas of the Whatcom Waterway are likely associated with

historical practices (Anchor Environmental/Hart Crowser, 2000). Although relatively limited

log rafting operations continue in some areas of the Whatcom Waterway site today,

historically there was more extensive log rafting throughout the Inner Bellingham Bay. In

addition, historical discharges of pulp and other materials from the G-P facility are now

controlled by a variety of improved handling, collection, and wastewater treatment processes,

all of which are regulated under G-P’s existing NPDES permit.

• Boulevard Park. Subsurface soil and groundwater at this upland cleanup site contain

elevated concentrations of metals, petroleum hydrocarbons, and polynuclear aromatic

hydrocarbons (PAHs) associated with historical manufactured gas production. However,

surface sediment samples collected adjacent to the site (AN-SS-301 and -304) did not exceed

SQS biological effects criteria.

• Chevron Bulk Fuels Facility. This is an upland cleanup site where elevated concentrations

of petroleum hydrocarbons have been detected in soil and groundwater at the former

Chevron Bulk Fuels facility. However, surface sediment samples collected within the

vicinity of the site (AN-SS-36 and -37) did not exceed SQS biological effects criteria.

Independent remedial actions have been implemented at the site, including soil removal and

operation of a subsurface product recovery and groundwater extraction/treatment system.

• R.G. Haley. Soil and groundwater at this upland contaminated site contain concentrations of

pentachlorophenol, dioxins and PAHs that exceed cleanup criteria.. Groundwater seeps from

the site to the Bay were recently discovered that might be adversely impacting sediments. In

addition, wet and dry season stormwater runoff samples collected from the site contained

concentrations of copper that exceeded water quality criteria (Anchor Environmental/Hart

Crowser, 2000). However, a surface sediment sample collected in the vicinity of the site

(HC-SS-29) did not exceed SQS chemical criteria for these chemicals, indicating that

sediment contamination, if it exists, may be localized. The current site owner is taking

emergency actions to control seepage from the site under Ecology oversight. Once the

discharge is terminated a broader investigation and cleanup of the site will occur that
Bellingham Bay Contaminated Sediments TMDL Page A-15

11/06/01

includes an evaluation of sediments. This work will occur under a MTCA Agreed Order

with Ecology.

Grid Cell Number H5D1- Georgia-Pacific Outfall

• Georgia-Pacific Outfall. Water quality at the outfall mixing zone boundary is monitored

and evaluated by Ecology under an NPDES permit. Based on effluent dispersion modeling,

water quality criteria are achieved within approximately 10 feet of the outfall. Sampling and

analysis of the G-P effluent discharge was undertaken as part of the Whatcom Waterway

RI/FS (Anchor Environmental/Hart Crowser, 2000). Based on detailed modeling analysis,

the G-P outfall has not been identified as an ongoing source of mercury to sediments in

Bellingham Bay. Sampling data from 1999 confirmed that the sediments at the G-P outfall

comply with SQS criteria for mercury (Anchor Environmental, 2000A). Further discharge

controls have been implemented at G-P, including the closure of the chlor-alkali plant (the

mercury discharge source), which will improve the discharge quality from the outfall. Under

the G-P NPDES permit, compliance monitoring of the effluent discharge and of sediments

around the outfall will be conducted.

Grid Cell Number H5C1- Harris Avenue Shipyard

• Harris Avenue Shipyard. Nearshore sediments in this area exceed SQS chemical criteria

for metals, PCBs, and semivolatile organic compounds. Historical releases are responsible

for sediment contamination. As discussed previously, the site cleanup and integrated source

control actions are being addressed as a component of the Near-term Remedial Action

Alternatives in the Bellingham Bay Comprehensive Strategy and by the Port of Bellingham’s

RI/FS. The NPDES permit for the shipyard operations controls current shipyard activities to

protect water quality and prevent sediment recontamination. At this facility, all process

wastewater and wash water is collected and treated prior to discharge to the sanitary sewer.

Furthermore, the facility is currently working with the Department of Ecology to develop

plans to collect industrial stormwater run off from all work areas at the facility, provide

treatment and discharge it to the sanitary sewer.

Grid Cell Number H4D9- Cornwall Avenue Landfill

h Cornwall Avenue Landfill. Groundwater and shoreline seepage samples collected in this

area have contained concentrations of metals and fecal coliform above the water quality

criteria. Nearshore sediments in this area also exceed SQS chemical criteria for mercury,

PCBs, and wood waste (sample stations HC-SS-20 and 28). Erosion of solid waste from the

exposed landfill shoreline has been an ongoing source of sediment contamination. Control of

seepage and erosion releases is occurring through emergency actions and is a component of

the Near-term Remedial Action Alternatives in the Bellingham Bay Comprehensive Strategy.

The source control and cleanup work are being addressed by the Port of Bellingham’s

concurrent focused Remedial Investigation and Feasibility Study under Ecology’s Voluntary

Cleanup Program.

Bay-wide Discharges

• Urban Stormwater Runoff. Direct sampling of surface water runoff from Bellingham

storm drains shows concentrations of dissolved metals that exceed freshwater and marine

ambient water quality criteria (Anchor Environmental/Hart Crowser, 2000). The highest

concentrations of metals including copper, lead and zinc have been reported during “first

flush” storm events, preceded by extended dry periods. Similarly elevated metals

concentrations in urban runoff have been documented throughout Puget Sound and appear to
Page A-16 Bellingham Bay ContSediments TMDL

 11/06/01

be the result of normal vehicle releases. Although metal concentrations in stormwater runoff

may exceed marine water quality criteria at the point of discharge, no near-field adverse

effects have been documented in water or sediment within the nearshore areas of Bellingham

Bay.

In addition to metals in the water column, accumulated particulate matter present within the

City’s stormwater runoff conveyance system has periodically contained concentrations of

phenol and 4-methylphenol above the SQS chemical criteria. However, sediment samples

collected immediately adjacent to storm drain outfalls in Bellingham Bay do not exceed SQS

criteria as demonstrated by confirmatory bioassays (Anchor Environmental/Hart Crowser,

2000).

Moreover, the overall distribution of phenol and 4-methylphenol in Bellingham Bay, and

particularly within Whatcom Waterway, are likely associated with the historical deposits of

woody debris and not due to stormwater discharges. Both phenol and 4-methylphenol are

known degradation products of natural wood products and an accumulation of these

compounds in regional sediments is frequently associated with woody debris deposits.

Overall, the pattern of sediment phenol and 4-methylphenol concentration in Bellingham Bay

seems to match with the distribution of woody debris (Anchor Environmental/Hart Crowser,

2000). Whatever the case, wood debris will be remediated in Inner Bellingham Bay to meet

state standards and source control efforts will be conducted to identify if any currently

unknown source of 4-methylphenol exists.

In conclusion, the technical studies developed as part of the remedial activities in Bellingham

Bay did not identify city stormwater sources as an on-going contributor to the sediment

contamination problems in Bellingham Bay. It is believed that the municipal stormwater

sources do not pose a reasonable potential to contaminated or recontaminated sediments in

the bay.

Ecology currently regulates certain industrial stormwater discharges to Bellingham Bay

under the Baseline Stormwater General Permit for Industrial Facilities. Urban stormwater

runoff includes piped and ditched conveyance as well as sheet flow releases and is regulated

through the Municipal stormwater permits. Bellingham is required to develop a stormwater

program in compliance with the Puget Sound Stormwater Management Manual. The City

also will be covered under the Phase II NPDES stormwater program. The city’s stormwater

program is discussed further in the Summary Implementation Strategy.

h Atmospheric mercury. Part per trillion mercury analysis performed at the Whatcom

Waterway site as part of the remedial investigation included water column, sediment trap and

in situ sediment. Mercury concentrations in the water column were far below WQ standards

and conservative partitioning calculations indicate that the water column is not a source of

sediment recontamination.
Bellingham Bay Contaminated Sediments TMDL Page A-17

11/06/01

Table A-7

Summary of Active Discharge Permits Administered by Ecology in the Larger Bellingham Bay

Watershed

(excluding surface water and groundwater discharges to the Nooksack River system)

Facility Name NPDES Permit No. Permit Type

NPDES Permits:

Bellingham Wastewater Treatment Plant WA0023744C Municipal

Brooks Manufacturing WA0030805B Industrial

Stormwater

Georgia-Pacific West WA000109-1 Industrial

Wastewater

Maritime Contractors/Harris Avenue Shipyard WA0031348B Industrial

Stormwater

Oeser Co. WA0030813B Industrial

Stormwater

Tilbury Cement WA0001198B Industrial

Stormwater

WDFW Bellingham Hatchery WA0031500A Fish Hatchery

General Permits - Boatyards:

B&J Fiberglass WAG030058A Industrial

Stormwater

Boatyard at Colony Wharf WAG030006A Industrial

Stormwater

Hilton Harbor Marina WAG030024A Industrial

Stormwater

Marine Services Northwest WAD030029A Industrial

Stormwater

Padden Creek Marine WAG030033A Industrial

Stormwater

Weldcraft Steel and Marine WAG030051A Industrial

Stormwater

General Permits - Sand and Gravel:

Pacific Concrete WAG503028A Stormwater

General Permits - Stormwater:

Bellingham Cold Storage SO300596/7B Stormwater

Bellingham Pole and Timber SO3001568B Stormwater

Bornstein Seafoods SO3000679B Stormwater

Cornwall Warehouse SO3000115B Stormwater

State Wastewater Discharge Permits to POTW :

Bellingham Cold Storage WA0002143B Industrial

Bornstein Seafoods ST0007304C Industrial

New West Fisheries ST0007345A Industrial

Olivine Corp ST0007383A Industrial
Page A-18 Bellingham Bay ContSediments TMDL

 11/06/01

Appendix A-8

Loading Capacity Discussion for Each 303(D) Listed Grid Cell

For each 303(d) listed water grid specifically, the loading capacity is viewed as follows:

Water grid cell # H4F9 - I&J Waterway

The loading capacity (meeting SMS) is not currently exceeded from historic contamination or

ongoing sources for any sediment quality parameter. For this reason, all the parameters

associated with the I&J Waterway should be removed from the 303(d) list in the next listing

cycle.

Water grid cell # H5D1- Georgia Pacific Outfall

Due to natural attenuation and recent source control activities, the loading capacity (meeting

SMS) is not currently exceeded from historic contamination or ongoing sources for mercury.

Recent sampling for mercury demonstrates compliance with SQS criteria (Anchor

Environmental 2000A). For this reason, grid cell # H5D1 should be removed from the 303(d)

list for mercury. A wasteload allocation is assigned to Georgia Pacific for discharges into

Bellingham Bay to assure sediment standards for mercury are not violated in the future.

Water grid cells # H4F9, H4E8, H4E9, H4D9, H5D0, H5E0- Whatcom Waterway

For Whatcom Waterway, due to natural attenuation and recent source control activities, the

loading capacity (meeting SMS) is not currently exceeded from historic contamination or

ongoing sources for 2,4-dimethylphenol, 2-methylnaphthalene, acenapthene, anthracene, arsenic,

benz(a)anthracene, benzo(a)pyrene, benzo(b.k)fluoranthenes, benzo(ghi)perylene, bis(2-

ethylhexyl)phthalate, chrysene, copper, dibenz(a,h)anthracene, dibenzofuran, fluoranthene,

fluorene, indeno(1,2,3-cd)pyrene, pentachlorophenol, phenanthrene, phenol, pyrene, and zinc.

This information should be used as a basis to de-listed these parameters from the 303(d) list.

The remaining parameters include mercury, phenol, 4-methylphenol, sediment bioassay, and

wood debris. The sediment cleanup will remediate the historical contaminant loadings that were

responsible for the 303(d) listing. Recontamination from mercury, phenol, 4-methylphenol,

biotoxicity, and wood debris have not been identified as a potential from ongoing sources in

Inner Bellingham Bay. Source control and monitoring activities will nonetheless be designed to

provide assurance against recontamination and maintain compliance with the state Sediment

Management Standards with the goal of maintaining sediment quality that satisfies SQS criteria.

The loading capacity is therefore designed as the mass loading that maintains compliance with

the state Sediment Quality Standards Criteria for mercury, phenol, 4-methylphenol, sediment

bioassay, and wood debris. The SQS criteria for Inner Bellingham Bay are: mercury: 1.2 mg/kg;

phenol: 420 μg/kg; 4-methylphenol: 670μg/kg; wood debris: <50% by volume; sediment

bioassay: “no adverse effects on biological resources”. The mass loading from any source or

combination of sources is not to exceed these criteria.

Water grid cell # H4D9 - Cornwall Avenue Landfill

Sediment cleanup is designed to remediate the historical contaminant loading responsible for the

303(d) listing. On-going impacts to sediments have not been identified, and source control

activities will provide assurance against recontamination and maintain compliance with the state

Sediment Management Standards with the goal of maintaining sediment quality that satisfies

SQS criteria. The loading capacity is the mass load that maintains compliance with the state

Sediment Management Standards.
Bellingham Bay Contaminated Sediments TMDL Page A-19

11/06/01

Water grid cell # H5C1- Harris Avenue Shipyard

Sediment cleanup will remediate the historical contaminant loading responsible for the 303(d)

listing and source control activities will prevent recontamination and maintain compliance with

the state Sediment Management Standards with the goal of maintaining SQS criteria. The

loading capacity, defined as the mass-based discharge that maintains compliance with standards,

will be achieved through the remediation activities. The current discharge from the shipyard is

controlled and does not pose a threat to sediment recontamination.

Table 6 (page 24 of text) provides a summary of the parameters and associated grid cells

recommended for de-listing from the 303(d) list in the next listing cycle based on analysis of data

used in the development of the Bellingham Bay TMDL.
Page A-20 Bellingham Bay ContSediments TMDL

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Appendix A-9

1998 DMMP Screening Level (SL), Bioaccumulation Trigger (BT) and Maximum Level (ML)

Guideline Chemistry Values (Dry Weight Normalized) (1)

CHEMICAL

CAS(2)

NUMBER

SCREEING

LEVEL

BIOACCUM

TRIGGER

MAXIMUM

LEVEL

METALS (mg/kg)

 Antimony 7440-36-0 150 150 (3) 200

 Arsenic 7440-38-2 57 507.1 700

 Cadmium 7440-43-9 5.1 --- 14

 Chromium 7440-47-3 --- --- ---

 Copper 7440-50-8 390 --- 1,300

 Lead 7439-92-1 450 --- 1,200

 Mercury 7439-97-6 0.41 1.5 2.3

 Nickel 7440-02-0 140 370 (4) 370

 Silver 7440-22-4 6.1 6.1 (3) 8.4

 Zinc 7440-66-6 410 --- 3,800

ORGANOMETALLIC COMPOUNDS (ug/L)

 Tributyltin(5) (interstitial water) 56573-85-4

ORGANICS (ug/kg)

Total LPAH --- 5,200 --- 29,000

 Naphthalene 91-20-3 2,100 --- 2,400

 Acenaphthylene 208-96-8 560 --- 1,300

 Acenaphthene 83-32-9 500 --- 2,000

 Fluorene 86-73-7 540 --- 3,600

 Phenanthrene 85-01-8 1,500 --- 21,000

 Anthracene 120-12-7 960 --- 13,000

 2-Methylnaphthalene 91-57-6 670 --- 1,900

Total HPAH --- 12,000 --- 69,000

 Fluoranthene 206-44-0 1,700 4,600 30,000

 Pyrene 129-00-0 2,600 --- 16,000

 Benz(a)anthracene 56-55-3 1,300 --- 5,100

 Chrysene 218-01-9 1,400 --- 21,000

 Benzofluoranthenes (b+k) 205-99-2

207-08-9

3,200 --- 9,900

 Benzo(a)pyrene 50-32-8 1,600 3,600 (4) 3,600

 Indeno(1,2,3,-c,d)pyrene 193-39-5 600 --- 4,400

 Dibenzo(a,h)anthracene 53-70-3 230 --- 1,900

 Benzo(g,h,i)perylene 191-24-2 670 --- 3,200

Chlorinated Hydrocarbons

 1,3-Dichlorobenzene 541-73-1 170 1,241 ---

 1,4-Dichlorobenzene 106-46-7 110 120 (4) 120

 1,2-Dichlorobenzene 95-50-1 35 37 110

 1,2,4-Trichlorobenzene 120-82-1 31 --- 64

 Hexachlorobenzene (HCB) 118-74-1 22 168 230
Bellingham Bay Contaminated Sediments TMDL Page A-21

11/06/01

Appendix A-9 (continued)

1998 DMMP Screening Level (SL), Bioaccumulation Trigger (BT) and Maximum Level (ML)

Guideline Chemistry Values (Dry Weight Normalized) (1)

CHEMICAL

CAS(2)

NUMBER

SCREEING

LEVEL

BIOACCUM

TRIGGER

MAXIMUM

LEVEL

ORGANICS, cont. (ug/kg)

Phthalates

 Dimethyl phthalate 131-11-3 1,400 1,400 (3) ---

 Diethyl phthalate 84-66-3 1,200 --- ---

 Di-n-Butyl phthalate 84-74-2 5,100 10,220 ---

 Butyl benzyl phthalate 85-68-7 970 --- ---

 Bis(2-Ethylhexyl)phthalate 117-81-7 8,300 13,870 ---

 Di-n-Octyl phthalate 117-84-0 6,200 --- ---

Phenols

 Phenol 108-95-2 420 876 1,200

 2-Methylphenol 95-48-7 63 --- 77

 4-Methylphenol 106-44-5 670 --- 3,600

 2,4-Dimethylphenol 105-67-9 29 --- 210

 Pentachlorophenol 87-86-5 400 504 690

Miscellaneous Extractables

 Benzyl alcohol 100-51-6 57 --- 870

 Benzoic acid 65-85-0 650 --- 760

 Dibenzofuran 132-64-9 540 --- 1,700

 Hexachloroethane 67-72-1 1,400 10,220 14,000

 Hexachlorobutadiene 87-68-3 29 212 270

 N-Nitrosodiphenylamine 86-30-6 28 130 (4) 130

Volatile Organics

 Trichloroethene 79-01-6 160 1,168 1,600

 Tetrachloroethene 127-18-4 57 102 210

 Ethylbenzene 100-41-4 10 27 50

 Total Xylenes (sum of o-, m-, p-) 95-47-6

108-38-3

106-42-3

40 --- 160

Pesticides

 Total DDT

 (sum of 4,4’-DDD, 4,4’-DDE and 4,4’-

 DDT)

72-54-8

72-55-9

50-29-3

6.9 50 69

 Aldrin 309-00-2 10 37 ---

 alpha-Chlordane 12789-03-6 10 37 ---

 Dieldrin 60-57-1 10 37 ---

 Heptachlor 76-44-8 10 37 ---

 Gamma-BHC (Lindane) 58-89-9 10 --- ---

 Total PCBs --- 130 38 (6) 3,100

Notes:

(1) Guidelines for non-ionic chemicals are likely to be carbon-normalized in a future edition of the users manual.

(2) Chemical Abstract Service Registry Number.

(3) BT adjusted to new SL for antimony, silver and dimethylphthalalte

(4) BT adjusted to new ML for nickel, benzo(a)pyrene, 1,4-dichlorobenzene and N-nitrosodiphenylamine.

(5) See Testing, Reporting, and Evaluation of Tributyltin Data in PSSDA and SMS Programs at

http://www.nws.usace.army.mil/dmmo/8tharm/tbt96.htm

(6) This value is normalized to total organic carbon, and is expressed in mg/kg (TOC normalized
Page A-22 Bellingham Bay ContSediments TMDL

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Bellingham Bay Contaminated Sediments TMDL Page B-1

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Appendix B- Public Participation Materials
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Water Cleanup Plans

Inner Bellingham Bay Contaminated Sediment TMDL Review Draft

Introduction 

The Washington Department of Ecology (Ecology) is seeking public comment on a water cleanup plan

for sediments in Inner Bellingham Bay. Water cleanup plans are called total maximum daily load

(TMDL) studies in the federal Clean Water Act. The Bellingham Bay water cleanup plan is one of the

first of its kind in the nation; few others have used as broad a range of regulatory programs to clean up

toxic pollution of marine sediments.

Background 

Located in the most northern part of Puget Sound, 42-square-mile Bellingham Bay receives drainage from

a 1,000-square-mile land base that includes the Nooksack River and Squalicum, Little Squalicum, Baker,

Whatcom and Padden creeks.

Bellingham Bay fulfills many activities that require a high level of environmental quality, including

commercial and recreational fishing and shellfishing. It provides valuable habitat for wild Chinook and

other types of endangered salmon, as well as for numerous marine mammals and waterfowl. Bellingham

Bay is also an essential feature of navigation, water-dependent commerce and recreation in northern

Puget Sound.

Like many urban bays in the country, contaminated marine sediments are a legacy of past industrial

practices that can pose a present threat to marine life and to public health. Most of the activity that affects

Bellingham Bay occurs in or near the city of Bellingham. However, the bay is also affected by pollution

sources located in watersheds that drain to the bay.

Contaminants in Bellingham Bay 

A decade ago, scientists confirmed 25 toxic substances present in Bellingham Bay sediments that failed

environmental standards. From cleanup and pollution prevention efforts carried out by businesses and

government, and natural cleansing processes during the past decade, many areas of the bay are now

considered safe to humans and aquatic life. However, ongoing sampling shows that remaining sediment

contaminants of concern are within three Bellingham Bay areas – Whatcom Waterway, Cornwall Avenue

Landfill, and the Harris Avenue Shipyard. Sediments in pockets of these three areas contain one or more

of the following pollutants or conditions that fail environmental standards:

Mercury and other metals – Naturally occurring in the environment, but also used in, or a by-product

of, manufacturing and mining processes. Many vehicle-use and maintenance activities produce heavy

metal by-products.

June 2001
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polychlorinated biphenyls (PCBs) - Complex compounds with different chlorine content. PCBs were

used in the manufacture of electrical equipment; also used in paints, adhesives, metals coatings and

plastics until 1976, when it’s use was banned; a by-product of combustion.

Phenols - A large group of chemicals, including 4-methylphenol, used in a variety of manufacturing

processes and a major ingredient of such wood preservatives as creosote and pentachlorophenol.

Wood waste – Measured in the volume of wood-waste along key shoreline areas.

Sediment “bioassay” - Tests of fish and shellfish to determine whether contaminants such as mercury are

accumulating in tissue.

Cleaning up polluted sediments 

Under the federal Clean Water Act, a “total maximum daily load” (TMDL) analysis must be developed

for waterbodies that fail environmental standards. A TMDL study determines how much pollution a

waterbody can receive and still remain healthy.

The cleanup plan for Bellingham Bay builds on the Bellingham Bay Comprehensive Strategy developed

by the Bellingham Bay Demonstration Pilot Work Group. The Bellingham Bay water cleanup plan is

designed to:

• Identify the portions of Bellingham Bay that are on the state's 303 (d) list of impaired waterbodies

due to sediment contamination;

• Summarize the degree of sediment contamination;

• Review the standards and regulatory procedures for improving sediment quality;

• Provide information on the technical analysis and modeling approach used for sediment

remediation and source control;

• Identify facilities and stormwater sources that discharge directly into Bellingham Bay;

• Identify sediment cleanup and other pollution reductions needed (wasteload allocations); and

• Document the implementation strategy for achieving environmental compliance with

Washington's sediment management standards.

The Bellingham Bay Comprehensive Strategy was developed by U.S. Fish & Wildlife Department,

Environmental Protection Agency and Army Corps of Engineers; Washington State departments of

Ecology, Natural Resources, Fish & Wildlife, Transportation and Puget Sound Water Quality Action

Team; Lummi Nation and Nooksack Tribe; Whatcom County Health and Human Services, Port of

Bellingham and City of Bellingham.

Public comment sought on Bellingham Bay sediments cleanup plan 

Comments on the proposed Bellingham Bay TMDL will be accepted through July 20, 2001. The TMDL

study and recommendations can be accessed at www.ecy.wa.gov/biblio/0110036.html or reviewed at

the Bellingham Library or Ecology’s Bellingham Office, 1204 Railroad Ave. Comments should be

mailed to Pam Elardo, P.E., Department of Ecology, NW Regional Office, 3190 - 160th Ave. SE,

Bellevue, WA 98008-5452. Comments may also be emailed to pam.elardo@metrokc.gov
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Public meeting June 21 

Ecology engineers will describe the water cleanup plan as part of a public meeting Thursday, June 21 at

the Bellingham Cruise Terminal. Beginning at 5 p.m., status reports from the bay cleanup and restoration

committees will be provided. At 6:30, information on the proposed Bellingham Bay TMDL will be

presented. Following the presentations, scientists who’ve been working on the overall Bellingham Bay

Comprehensive Strategy will be on hand until 8 p.m. to talk individually with citizens.

For more information 

Bellingham Bay TMDL – Pam Elardo – (206) 263-3699

Bellingham Bay Comprehensive Strategy – Lucy Pebles McInerney – (425) 649-7272

Ecology is an equal opportunity agency. If you have special accommodation needs, please call Carmen

Gilmore at Ecology’s Bellingham Office, (360) 738-6250, or TDD at (425) 649-4259.
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Appendix C- Comments Received

and Responses
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Comment letterRobyn du Pré

ReSources

Bellingham, WA
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Response to Robyn du Pré:
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Comment emailSteve E. Parker,

KingPriest Industrial Construction, Inc.

Ferndale, WA

-----Original Message-----

From: Steve E. Parker [mailto:steve@kingpriest.net]

Sent: Thursday, June 21, 2001 3:17 PM

To: pam.elardo@metrokc.gov

Cc: steve@masterd.net

Subject: Bellingham Bay cleanup and neighboring watersheds.

Pam

I was reading the report put out by the Department of Ecology as

a news release on June 15, 2001. The topic of "Bellingham bay's

cleanup and the progress" is a really big issue here in

Bellingham. I currently live in the neighboring town of

Ferndale,Wa and I am very interested in our present and future

watershed and Bay.

I own a Construction Company and I have installed Westmar Wash

Basins to many auto detailing companies, auto body shops, and

rental companies. We currently have a contract with Enterprise

Rent-a-car and install, maintain, and service for this company

all over the Puget Sound Area. The wash basin that we install

is similar to a oil water separator. The difference is the set

up. Oil water separators have no filtration set up in the

units, it

collects the water and sediments ( soap,oil,chemicals) and

allows them tosettle at the bottom of the unit while the water

runs into the Sanitary Sewer. To me, that is just fixing part

of the problem. What about the chemicals that don't settle.

They just end up in our Sanitary department and create larger

pollution problem that we'll have to deal with later. Why don't

we deal with it now and stop creating more problems. Are unit

operates similar to the standard oil water separator but it has

a filtration system. It allows the sediments to settle and then

it goes thru a oil skimmer and then it passes thru a pillow

filter with MaxFloKlear. Then the water is pumped or gravity

fed to sanitary services, but as filtered water. A recycling

process can also be used to conserve on water. That's killing

two birds with one stone. What happen to the enforcement of the

4-D law which prohibits the run off of soaps, oils, and

chemicals into the storm drain? I have seen enforcement in the

greater Seattle area, but not locally. We have done many jobs

down in the Seattle area and have been told about the pressure

to install units like ours at businesses applicable. Even
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warnings given and fines to enforce the issue. The issue of our

water supplies and watershed is very important to me and several

other people, and

the animals we protect by keeping our water clean. So my

question is, why doesn't the county enforce this issue? Who

enforces this issue? Why doesn't the government lead by example

and start placing these units in their vehicle maintenance

areas?

please send back a response to this email. Your time and

expertise is greatly appreciated.

Thank you,

Steve Parker

cell # is : (360)815-5664 Office # is : (360) 933-0825 fax #

is : (360)933-0825 Email : steve@masterd.net
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Email Response to Steve Parker:

-----Original Message-----

From: Elardo, Pam

Sent: Friday, August 17, 2001 11:43 AM

To: 'steve@kingpriest.net'

Subject: RE: Bellingham Bay cleanup and neighboring watersheds.

Mr. Parker:

I appreciate your comments on the Water Cleanup Plan for Inner

Bellingham Bay. I also appreciate your presence at the June

21st public meeting and our ensuing discussion.

The equipment you describe for auto washing may be a valuable

component of any industry’s or city’s stormwater management

program. It sounds like you have had notable success with your

product in numerous areas around Puget Sound. However, we

cannot legally advocate for a particular vendor in our program.

The Department of Ecology does have stormwater inspectors on

staff to address many of the problems you identify in your

letter. We work with industries and other facilities to comply

with water quality laws and regulations. We also issue

enforcement actions, when appropriate.

In addition, Ecology oversees local stormwater programs. We

have been involved with the City of Bellingham’s program, and

this involvement will increase as they will be covered under the

Phase II NPDES stormwater permit.

Your suggestion to place wastewater treatment units at

government maintenance areas would be evaluated by the city or

county stormwater program or at regulated industries or

commercial facilities.

The city’s stormwater program does contain inspection and

enforcement components through the Environmental Division in the

Public Works Department. Ecology is currently working with the

city and Whatcom County to clarify their roles with respect to

illegal discharges to the storm sewer system.

If you know of any specific spills or pressing water quality

problems, I suggest you contact our Bellingham Field Office at

(360)-738-6250.

Thank you for taking the time to comment on the Bellingham Bay

Water Cleanup Plan.
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Comment letterDonald Burpee

Enviro-Drain, Inc.

Snohomish, WA
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Response to Donald Burpee:
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Comment letterDarin Cramer

Washington State Department of Natural Resources

Olympia, WA
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Response to Darin Cramer:
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