# 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-WQFor 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 opport unity agency and does not discriminate on the basis of race, creed, color, disability, age, reli gion, national origin, sex, marital status, disabled veteran's status, Vietnam Era veteran' s status, or sexual orientation.

If you have special accommodation needs or requi re this document in an alternative format, please call Donna Lynch at (360) 407-7529. Th e TDD number is (360) 407-6006. E-mail can be sent to dlyn461@ecy.wa.gov.Bellingham Bay Contaminated Sediment TMDL Page i 11/06/01 

# 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 ...............................................................................................3 3 Overview....................................................................................................................... .........33 Implementation Plan Development........................................................................................33 Implementation Activities...................................................................................................... 34 Monitoring Strategy............................................................................................................ ...41 Reasonable Assurance ........................................................................................................... 41 Funding Sources ................................................................................................................ ....42

References Cited ............................................................................................................... .............45Page ii Bellingham Bay Contaminated Sediments TMDL 11/06/01 

# List of Tables

Table 1- Sediment Quality and Cleanup Screeni ng Level criteria for cont aminants 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 cel l 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 base d 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 Sedi ment 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, Se ptember 1999 Sediment Sampling Results A-6: Estimated Maximum Impact/Mixing Zone s 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), Bi oaccumulation Trigger (BT) and Maximum Level (ML) Guideline Chemistry Values (Dry Weight Normalized) Appendix B: Public Participation Materials Appendix C: Responses to Comments ReceivedBellingham Bay Contaminated Sediment TMDL Page iii 11/06/01 

# 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 Invest igation/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 Sedime nt Management Standards SQS- Sediment Quality Standards VCP- Voluntary Cleanup Program WAC- Washington Administrative Code

WLA- Waste Load AllocationPage iv Bellingham Bay Contaminated Sediments TMDL 11/06/01 

# Acknowledgements

This report was created through the efforts of several people at the Department of Ecology. Participants in Ecology’s contaminated sedi ment TMDL workgroup provided input and support to this TMDL development. Steve Butkus, Ri ck Huey, Lucy Pebles, and Brenden McFarland wrote key sections in their areas of expertis e. More people provi ded vital input through reviewing draft versions including Lucy Pebl es, 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 primar y author would also lik e to acknowledge those from the public at large who provided comments on the review draft document. This provide valuable input and contribute d greatly to the final report.Bellingham Bay Contaminated Sediments TMDL Page 1 11/06/01 

# 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 de veloped 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 qual ity standards consist of designated uses, such as cold water biota and drinking water supply, and cr iteria, usually numeric, to achieve those uses. When a lake, river or stream fails to meet wate r 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 wate rs will attain water quality standards. A TMDL includes a written, quantitative assessment of wate r 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 s till 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 diffus e source (referred to as a nonpoint source ) such as a farm, that f acility’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 (E cology) 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 Sect ion 303(d) list of impaired waterbodies. The list contains 31 separate parameters at seve ral 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 ha ve 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) lis t. The remaining parameters addressed in this submittal are those currently violating state standa rds or those in need of establishing wasteload allocations (see Table 4, Page 16).

As a summary, the five elements of the Be llingham Bay Contaminated Sediments TMDL as required by the Clean Water Act are:


### Loading CapacityPage 2 Bellingham Bay C ontSediments TMDL 11/06/01 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 sedime nt 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 de fined as the mass-based discharge that maintains compliance with sediment quality standards (e.g., for mercury: 1.2 mg/kg; phenol: 420 μ g/kg; 4-methylphenol: 670 μ g/kg; wood debris: <50% by volume). The implementation strategy employs cleanup, so urce 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 tota l 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 pr esented 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 impair ments 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 e ach 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 c ontributing 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.Bellingham Bay Contaminated Sediments TMDL Page 3 11/06/01 

# Background

Bellingham Bay is an urban bay in the heart of the city of Bellingham in northwest Washington State. The bay is an essen tial feature for navigation, commer ce, and recreation in the region. Like many urban bays in Puget Sound, contaminat ed marine sediments are a legacy of past industrial practices th at 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 contaminat ed sediments on the 1998 303(d) list. The purpose of this TMDL is to assure the CWA requirement s are satisfied to ensure the sediment quality in the bay meet Washington State Standards. The Inner Bellingham Bay Contaminat ed Sediment TMDL is designed to:

• Identify the portions of Bellingham Bay that ar e and designated on the 303(d) list as impaired due to contaminated sediments;

• Summarize the degree of sediment contamination;

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

• Provide information on the technical analysis and modeling approach used for sediment remediation and source control;

• Identify direct discharg ers to Inner Bellingham Bay;

• Identify sediment remediation (cleanup) a nd discharge source performance expectations (wasteload allocations ) fo r Inner Bellingham Bay; and

• Document the implementation strategy for ac hieving compliance with the state Sediment Management Standards.

The geographic area of the Bellingham Bay Proj ect 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 implementa tion activities that will be us ed 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 Demonstr ation 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 fede ral, state and local entities charged with addressing and coordinating contaminated sedi ment 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 sedime nt disposal to include source control, habitat restoration, and aquatic land use.Page 4 Bellingham Bay C ontSediments TMDL 11/06/01 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 me rcury and other contaminants at levels that exceed the state Sediment Management Standard s (SMS) chemical crite ria. Through Ecology’s contaminated site determination process, several areas in Bellingham Bay have been identified as being in violation of the SMS and were subse quently placed on the 303(d) list. Table 2 (Page 12) gives the 1998 303(d) list for Inner Bellingh am Bay. The contaminated areas identified in the 303(d) list correspond with the priorities identif ied in the Bellingham Bay Pilot Project. This TMDL does not address the Inner Bellingham Ba y water column impairments on the 303(d) list (fecal coliform and pH).

The Inner Bellingham Bay Contaminated Se diment TMDL draws heavily from the work conducted by members of the Pilot Work Group, bot h individually and collectively, to meet the requirements of the CWA. This contaminated se diment TMDL is one of the first of its kind nationwide. It is designed to bring together the cleanup and sour ce 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 c ontrol activities for the parame ters addressed in this TMDL are conducted by the individual responsible parties through th e Department of Ecology’s authority under the Model Toxics Control Ac t (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 Perm it 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 wa ter quality concerns related to the existing sediment contamination and to assess poten tial 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 outfa ll pipes (Anchor Environmental 1999). Source control and monitoring activities are to be us ed to verify predictions about ca pability for stormwater sourcesBellingham Bay Contaminated Sediments TMDL Page 5 11/06/01 to cause sediment contamination or recontamin ation. There are no non-st ormwater point source dischargers in Inner Belli ngham 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 acti vities that coincide with 303(d) listed areas in Inner Bellingham Bay. However, the Compre hensive 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 id entified in the Bellingham Bay Comprehensive Strategy.Page 6 Bellingham Bay C ontSediments TMDL 11/06/01Bellingham Bay Contaminated Sediments TMDL Page 7 11/06/01 

# 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). Aut hority to adopt rules, re gulations, and standards as are necessary to protect the environment is ve sted 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 designat ed 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 pr otection 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 Manage ment 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 th e original 303(d) listings in Inner Bellingham Bay. However, recent data has revealed th at 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 di scussion on the applicable criteria in the Sediment Management Standards (SMS). Th e Model Toxics Control Act (MTCA) and how SMS and MTCA work together under the 303(d) li st and TMDL development are also presented below. The SMS and MTCA rules are the prim ary tools for setting the standards and the implementation mechanisms for this TMDL.Page 8 Bellingham Bay C ontSediments TMDL 11/06/01 

## Sediment Management Standards
In 1991, the Washington State Department of Ecology adopted the Sediment Management Standards (SMS), Chapter 173-204 WAC, to identif y and designate sediments that have adverse effects on aquatic organisms or pose significant heal th risk to humans. The standards established a sediment quality goal for Washington State. Th e standards also include the requirements for how the standards are applied in source cont rol and cleanup actions. The regulation includes numeric chemical and biological standards to address ecological effects of impaired marine sediment quality in Puget Sound. Sediment crit eria 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 acu te 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 pr iority areas and define areas warranting further investigation. The framework in the SMS establ ishes that the biologica l tests override the chemical results under WAC 173-204-310(2), confir matory designation, which states “Sediment samples that pass all the required confirmatory biological tests are desi gnated as passing the applicable sediment quality standards of WA C 173-204-320”. Therefore, for example, when sediments do not meet quality criteria based on num erical chemical results, but do demonstrate compliance with biological standards, then th e 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 exceed ances 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 concep t 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 thos e 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 cu rrently 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 comp arison of the 1996 and 1998 303(d) listings for Inner Bellingham Bay. This TMDL submittal addres s all 303(d) parameter li stings and grid cells through either demonstrating compliance with sta ndards by review of current data or defining a wasteload allocation. The compete list of paramete rs 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.Bellingham Bay Contaminated Sediments TMDL Page 9 11/06/01 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

μ g/kg dry weight μ g/kg dry weight Phenol 420 1200 4-methylphenol 670 670

Sediment bioassay (1) (2) Wood waste 50% by volume 3 1. The biological effects criteria under SQS are base d 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 conf irmatory biological tests, the sample location is considered “clean” or in compliance with the SQS. 2. The biological effects criteria under CSL are ba sed 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 effect s tests. The specific tests and target endpoints for CSL biological effects criteria for Puget Sound mari ne 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 belo w which only minor adverse effects may result in marine sediments (Kendall and Michelsen, 1997).

Some of the key concepts of the Sediment Ma nagement Standards applicable to contaminated sediments and TMDLs in general include:

• Sediment Impact Zones (WAC 173-204-415) ar e sediment quality dilution zones that may be authorized around outfalls for ongoi ng 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 th e 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 (W AC 173-204-530) – The numeric CSL values provide the basis for defining contaminat ed sediment “sites”, which are typically addressed by either the Department of Ecology’s Toxics Cleanup Program under the Model Toxics Control Act (see section belo w) 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 concer n" and not subject to cleanup actions (WAC 173-204-510(4)).Page 8 Bellingham Bay C ontSediments TMDL 11/06/01 • 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 stat e to gather available data on sediments and produce an inventory of sediment sampli ng stations which pass or fail applicable standards.

The goal of the Bellingham Bay Comprehensive Strategy is to carryou t 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 Imp act Zones for any sediment area or discharger, respectively.


## Model Toxics Control Act

The Model Toxics Control Act (MTCA) is the ad ministrative/implementation component of the Sediment Management Standards used to a ddress contaminated sediment remediation in Washington State. The state’s Water Polluti on 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 ach ieve cleanups through cooperative means with potentially liable parties (PLPs). Th erefore, the MTCA rules are designed to encourage PLPs to initiate clea nup actions, provide an open public process, and facilitate cooperative agreements rather than Ecology-initiated enforcement orders.

Negotiated agreements are one way in whic h 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 a nd 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 bi nding, administrative order issued by Ecology and agreed to by the PLP. Agreed orders are availabl e for remedial investigations, feasibility studies, and final cleanup actions. Both consent decrees and agreed orde rs 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 si tes. This informal consultation arrangement is non-binding for both the re sponsible 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 hea lth and the environment. The following is a description of the steps typi cally taken for the cleanup of contaminated sediment sites.DRAFT Bellingham Bay Contaminated Sediments TMDL Page 9 11/06/01 Screening and Evaluation of Contaminated Sites under MTCA

1. Sediment quality standards inventory (WAC 173-204-350) is an id entification process that screens all sediment station clusters. A cl uster 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 st andards of this secti on. Station clusters of potential concern are further evaluated using the hazard assessment standards of WAC 173- 204-530. Station clusters of low concern rema in 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 a nd 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 th e 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 informa tion 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 cl eanup 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 ar eal extent of sediments requiring remediation. Next, factors affecting the net environmental bene fit, 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 SQ S value and the higher minimum cleanup level (MCUL) standard.

7. Selection of cleanup action - based on the RI/FS, a cleanup act ion plan is developed. The plan identifies a preferred cl eanup alternative and specifies cleanup standards at the site.

8. Site cleanup - actual cleanup begins when, followi ng 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 envi ronmental monitoring to assure continued compliance with standards.

9. Delisting - a sediment site can be taken off th e 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 syst em of grids throughout Puget Sound to identify water quality impaired areas. In 1996, Ecology’s Sediment Management Unit identifiedPage 10 Bellingham Bay C ontSediments TMDL 11/06/01 contaminated sediment sites throughout Puget Sound in the Sediment Management Standards Contaminated Site List (Ecology, 1996). The 1998 303(d) list for the St ate of Washington then identifies the impaired sediment areas in the C ontaminated 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 intende d to identify areas of potential contamination (station clusters of concern). These data may not be comprehensive in nature and therefore, confirmation of contam ination 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 clea n, 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 confir med as being contaminated, and the site boundaries establis hed, 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 contam inated site is not considered contaminated under SMS. There may, however, be individual data points that exceed SMS numeric and/or bioassay contaminati on criteria within a listed grid area. If these data points are not contiguous with a minimum of 2 other data poi nts that also exceed SMS contaminant criteria, these non-contiguous, individual data points do not co nstitute a station clus ter. These occasional data outliers are therefor e not considered in exceedance of SMS numeric and/or bioassay criteria and are not targeted for cleanu p. Ecology examines the whole brea dth of available data at each station to define areas of contamination. Fi gure 2 (next page) provides an illustration of contaminated sites within the struct ure of the 303(d) water grid system.DRAFT Bellingham Bay Contaminated Sediments TMDL Page 11 11/06/01 Figure 2- Generic depiction of a 303(d) lis ted grid cell and sedime nt contaminated sites.Page 12 Bellingham Bay C ontSediments TMDL 11/06/01DRAFT Bellingham Bay Contaminated Sediments TMDL Page 13 11/06/01 

# 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 H5D1 2 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 C ontSediments TMDL 11/06/01 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 site s 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. Theref ore, water grid cell numbers H4F9, H4D9, and H5D0 have been added and addressed in this TM DL. These additions include impaired sediment areas adjacent to Cornwall Avenue Landfill and St arr 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 addi tional grid cells and parameters are subject to the cleanup and monitoring activiti es 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 name 1 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 H4F9 2 Whatcom and I&J Waterways no (same as Whatcom Waterway) H4E9 Whatcom Waterway 3 yes H5E0 4 Whatcom Waterway no (same as Whatcom Waterway) H5D1 G-P Outfall yes H5D0 5 Whatcom Waterway (Starr Rock) no (same as Whatcom Waterway) H4D9 5 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 gi rd 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 Whatco m 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 physi cal location of each grid cell is illustrated in Figure 3. In the following and subs equent analysis, I&J Waterway is dealt with separately from Whatcom Waterway. The parameters of con cern and cleanup boundaries are distinct between the two areas and are treated accordingly.

Water grid cells # H4F9, H4E8, H4E 9, H4D9, H5D0, H5E0- Whatcom WaterwayDRAFT Bellingham Bay Contaminated Sediments TMDL Page 15 11/06/01 Sediment Parameters: 2,4-Dimethylphenol, 2-Me thylnaphthalene, Acenapthene, Anthracene, Arsenic, Benz(a)anthracene, Benzo(a) pyrene, Benzo(b,k)fluoranthenes, Bis(2- ethylhexyl)phthalate, Chrysene, Copper, Dibe nz(a,h)anthracene, Dibenzofuran, Fluoranthene, Fluorene, Indeno(1,2,3-cd)pyrene, Mercury, Pentach lorophenol, 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 (A nchor 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 de bris to exceed a derived standa rd 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-methylnapht halene, acenapthene, anthracene, arsenic, benz(a)anthracene, benzo(a)pyrene, benzo(b.k)fluor anthenes, benzo(ghi)perylene, bis(2-ethylhexyl)phthalate, chrysene, copper, dibenz(a,h)anthracene, di benzofuran, fluoranthene, fluorene, indeno(1,2,3- cd)pyrene, pentachlorophenol, phena nthrene, 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 ne xt 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, a ll confirmatory biological testing data demonstrate compliance with the state SQS biologi cal 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 Waterw ay therefore demonstrates compliance with SQS criteria. The recent sampling data are sufficien t 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.Page 16 Bellingham Bay C ontSediments TMDL 11/06/01 Water grid cell # H5D1- Georgia Pacific Outfall Sediment parameters: mercury. Mercury was the sediment parameter original res ponsible for listing this gr id cell on the state’s 303(d) list. However, surface sediment sampli ng at the G-P Outfall (Anchor Environmental, 2000A) demonstrates that a mercury sediment cleanup site no longer ex ists 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 identifie d 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. Th e investigation revealed that the nearshore sediments are composed mostly of solid waste debr is 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 Shi pyard are being addressed in the RI/FS work conducted by the Port of Bellingham. Sampli ng data and planned cl eanup 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 pa rameters will be proposed for de-listing in the next cycle, while some will be addressed di rectly through the TMDL process (e.g., mercury, phenol, 4-methylphenol, sediment bioassay, and wood debris in Whatcom Waterway).DRAFT Bellingham Bay Contaminated Sediments TMDL Page 17 11/06/01 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 parame ter 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 C ontSediments TMDL 11/06/01DRAFT Bellingham Bay Contaminated Sediments TMDL Page 19 11/06/01 

# 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 samp ling results (Anchor Environmental, 2000A).

Sediment Quality Of the more than 50 chemicals analyzed, only th ree 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 identifi ed in the Whatcom Waterway area, and were often correlated with elevated pheno l and 4-methylphenol concentrations.

Surface concentrations of mercury, 4-methyl phenol, and wood material in the Whatcom Waterway area were significantly lower than con centrations detected several feet below the mudline. These patterns corres pond to decreasing surface sediment concentrations over the past 25 years, due to source controls implemented at th e G-P facility and in ot her areas of Bellingham Bay beginning in the early 1970’s. This process of na tural 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 t oxicity predicted on the basis of sediment chemical concentrations. The Sedi ment Management Standards utilize biological effects criteria to confirm the presence or ab sence 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 di d not exceed the SQS minor biological effect criteria. The remaining 40 percent of the lo cations exceeded SQS mi nor adverse biological effects criteria. Sediment toxicity was not corre lated with the concentra tion 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 t hough underlying subsurface sediments within the channel contained some of the highest concentrati ons of the contaminants of concern at the site. These data confirm the protectiven ess 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, bioaccumulati on 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 regionalPage 20 Bellingham Bay C ontSediments TMDL 11/06/01 background levels. However, even the maximum ti ssue concentrations reported in this area are below conservative benchmark concentrations calc ulated to protect trib al fishers and sensitive wildlife that may consume relatively large amounts of seafood (Anchor Environmental/Hart Crowser, 2000).

In order to address the potential for locali zed 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 concentrati ons and surface sediment concentrations within the sampled species’ home range. Using screen ing-level risk assessment methods approved by Ecology, a conservative tissue benc hmark 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 th is health-based screening level generally corresponded to those areas of th e site also targeted for clea nup to address sediment toxicity

concerns.


## Contaminated Sediment Evaluation

The contaminated sediment evaluation shall be presented using the project components consistent with the Bellingham Bay Demonstr ation Pilot Project. The known contaminated sediment sites and potential contaminant sour ces are given in Figure 4. The contaminated sediment components addressed in this TMDL are those listed on th e 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 sa mpling 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 th e footprints addressed by the re mediation 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. Consequentl y, some sites correspond with more than one 303(d) grid cell and, likewise, some grid cells identify more than one c ontaminated 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 numer ical 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 pr oject 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 designat ed 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 analys is. Figure 6 describes the sediment mercuryDRAFT Bellingham Bay Contaminated Sediments TMDL Page 21 11/06/01 chemical concentrations in the Whatcom Wate rway area. Figure 7 presents the sediment bioassay results, while Figure 8 pr ovides the results of the bi oaccumulation screening level analysis. The contaminant footprint for mercur y encompasses the areas violating SQS criteria for phenol and 4-methylphenol. The union of th e areas encompassing the SQS biological effects criteria failures and the areas with concentratio ns greater than the bioaccumulation screening level constitute the total area slat ed 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 identifie d as a 303(d)-listed contaminated sediment site in Bellingham Bay due to levels of mercury above the clea nup 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) utiliza tion of the WASP model with current data for far-field analysis. More details on the modeling effort are availa ble in Whatcom Waterway Final RI/FS (Anchor Environmental/Hart Crowser, 2000). The modeli ng process predicts th e current G-P Outfall discharge will not cause mercury sediment c ontamination to SQS levels in Bellingham Bay. Furthermore, the dynamic model showed that ex isting sediments within the immediate outfall area were predicted to recover to below the merc ury 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 addi tion, 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 vici nity of the G-P outfall. Biological confirmatory tests were run on the samples from the three highes t-concentration stations in the station cluster. All biological tests passed SQS biological screening criteria. Therefore, the confirmatory biological testing procedures unde r SMS do not qualify this stat ion cluster as a contaminated sediment site and demonstrates compliance with the Sediment Management Standards SQS criteria through the principal of biological ove rride (Appendix A-4) (Anchor Environmental, 2000A). This has not been identified as a tr end 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 wa ste and 4-methylphenol distribution will be confirmed by further monitoring of the G-P disc harge and receiving water sediments under their current NPDES permit. In addition, since G-P ha s closed their chlor-alkali facility and ceased the pulping operations at the plan t, the contaminant discharge ra te associated with current discharge to the cluster area is not likely to result in a cleanup site in the future.Page 22 Bellingham Bay C ontSediments TMDL 11/06/01 Grid Cell Number H5C1- Harris Avenue Shipyard An expanded site investigation has been comp leted 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 investiga tion and determined the landfill is actively eroding into Bellingham Bay. Th e investigation revealed that the nearshore sediments are composed mostly of solid waste debr is 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 bei ng delivered to Bellingham Bay in quantities significant enough to cause violation of state Sedi ment 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 m odel. The models were used to perform mass balance and mass transfer calculat ions for contaminants in the water column and sediments. The models incorporate mixing and chemical partiti oning phenomena and include local currents, tidal dispersion, sedimentation and resuspension. A de tailed discussion can be found in Chapter 8 of Anchor Environmental/Hart Crowser, 2000.

This modeling work provides the primary tool us ed in this TMDL to define the Waste Load Allocation for the Georgia Pacific facility.

The second modeling effort was designed as a sc reening and evaluation tool for other potential ongoing sources in Bellingham Bay in order to identify, plan, and prio ritize source control activities. In this analysis, sediment concen trations 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 meas ured flows and maximum concentrations from each source and the gross sedimentation rate measured in Inner Bellingham Bay. Local background concentrations of chem icals 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 an alysis is provided in Appendix A-6.

This analysis predicts that sediment quality im pairment or recontamination from existing sources is relatively localized near a potential sour ce 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 exceed ing the SQS criteria.DRAFT Bellingham Bay Contaminated Sediments TMDL Page 23 11/06/01 Although the areal extent of poten tial recontamination is small, source control concerns are carried forward in the cleanup process and th rough 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 qua lity 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 pot ential near-field wate r quality concerns were compiled and evaluated. This evaluation f ound no specific ongoing discharge sources for mercury, phenol, 4-mehtylphenol, wood debris , or other sediment contaminants.

Table 5 below provides a tabular summary discussi on on the facilities that have a direct release to Inner Bellingham Bay. The details of the di scharge sources by each grid cell location is presented in Appendix A-7. The detailed discu ssion 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 C ontSediments TMDL 11/06/01 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 bein g 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 CS O 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 over seeing 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 sa mples 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 co llected 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 seep age and erosion is occurring through emergency actions. The source control and cleanup work are being addressed under Ecology’s Voluntary Cleanup Program.DRAFT Bellingham Bay Contaminated Sediments TMDL Page 25 11/06/01 

# Loading Capacity

Identification of the loading capacity is an impor tant step in developing TMDLs. The loading capacity is the amount of pollutant a wate r 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 th at is assigned to a particular source. EPA defines the loading capacity as "the greatest am ount of loading that a wa ter 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) lis tings. Cleanup activities and source control to prevent sediment recontamination will be impl emented to achieve compliance with the state Sediment Management Standards with the goal of maintaining sediment quality that satisfies SQS criteria.

The loading capacity throughout I nner 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 act ivities and setting load and/or wasteload allocations for sources, where necessary, to achieve SMS compliance.

For many 303(d) listed parameters in Bellingha m Bay, natural attenuat ion and recent source control activities has resulted in compliance w ith 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 parame ters 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-met hylphenol, 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. Futu re recontamination from these parameters have not been identified as a potential from ongoing sources in Inner Bellingham Bay. The loading capacity is therefor e designed as the mass loading that maintains compliance with the state Sediment Qualit y Standards Criteria for mercury, phenol, 4- methylphenol, sediment bioassay, and wood debris (mercury: 1.2 mg/kg; phenol: 420 μ g/kg; 4- methylphenol: 670 μ g/kg; wood debris: <50% by volume; sedi ment 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 histori cal contaminant loading responsible for the 303(d) listing. On-going imp acts to sediments are controlled through source control activities, namely, upland isolation a nd remediation. Current sources of sediment contamination have not been identified in the bay. All activities are designed to providePage 26 Bellingham Bay C ontSediments TMDL 11/06/01 assurance against recontamination and to ma intain compliance with the state Sediment Management Standards with the goal of maintain ing sediment quality that satisfies SQS criteria.

Appendix A-8 provides more detail on the loading ca pacity 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 MercuryDRAFT Bellingham Bay Contaminated Sediments TMDL Page 27 11/06/01 

# Load and Waste Load Allocations

The objective of the Bellingham Bay Contaminat ed 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 c ontaminated sediments, and the “W aste Load Allocation” (WLA) or “Load Allocation” (LA) to each existing point or nonpoint source, respectively. There are no non-point discharge sources in Be llingham Bay, therefore, no load allocations apply. Historic sediment contamination is the reason for the se diment quality impairment and subsequent 303(d) listing in Inner Bellingham Bay. The Load Re duction is achieved through the implementation of the cleanup strategies that will bring all area s of the Bay in compliance with the Sediment Management Standards. The Wasteload for e ach source is the require d 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 concen tration 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 Bellingha m Bay. One point source that requires a Waste Load Allocation is the G-P out fall. 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 merc ury 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 load ing for the model input was derived from the actual sampling record 1995 to 1997 tr eating all non-detect values as at the detection limit of 0.2
μ g/L (The average mass loading using one-hal f 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 μ g/L.

The current average permit limit of 0.03 lbs/da y (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 discha rge 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 perm its 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 Ma nagement Standards. No ongoing sources havePage 28 Bellingham Bay C ontSediments TMDL 11/06/01 been documented as currently contributing to the sediment quality impairments in Inner Bellingham Bay. Therefore, wasteload Allocati ons are not necessarily required for the remaining discharging sources. Where the discharge from any fa cility 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, Ec ology 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 fo r 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 establis hed for the 303(d) listed parameters. The previous impact to sediments from this source have been effectively c ontrolled to result in no discharge of contaminants to criteria levels.

Grid Cells numbers H4F9, H4E8, H4E 9, H4D9, H5D0, H5E0- Whatcom Waterway

• Bellingham Marine Industr ies- 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 histor ical deposits of woody debris and not to CSO discharges. Nonethele ss, the WLA for this source is the discharge level that does not exceed a level of 670 μ g/kg for 4-methylphenol and 420 μ g/kg for phenol in receiving water sediments.

• Boulevard Park- WLAs are not establis hed 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 sediment s from this source is effectively controlled to result in no discharge of contamin ants adversely affecting sediments.

Grid Cell Number H5C1- Harris Avenue Shipyard Discharge sources from the shipyard are curren tly effectively controlled through NPDES Permit No. WA-003134-8 (Ecology, 1994. Harris Avenue Shipyard was formerly known as “Maritime Contractors, Inc.”). The current stormwater di scharges from this facility have not been documented to result in levels that cause ex ceedances of SQS levels for the 303(d) listed parameters. Under the next NPDES permit, Ecology plans to requir e the collection and treatment of all industrial stormwater prior to discharge to the sanita ry 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 Trea tment Plant for the discharge to the sanitary sewer. Limitations for the san itary sewer discharge are currently established for copper, lead, zinc, and arsenic. After the faci lity 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.DRAFT Bellingham Bay Contaminated Sediments TMDL Page 29 11/06/01 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 w ill 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 activ ities under MTCA.

Narrative effluent limitations may be used in NP DES 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 writte n EPA policy (EPA, 1996). Furthermore, the Sediment Quality Standards provi de 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, additiona l source investigation and cont rol 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 prev ention 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 th e control activities achieve the expected load reductions to maintain compliance with the Se diment 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 indi vidual cleanup and source control strategies in Bellingham Bay.

Sediment monitoring in Bellingham Bay is designe d to: 1) measure contaminants in the surface sediments where they exists; 2) evaluate the effectiveness of c ontrol actions (e.g. sediment and upland remediation, stormwater BMPs, etc.); and 3) determine the need for additional pollutant controls through a process of adaptive manage ment. More details on the monitoring approach are given below under “Summary Implementation Strategy”.Page 30 Bellingham Bay C ontSediments TMDL 11/06/01DRAFT Bellingham Bay Contaminated Sediments TMDL Page 31 11/06/01 

# 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 marg in of safety as required by the statute.

In most cases for this TMDL, the margin of safety is not strictly calculate d or allocated. Rather, the margin of safety is implicit due to the conservative assu mptions 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 con centrations in recontamination modeling analyses for potential sources;

• Using high seafood consumption rates and assumi ng 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-detectab le data to be at the full detection value;

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

- Conservative dispersion coeffici ents 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 NP DES 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 C ontSediments TMDL 11/06/01DRAFT Bellingham Bay Contaminated Sediments TMDL Page 33 11/06/01 

# Summary Implementation Strategy

Overview
The Bellingham Bay Demonstration Pilot Work Gr oup was established to address the need for sediment cleanup and to expedite remedial ac tions. 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 a nd associated habitat re storation in Bellingham Bay. The Pilot Work Group developed a Comprehe nsive Strategy that considered contaminated sediments, sources of pollution, habitat restor ation, and land-use from a baywide perspective.

The Bellingham Bay Comprehensive Strategy deve loped by the Pilot Work Group includes the cleanup actions and source controls measures th at comprise the TMDL implementation strategy. An Environmental Impact Statement (EIS) was pr epared to describe the approach and evaluate the potential environmental impacts of implem enting 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 ch allenge of coordinati ng navigation needs with contaminated sediment and habitat management issues in Bellingham Bay. The participants involved in the Pilo t 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 ca rry out the day-to-day management of the project. In the Comprehensive Strategy, the P ilot 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 Compre hensive Strategy include all the 303(d) listed areas of Inner Bellingham Ba y. The cleanup and source control activities associated with a particular priority site ar e conducted by the individual parties responsible for the contamination. The Department of Ecol ogy oversees, regulates and enforces the cleanup processes through the authority under the Model Toxics Contro l Act (Chapter 173-340 WAC).

The approaches used to meet the load allo cations include the sedi ment cleanup projects, associated source control activities, and NPDES permits, where appropriate. The success of thePage 34 Bellingham Bay C ontSediments TMDL 11/06/01 TMDL implementation will be assessed through m eeting milestone dates for cleanup as well as through monitoring plans.



## Implementation Activities
Implementation activities planne d as part of the remediati on and source control process in Bellingham Bay will attain compliance with Sediment Management Standards. Based on monitoring and evaluation, adaptive management pr inciples will be used to track and target future activities in the Bay to assure comp liance 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 Ecol ogy, has conducted an RI/FS in accordance with a MTCA Agreed Order. The Whatcom Waterw ay 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 a ddition, 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 ra nge of potential near-term remedial action alternatives th at 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 treatm ent, removal, and in-water containment of contaminated sediment to meet the SQS crite ria throughout the Whatcom Waterway site. In areas where containment through capping is pr oposed as the remedial action, clean capping material would meet or exceed standards fo r quality established by the Puget Sound Dredged Disposal Analysis (PSDDA) program. The PSDDA process created the Dredged Material Management Program (DMMP) to manage dredge d material activities. This includes the development of evaluation procedures to charact erize the suitability of sediments for disposal and capping. The DMMP provides screening le vel (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 Sedime nt Management Standards, and represent concentrations below which adverse biological effects are considered to be unlikely.

Ecology expects that the actual cleanup of th e 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 addi tional source control and cleanup actions to ensure that sediments within the Log Pond remain below SQS chemical criteria following theDRAFT Bellingham Bay Contaminated Sediments TMDL Page 35 11/06/01 cleanup action under MTCA.

- R.G. Haley Soil and groundwater at this upland contam inated site contain concentrations of pentachlorophenol and PAHs that exceed wate r quality and sediment protection criteria, respectively. Groundwater seeps from the s ite 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 Be llingham 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 s how 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 unde r 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 stormwat er 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 stormwat er program review and approval process, source control activities and poten tial 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 Di scharge Permit (ST7304) for the discharge of screened seafood processing wastewater to the Bellingham Post Point WWTP. They have a Baseline General Permit for Industrial Stor mwater (SO3-000679). The Washington State Department of Ecology administers both pe rmits. Although, Bornstein Seafoods is not identified as an ongoing source of contaminated sediments, water quality investigations will be conducted as part of Ecology’s perm it management activities and the TMDL implementation.

Upland Remediation

- Roeder Avenue Landfill The Port of Bellingham is currently conducti ng 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 efflue nt limitations for mercury, a mercuryPage 36 Bellingham Bay C ontSediments TMDL 11/06/01 source evaluation sampling plan, as well as se diment 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 se diment 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 th e closure of the chlor-alkali facility. The NPDES permit will also require G-P to evalua te 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, a nd 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 co mplete 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 shi pyard operations is designed to control shipyard activities to prevent sediment recontamination. The sediment contamination in the Bay is due to historic releases, a nd the current discharge from the shipyard does not pose a threat to sediment recontamination. The shipyard is inspected regularly by Ec ology. 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 Sh ipyard in the winter of 2002. Conditions and monitoring requirements for stormwater and sedi ment 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 th e City of Bellingham and Washington State DNR has completed a Remedial Investigation and Fe asibility Study (Landau, 2000) of this site under Ecology’s Voluntary Cleanup Program. In add ition, the Cornwall Avenue Landfill site is identified as a high-priority in the Bellingham Bay Comprehensive Strategy EIS. The RI/FS andDRAFT Bellingham Bay Contaminated Sediments TMDL Page 37 11/06/01 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 stat e’s Sediment Management Standards.

Bay-wide Activities

As part of developing the Bellingham Bay Co mprehensive Strategy, all potential sources discharging to Bellingham Bay have gone th rough a multiphase process of evaluation for sediment recontamination potential. In th is process, the eval uation tools included:

• Sediment quality screening and characteri zation 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 r econtamination after the cleanup process is complete;

• Source control evaluation based on the reco ntamination potential for each source.

The source control evaluation utilized a tiered approach by placing each potential source in one of three categories. The cate gories 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 recontaminat e – these sources will be contro lled 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 te rm monitoring program consistent with SIZ requirements will be put in place.

The source control categories will be implem ented on a case-by-case basis for all ground and surface water sources in the Bay through upland re medial 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 Gene ral Permit and Comprehensive Stormwater Program The technical studies developed as part of th e 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 c ity 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 C ontSediments TMDL 11/06/01 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 activi ties, and a comprehensive plan. After review of the program, Ecology recommended that the city concentr ate on improvements in following two areas: 1) coordinate the stormwater program with the pl anned 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 exis ting 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 ne w 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 citi zens, businesses, and industries 5. Adoption of comprehensive land use plans 6. Identification and ranking of significant pollutant sources 7. Investigation and correcti on of illicit discharges into stormwater systems 8. Programs for the proper O&M of stormwat er 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 stor mwater 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 requir ements 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 st ormwater 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 monitori ng and source control act ivities aligned with MTCA monitoring and source control requireme nts for the various cleanup sites in Inner Bellingham Bay.DRAFT Bellingham Bay Contaminated Sediments TMDL Page 39 11/06/01 Specifically, to minimize the potential for se diment 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 discha rges 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. Th is may include BMPs such as: increased frequency of catch basin cleaning; system ma intenance; catch basin sediment monitoring; and other activities that affect the quality of receiving water sediments.

3. Develop a sediment sampling and analysis pl an for these or selected representative outfalls within 12 months after the issuan ce of the NPDES Phase 2 stormwater permit. This shall include the outfall identificati on 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 sour ces are identified as having an impact on local sediments in the receiving water, the complia nce 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 De partment of Ecology’s Puget Sound Stormwater Technical Manual for all development and rede velopment activities in the Harbor. The Stormwater Master Plan includes a series of pollution prevention oper ational and structural BMPs and treatment alternatives to reduce or el iminate adverse impacts from Port activities on stormwater and receiving waters. The planne d 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 Ba y. One general permit is for the Bellingham Airport. The Port also has coverage for th e maintenance shop near the shipping terminal on Whatcom Waterway and for the Alaska ferry term inal in Fairhaven. Data for these facilities covered under the general permit does not show th ey 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 Inne r Bellingham Bay identifie d as likely to cause sediment contamination. Noneth eless, 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 th rough agreements or requirements made underPage 40 Bellingham Bay C ontSediments TMDL 11/06/01 MTCA and/or the City of Bellingham NPDES st ormwater 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. Meeti ng 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 th e Bellingham Bay Demonstration P ilot 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 pe riod 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 ope n 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 th e life of the project. Examples include briefings to the city counc il, 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 activit ies will be conducted as part of implementing the Bellingham Bay Comprehensive Strategy. In addition, for ea ch individual cleanup site, Ecology will prepare draft orders or decrees, and associated draft cleanup action pl ans for public review. The public review periods are typically 30 days, and Ec ology will likely conduct a public meeting for each site.

Public review is also a requ ired under the NPDES program. Es tablished 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 11/06/01 Future public involvement activit ies will include reference to th e contaminated sediment TMDL for Bellingham Bay. A public meeting specifically addressing this TMDL will be conducted independently or in conjunction with othe r Bellingham Bay public outreach efforts.



## Monitoring Strategy
Discharge and sediment monitoring will asse ss 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 Acti on Plan (CAP) is developed that contains provisions for monitoring. The implementa tion of an Ecology-approved CAP, including monitoring, is mandated through a consent decree. In the CAP development process, Ecology determines the sediment monitoring schedule, fr equency, parameters, and locations, as well as source monitoring, and additional site specific m onitoring 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-t erm compliance with the state’s Sediment Management Standards. Ecology will us e 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 Ba y will be reviewed for consistency with this TMDL upon re-issuance.



## Reasonable Assurance

Reasonable assurance is defined as a demonstra tion that the WLAs for point sources, or load reductions for historic sediment releases, derive d 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. Fo r load reductions, remediation activities are required to bring contaminated sediments into compliance with standards. The reasonable assurance standard requires th e procedures apply to the po llutants for which the TMDL is established, be implemented expeditious ly, and be supported by adequate funding.

The many activities related to implementation of the Belli ngham Bay Comprehensive Strategy and the issuance of NPDES permits provide the r easonable assurance that the requirements for this contaminated sediment TMDL will occur.

Cleanup Actions The contaminated sediment and upland cleanup si tes 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) ultim ately 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 sedime nt remediation cleanup site in the Bay is given above under “Cleanup sites”.Page 42 Bellingham Bay C ontSediments TMDL 11/06/01 The cleanup actions are coupled with monitori ng to assure the remedial actions have been adequately implemented and potential sources ade quately 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 th e 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 se diment monitoring and BMPs as appropriate.

Ecology also provides reasonable assurance for st ormwater impacts through the oversight of the City’s stormwater management program. Through linkage with the TMDL and long term monitoring efforts, Ecology can identify potenti al areas of concern and potential problem stormwater outfalls. Ecology can then oversee the city’s source control e fforts in problem areas. 

## Adaptive Management
“Adaptive management” is often defined as the re liance 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 logica lly requires focus on the elements with the greatest uncertainty or risks.

Sediment cleanup techniques have been wi dely used and proven successful at many contaminated sediment cleanup sites. Potentia l sources of sediment contamination must be identified in conjunction with cl eanup projects. However, the vari ability 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 cha nge 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 ye ars, Ecology examines all the TMDLs in the Nooksak basin to assess the eff ectiveness of management activit ies 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 Mode l Toxics Control Act and the NPDES programs. 

## Funding Sources
At each cleanup site, the liable pa rties are responsible to fund the remediation activities required to bring their respective sites into full complia nce with the Sediment Management Standards. Where responsible parties do no t fully fund remediation activit ies the Department of Ecology maintains the legal authority to carry out reme diation activities and s ubsequently recover the cleanup costs from liable parties.DRAFT Bellingham Bay Contaminated Sediments TMDL Page 43 11/06/01 NPDES permit holders are required to fund the activitie s necessary to maintain compliance with their respective permits and state water quality regulations.Page 44 Bellingham Bay C ontSediments TMDL 11/06/01DRAFT Bellingham Bay Contaminated Sediments TMDL Page 45 11/06/01 

# References Cited

Anchor Environmental, 1999. Bellingham Bay Dem onstration 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, Be llingham 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. Squa licum Harbor, Port of Bellingham Draft Stormwater Management Master Plan. April 2000. Ecology, 1994. Maritime Contractors, Incorpor ated, 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 Dredge d Material Management Programs and the Sediment Management Standar ds (SMS) Cleanup Program. September 1997. Landau, 2000. Final Report, Focused RI/FS, Cornwa ll Avenue Landfill, Bellingham, Washington. Prepared by Landau Associates, Inc. for the Po rt 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 Ba sin Source Tracing Study, Phase 1 Technical Memorandum. February 1994. U.S. Environmental Protection Agency, 1991. Gu idance 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 C ontSediments TMDL 11/06/01Bellingham 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 sedime nt 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 LevelPage Figure- 2 Bellingham Bay ContSediments T MDL 11/06/01Bellingham Bay Contaminated Sediments TMDL Page Figure 3 11/06/01 Figure 1: Bellingham Bay Vicinity MapPage Figure- 4 Bellingham Bay ContSediments T MDL 11/06/01Bellingham Bay Contaminated Sediments TMDL Page Figure 5 11/06/01 

## Figure 4Page Figure-6Bellingham Bay ContSediments TMDL11/06/01Figure 5Bellingham Bay Contaminated Sediments TMDL Page Figure-711/06/01Figure 6Page Figure-8Bellingham Bay ContSediments TMDL11/06/01Figure 7Bellingham Bay Contaminated Sediments TMDL Page Figure-911/06/01Figure 8Page Figure-10Bellingham Bay ContSediments TMDL11/06/01Bellingham 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 Sedi ment 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, Se ptember 1999 Sediment Sampling Results

A-6: Estimated Maximum Impact/Mixing Zone s 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), Bi oaccumulation Trigger (BT) and Maximum Level (ML) Guideline Chemistry Values (Dry Weight Normalized)Page A- 2 Bellingham Bay ContSe diments TMDL 11/06/01Bellingham 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 Clea nup 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 29Page A- 4 Bellingham Bay ContSe diments TMDL 11/06/01 PENTACHLOROPHENOL 360 690 BENZYL ALCOHOL 57 73 BENZOIC ACID 650 650Bellingham 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 TMDLPage A- 6 Bellingham Bay ContSe diments 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 TMDLBellingham 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 Dibe nz(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 YesPage A- 8 Bellingham Bay ContSe diments TMDL 11/06/01 Whatcom WW 48122H5E0 48.745 122.505 Mercury No YesBellingham Bay Contaminated Sediments TMDL Page A- 9 11/06/01 Appendix A-4

I&J Waterway Chemical and Bi ological 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 sta tions can be found in Anchor Environmental/Hart Crowser, 1999, Appendices B and L. Data qualifiers “U” means the analyte was not detect ed 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 ContSe diments TMDL 11/06/01 Appendix A-5

Georgia Pacific Outfall, Septemb er 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-1111/06/01Appendix A-6Estimated Maximum Impact/Mixing Zones near Identified Sources of Potential Sediment Quality Concern in Bellingham BayWater Quality Sediment QualityIdentified SourceParameters ofPotential ConcernMax MeasuredConcentration(ug/L)WaterQualityCriterion(ug/L)MeasuredPeak Flow(m3/sec)Estimated MaxImpact/Mix ZoneRadius(feet)MeasuredPeak Flow(m3/sec)SuspendedSedimentConc.(mg/L)AveParticulateConc, (mg/kgdry wt)SedimentQuality Std.(mg/kg drywt)Est. MaxImpact/MixZone Radius(feet)Bellingham MarineDissolved Copper 6.7 2.5 0.0003< 10.0001 - - --Stormwater Runoff Total Copper 1,100 - --0.0001 290 - 39030Total Mercury 0.2 0.025 0.0003< 10.0001 290 - 0.4120Bornstein SeafoodsTotal Arsenic 350 36 0.000320.0001 - - 5740Area Drainage Outfall Diss/Tot Cadmium 32 8 0.0003< 10.0001 - - 5.140Diss/Tot Copper 1,600 2.5 0.0003300.0001 - - 39030Diss/Tot Silver 28 1.2 0.0003100.0001 - - 6.140Diss/Tot Zinc 830 77 0.000320.0001 - - 41020"C' Street OutfallDissolved Copper 34 2.5 0.05070.029 - - --City Stormwater and CSO Particulate Phenol 0.02 - 0.050-0.029 38 0.66 0.4270Particulate 4-Methylphenol0.08 - 0.050-0.029 38 2.0 0.67100Cornwall LandfillDissolved Copper 12 2.5 0.00210.002 - - 39010Seepage and Dissolved Lead 9.9 5.8 0.002< 10.002 - - 45010Shoreline Erosion Fec. Colif. (#/100ml)230 14 0.00210.002 - - --Solid Waste - - N/A-N/A - - 50% by vol.?(c)G-P Log Pond(groundwater)Total Mercury 9.4 0.025 0.00004100.00004 - - 0.4160G-P OutfallParticulate Mercury 0.29 0.025 1.6101.6 96 3.0 0.410(d)(wastewater) (historic releases)Page A-12Bellingham Bay ContSediments TMDL11/06/01Appendix A-6 (continued)Estimated Maximum Impact/Mixing Zones near Identified Sources of Potential Sediment Quality Concern in Bellingham BayWater Quality Sediment QualityIdentified SourceParameters ofPotential ConcernMax MeasuredConcentration(ug/L)WaterQualityCriterion(ug/L)MeasuredPeak Flow(m3/sec)Estimated MaxImpact/Mix ZoneRadius(feet)MeasuredPeak Flow(m3/sec)SuspendedSedimentConc.(mg/L)AveParticulateConc, (mg/kgdry wt)SedimentQuality Std.(mg/kg drywt)Est. MaxImpact/MixZone Radius(feet)Harris Ave. ShipyardSource control within this areais being addressed as part of the ongoing Harris Avenue Shipyard Site independent MTCA actionR.G. HaleyDissolved Copper 33 2.5 0.03080.019 - - --City Stormwater Runoff Particulate Phenol 0.02 - 0.030-0.019 32 0.66 0.4250Particulate 4-Methylphenol0.06 - 0.030-0.019 32 2.0 0.6780Roeder Avenue LandfillSource control within this areais being addressed as part of the ongoing RoederAvenue Landfill Site independent MTCA actionAnchor 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 inform ation on point source, gr oundwater, and other nonpoint sources that may affect sediments or car ry potential near-field wa ter 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 Belli ngham Bay watershed is given in Table A-7.

Grid Cell Number H4F9- I&J Waterway

• Bornstein Seafoods . All process wastewater from this f acility is treated and discharged to the sanitary sewer. Stormwater runoff samp les collected from the site have contained concentrations of metals that exceeded wate r quality criteria (Anchor Environmental/Hart Crowser, 2000). However, a surface sediment samp le collected within th e vicinity of the site (HC-SS-45) did not exceed SQS chemical criteri a for metals. Bis(2-ethylhexyl) phthalate has been also detected in sediments near the Bornstein Seafoods out fall, 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 landfil l is located between Whatcom and I&J Waterways. Groundwater quality monitori ng performed at locations adjacent to the landfill detected levels of ch romium above marine water qua lity criteria migrating towards Bellingham Bay. However, surface sediment sample s 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 locali zed. Releases from the Roeder Avenue site are being addressed through an integrated upland cleanup and redevelopment plan. Ecology is overseeing the work under Ecol ogy’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 sa mple collected within the vicinity of the site (AN-SS-37) did not exceed SQ S 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 de tected in upland soil and groundwater and shoreline seepage may contain similar or lo wer 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 implem ented to ensure that sediments within the Log Pond remain below SQS chemical criter ia following the cleanup action under MTCA.Page A- 14 Bellingham Bay ContSe diments 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 th at 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 w ithin 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 (Anc hor Environmental/Hart Crowse r, 2000). Localized biological toxicity and the accumulations of phenol and 4-methylphenol in nearshore sediments within the outfall area may be partly at tributable 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 out fall area will be remediated as part of the Whatcom Waterway remediation. Further anal ysis of source control for this outfall is discussed in the Summary Implem entation 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 Wh atcom Waterway are likely associated with historical practices (Anchor E nvironmental/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, co llection, and wastewater treatment processes, all of which are regulated unde r G-P’s existing NPDES permit.

• Boulevard Park. Subsurface soil and groundwater at this upland cleanup site contain elevated concentrations of metals, pe troleum hydrocarbons, and polynuclear aromatic hydrocarbons (PAHs) associated with histor ical manufactured gas production. However, surface sediment samples collect ed 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 detect ed in soil and groundwater at the former Chevron Bulk Fuels facility. However, su rface sediment samples collected within the vicinity of the site (AN-SS-36 and -37) di d not exceed SQS biological effects criteria. Independent remedial actions have been implem ented at the site, incl uding soil removal and operation of a subsurface product recovery a nd groundwater extracti on/treatment system.

• R.G. Haley. Soil and groundwater at this upland cont aminated site contain concentrations of pentachlorophenol, dioxins and PAHs that ex ceed cleanup criteria.. Groundwater seeps from the site to the Bay were recentl y discovered that might be adversely impacting sediments. In addition, wet and dry season stor mwater runoff samples collected from the site contained concentrations of copper that exceeded water quality criteria (Anchor Environmental/Hart Crowser, 2000). However, a surface sediment sa mple collected in the vicinity of the site (HC-SS-29) did not exceed SQS chemical crite ria 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 investig ation and cleanup of th e site will occur thatBellingham 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 confir med 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, incl uding the closure of th e 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 co mpounds. Historical re leases are responsible for sediment contamination. As discussed prev iously, the site cleanup and integrated source control actions are being addr essed as a component of the Near-term Remedial Action Alternatives in the Bellingham Bay Comprehe nsive 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 rec ontamination. At this facility, all process wastewater and wash water is collected and treat ed prior to discharge to the sanitary sewer. Furthermore, the facility is currently working with the Department of Ecology to develop plans to collect industrial stor mwater 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 seep age samples collected in this area have contained concentrations of metals and fecal coliform above the water quality criteria. Nearshore sediments in this area al so 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 b een an ongoing source of sediment contamination. Control of seepage and erosion releases is occurring th rough 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 dissol ved metals that exceed freshwater and marine ambient water quality criteria (Anchor Envi ronmental/Hart Crowser, 2000). The highest concentrations of metals including copper, le ad 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 toPage A- 16 Bellingham Bay ContSe diments TMDL 11/06/01 be the result of normal vehicle releases. Al though metal concentrations in stormwater runoff may exceed marine water quality criteria at the point of disc harge, no near-field adverse effects have been documented in water or sedi ment within the nears hore areas of Bellingham Bay.

In addition to metals in the water column, accu mulated particulate matter present within the City’s stormwater runoff con veyance 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 Be llingham Bay do not exceed SQS criteria as demonstrated by confirmatory bioassays (Anchor Environmental/Hart Crowser, 2000).

Moreover, the overall distri bution of phenol and 4-methylphe nol in Bellingham Bay, and particularly within Whatcom Waterway, are likel y associated with the historical deposits of woody debris and not due to stormwater disc harges. Both phenol and 4-methylphenol are known degradation products of natural w ood products and an accumulation of these compounds in regional sediments is frequently associated with woody debris deposits. Overall, the pattern of sedi ment phenol and 4-meth ylphenol 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 iden tify 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 sour ces as an on-going contri butor 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 cert ain industrial stormwater di scharges to Bellingham Bay under the Baseline Stormwater General Permit fo r Industrial Facilities. Urban stormwater runoff includes piped and ditched conveyance as well as sheet flow rel eases and is regulated through the Municipal stormwater permits. Be llingham 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 NPDE S stormwater program. The city’s stormwater program is discussed further in the Summary Implementation Strategy

.

h Atmospheric mercury. Part per trillion mercury anal ysis performed at the Whatcom Waterway site as part of the remedial inves tigation included water column, sediment trap and in situ sediment. Mercury concentr ations in the water column were far below WQ standards and conservative partitioning calcu lations indicate that the wa ter 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 Ecol ogy 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 Treatm ent Plant WA0023744C Municipal Brooks Manufacturing WA0030805B Industrial Stormwater Georgia-Pacific West WA000109-1 Industrial Wastewater Maritime Contractors/Harris Av enue 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 IndustrialPage A- 18 Bellingham Bay ContSe diments 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 curr ently exceeded from historic contamination or ongoing sources for any sediment quality parame ter. For this reason, all the parameters associated with the I&J Waterway should be rem oved from the 303(d) list in the next listing cycle.

Water grid cell # H5D1- Georgia Pacific Outfall Due to natural attenuation and recent source c ontrol 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 as signed to Georgia Pacific for discharges into Bellingham Bay to assure sediment standards fo r mercury are not violated in the future.

Water grid cells # H4F9, H4E8, H4E 9, H4D9, H5D0, H5E0- Whatcom Waterway For Whatcom Waterway, due to natural attenua tion and recent source co ntrol activities, the loading capacity (meeting SMS) is not curren tly exceeded from historic contamination or ongoing sources for 2,4-dimethylphenol, 2-methylna phthalene, acenapthene, anthracene, arsenic, benz(a)anthracene, benzo(a)pyrene, benzo(b.k) fluoranthenes, benzo(ghi)perylene, bis(2- ethylhexyl)phthalate, chrysene, copper, dibe nz(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, phe nol, 4-methylphenol, sediment bioassay, and wood debris. The sediment cleanup will remediate the historical contaminant loadings that were responsible for the 303(d) lis ting. Recontamination from mercury, phenol, 4-methylphenol, biotoxicity, and wood debris have not been id entified as a potentia l from ongoing sources in Inner Bellingham Bay. Source control and monito ring activities will nonet heless be designed to provide assurance against recontamination and maintain compliance with the state Sediment Management Standards with the goal of maintain ing 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 Criteri a 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 μ g/kg; 4-methylphenol: 670 μ g/kg; wood debris: <50% by volume; sediment bioassay: “no adverse effects on biological reso urces”. The mass loading from any source or combination of sources is no t to exceed these criteria.

Water grid cell # H4D9 - Cornwall Avenue Landfill Sediment cleanup is designed to remediate the hist orical 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 disc harge 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 thre at 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 ba sed on analysis of data used in the development of the Bellingham Bay TMDL.Page A- 20 Bellingham Bay ContSe diments TMDL 11/06/01 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

ORGANOMETALLI C 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 230Bellingham 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 ca rbon-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)pyre ne, 1,4-dichlorobenzene and N-nitrosodiphenylamine. (5) See Testing, Reporting, and Evaluation of Tri butyltin Data in PSSDA and SMS Programs at http://www.nws.usace.army.mil/dmmo/8tharm/tbt96.htm (6) This value is normalized to to tal organic carbon, and is expre ssed in mg/kg (TOC normalizedPage A- 22 Bellingham Bay ContSe diments TMDL 11/06/01Bellingham Bay Contaminated Sediments TMDL Page B- 1 11/06/01 

# Appendix B- Public Participation MaterialsPage B- 2 Bellingham Bay ContS ediments TMDL 11/06/01Bellingham Bay Contaminated Sediments TMDL Page B- 3 11/06/01 

# 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 u sed 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 Nook sack 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 nu merous marine mammals and waterfowl. Bellingham Bay is also an essential feature of navigation, wa ter-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 substa nces present in Bellingham Bay sediments that failed environmental standards. From cleanup and pollutio n 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. Howe ver, ongoing sampling shows that remaining sediment contaminants of concern are within three Belli ngham 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 ve hicle-use and maintenance activities produce heavy metal by-products.

June 2001Page B- 4 Bellingham Bay ContS ediments TMDL 11/06/01 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 maximu m 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 Comprehensiv e 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 redu ctions needed (wasteload allocations); and

• Document the implementation strategy fo r achieving environmental compliance with Washington's sediment management standards.

The Bellingham Bay Comprehensive Strategy was de veloped by U.S. Fish & Wildlife Department, Environmental Protection Agency and Army Corps of Engineers; Washington State departments of Ecology, Natural Resources, Fish & Wildlife, Tr ansportation and Puget So und 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 O ffice, 1204 Railroad Ave. Comments should be mailed to Pam Elardo, P.E., Department of Ec ology, NW Regional Office, 3190 - 160th Ave. SE, Bellevue, WA 98008-5452. Comment s may also be emailed to pam.elardo@metrokc.govBellingham Bay Contaminated Sediments TMDL Page B- 5 11/06/01 

### 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, informa tion on the proposed Bellingham Bay TMDL will be presented. Following the presentations, scientists w ho’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.Page B- 6 Bellingham Bay ContS ediments TMDL 11/06/01Bellingham Bay Contaminated Sediments TMDL Page C- 1 11/06/01 

# Appendix C- Comments Received and ResponsesPage C- 2 Bellingham Bay ContSe diments TMDL 11/06/01Bellingham Bay Contaminated Sediments TMDL Page C- 3 11/06/01Comment letterRobyn du Pré ReSources Bellingham, WAPage C- 4 Bellingham Bay ContSe diments TMDL 11/06/01Bellingham Bay Contaminated Sediments TMDL Page C5 11/06/01Page C- 6 Bellingham Bay ContSe diments TMDL 11/06/01 Response to Robyn du Pré:Bellingham Bay Contaminated Sediments TMDL Page C7 11/06/01Page C- 8 Bellingham Bay ContSe diments TMDL 11/06/01Bellingham Bay Contaminated Sediments TMDL Page C9 11/06/01Page C- 10 Bellingham Bay ContSe diments TMDL 11/06/01Comment 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. EvenBellingham Bay Contaminated Sediments TMDL Page C- 11 11/06/01 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.netPage C- 12 Bellingham Bay ContSe diments TMDL 11/06/01 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.Bellingham Bay Contaminated Sediments TMDL Page C- 13 11/06/01Comment letterDonald Burpee Enviro-Drain, Inc. Snohomish, WAPage C- 14 Bellingham Bay ContSe diments TMDL 11/06/01 Response to Donald Burpee:Bellingham Bay Contaminated Sediments TMDL Page C- 15 11/06/01Comment letterDarin Cramer Washington State Department of Natural Resources Olympia, WAPage C- 16 Bellingham Bay ContSe diments TMDL 11/06/01Bellingham Bay Contaminated Sediments TMDL Page C- 17 11/06/01Page C- 18 Bellingham Bay ContSe diments TMDL 11/06/01Bellingham Bay Contaminated Sediments TMDL Page C- 19 11/06/01Page C- 20 Bellingham Bay ContSe diments TMDL 11/06/01Bellingham Bay Contaminated Sediments TMDL Page C- 21 11/06/01Page C- 22 Bellingham Bay ContSediments TMDL 11/06/01 Response to Darin Cramer:Bellingham Bay Contaminated Sediments TMDL Page C- 23 11/06/01Page C- 24 Bellingham Bay ContS ediments TMDL 11/06/01Bellingham Bay Contaminated Sediments TMDL Page C- 25 11/06/01