2.0 SUMMARY OF SOURCE CONTROL ACTIVITIES

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1 2.0 SUMMARY OF SOURCE CONTROL ACTIVITIES This section describes the source control activities in the Thea Foss Basin including an update on special studies. In Appendix A, these activities and special studies are further detailed in the specific outfall work plans where relevant. The source control activities are summarized in the Sections 2.1 and 2.2 including those associated with the Thea Foss 2009 Work Plan and those associated with Tacoma s Phase 1 Municipal NPDES Permit as part of The City s Stormwater Management Program. Sections 2.3 and 2.4 presents summaries of special studies conducted under the Thea Foss Program or that are part of other City programs and relevant to source control within Thea Foss Basin. 2.1 MASTER SPREADSHEET (DRAIN, ACTION, DATE, POTENTIAL COCs, STATUS) Source control investigations and other actions for each outfall drainage area are described in Table 2-1. The activities are grouped by the following actions: Construction - Site construction Inspection Inspections Onsite Facilities or Facilities Onsite facility or public facility constructed in that year Maintenance - Storm system maintenance Point Sources Located point source to storm system UST Underground Storage Tank or Leaking Underground Storage Tank (UST/LUST) located, removed or closed in place Cleanup Actions - Site cleanup Spill Spill reported and cleaned Fines Fine issued by a regulatory agency Education Public education Each action is defined by basin/sub-basin, date of occurrence, potential COCs, status (ongoing, completed, one-time) and a short description. Once completed, these activities by themselves may have a very small reduction in the total pollutant load. Over time, these very small pollutant load reductions are additive and real reductions in the total pollutant load may be observed. This will be further evaluated in Section 5.0 Program Effectiveness. From August 2001 through 2010, approximately 355 actions have occurred within the Thea Foss Watershed. The actions shown in Table 2-1 and are summarized as follows: Action Thea Foss A 237B Construction Inspection Facilities Maintenance Point Sources UST Cleanup Actions Spill Fines Education Total The number reported includes notable actions only. Number of all inspections and spills are provided in Section Thea Foss and Wheeler-Osgood Waterways 5

2 2.1.1 Stormwater Suspended Particulate Matter Monitoring Stormwater Suspended Particulate Matter (SSPM) monitoring is used in identifying potential problem areas in sub-drainage systems. Multi-year sampling is used to confirm an ongoing problem area or to confirm control/removal of an ongoing problem. Between 2002 and 2011, upstream monitoring was completed in some of the Thea Foss drainage basins. Table 2-2 lists the upstream monitoring locations for each of these years. The data for each of these monitoring stations are provided in Appendix D, and Tables D-15 and D-16. The drainage basin and SSPM data are shown in Figures 2-1a through 2-1d for each COC (i.e., mercury, total PAHs, total phthalates and total PCBs). These figures show each outfall and upline sediment trap location and the level of concentration for that location in relation to all reported values for that year. The levels of concentrations are color-coded as low, medium and high concentration ranges with each additional year stacked on the previous year. Low concentration ranges represent concentrations that are similar to other locations with no need for additional source control efforts at this time. Medium concentration ranges represent concentration levels that are slightly above other locations. Priority for medium levels would be set as additional source control is needed but at a lower priority in comparison to other locations determined to be of greater impact. High concentration ranges represent concentration levels above and beyond other locations in the Thea Foss watershed, and the need for additional source control is higher in comparison to other locations. In general, the SSPM data remained the same or increased in Mercury at FD34 (OF237B), FD3A (OF230) and FD23 (OF243) remained in the medium range measurements (see Figure 2-1a). Mercury increased to the medium range measurements at FD18B (OF230), FD6A (OF235) and FD22 (OF245/248). PAHs at FD13B (OF237A) remained in the medium range measurements (see Figure 2-1b). PAHs increased to the medium range measurements at FD10C (OF237A) and high range measurements at FD31 (OF237B). Phthalates at FD10C (OF237A) remained in the medium range measurements (see Figure 2-1b). Phthalates increased to the medium range measurements at FD18B (OF230) and high range measurements at FD16 (OF230) and FD22 (OF245/248). PCBs were once again measured in the high range at FD3A (OF230), FD34 (OF237B) and FD35 (OF237B) (see Figure 2-1d). The data results by basin are discussed in Appendix A and Section 5 of this report. The City will continue to conduct SSPM monitoring using sediment traps at the outfalls and at upstream locations in several drainage basins. Future plans and decisions related to upstream monitoring studies are discussed cooperatively by the Foss Workgroup Foss Work Group The Annual Foss Work Plan meeting was held on June 17, The work group consisted of representatives from the City, Washington State Department of Ecology (Ecology), EPA, Port of Tacoma, Citizens for a Healthy Bay (CHB), Foss Waterway Development Authority and the Utilities. The group met to discuss on-going and pending source control issues. Tacoma presented its data analyses for the Stormwater Monitoring Report and updated source control activities on the 2010 Work Plan. Thea Foss and Wheeler-Osgood Waterways 6

3 In a letter dated June10, 2008, EPA and Ecology agreed that Quarterly Stormwater Source Control Reports would no longer be required and that one annual submission for source control status would be required (USEPA 2008). This source control status report is submitted annually and is appended to the City s NPDES Annual Report which is due March 31 each year. Tacoma submitted the 2009 Stormwater Source Control Report and Water Year 2009 Stormwater Monitoring Report on March 31, In the 2009 Source Control Report, the City recommended several source control activities referred to herein as the 2010 Work Plan (City of Tacoma 2010). Completion of each activity contained in the 2010 Work Plan was dependent on what was found during the preceding tasks in the investigation. A summary of the source control activities identified in the 2010 Work Plan is provided below, including an update on each task Source Control Work Plan A majority of the recommended tasks from the 2010 Work Plan were completed or are ongoing. Completed and ongoing activities include: Completed Priority 1 tasks: OF237A PAHs and mercury in the area draining to FD13 and FD13A: The stormwater treatment retrofit was completed in September Business inspections were completed in this drainage in The Tacoma News Tribune system was mapped. Continued OF245 monitoring for oil snakes downstream of the new stormwater line on South 19 th Street. Monitored the final remediation phase of the Northern Pacific rail yard oil pipeline area along D Street to the old Standard Oil site (OF254 PAHs). OF254 DEHP: Conducted follow-up inspections at Northwest Detention Center. OF254: Evaluated the post cleaning stormwater and baseflow data to determine the ongoing effectiveness of storm line cleaning. OF230: Constructed the $1,000,000 Ecology grant CIPP project in OF230: Developed and distributed a Stormwater Education Flyer for Tacoma s Public Market on Market Street OF243: Mercury and PCBs source tracing investigations. Gained access to BNRR site with aid from Legal Department. Pursued contractor safety certification for access to BNRR site. OF235: Continued support of Ecology-led investigations. Monitored Ecology s MTCA, Clean Sites Initiative, Puget Sound Initiative and other sites and activities including but not limited to: American Plating (OF243), and Sauro s Cleanerama (OF230). Monitored SuperValu structural BMP installation in OFs 245, 248 and 249. Reinstalled all sediment traps before 2010 seasonal first flush. Reviewed the SSPM data to confirm existing conditions in the basin. Implemented the City s Surface Water Management Manual, September 2008 edition, revised Inspected 1,523 businesses in 2010 throughout Tacoma with 784 of those in Thea Foss Basin. Tracked all inspections in the business inspections database. In 2010, the City completed an estimated 85 percent of the City inspected since Responded to 977 complaints/spills throughout Tacoma with 212 of those in Thea Foss Basin. Tracked all in complaints database. Thea Foss and Wheeler-Osgood Waterways 7

4 Completed 436 treatment device signoff inspections in 2010 throughout Tacoma with 119 of those in the Thea Foss Basin. Completed Foss Stormwater Monitoring Water Year Participated with UWT and WSU Extension in Ecology Grant to develop a continuing TRC and TAPE program for Stormwater Treatment Technologies. Participated in Tacoma Maritime Fest Participated in Clean Green Boating Fair as part of the Marina Owners, Tenants and Operators working group. Monitored the major construction activities related to the WSDOT, Nalley Valley Viaduct/SR-16 rebuild and construction of the Sounder Corridor, South M to South 56 th. Completed report for Wet/Dry Air Deposition Study. Completed report for the WSDOT/UW Stormwater Technology Study. Continued participation in the Marina Owners, Tenants and Operators working group formed during Acquired spill response materials for marinas. Updating our Surface Water Management Manual in 2010 and Monitored the major construction activities in Basin 230. Monitored the major construction activities in Basin 235. OF235: Awarded $1M FY 2011 Stormwater Retrofit and LID Competitive Grant from Ecology for a $1.54M regional stormwater treatment facility in the Hood Street Corridor through the Brewery District (S 23 th through S 21 st ). This project will be designed to coordinate with the Prairie Line Trail and will be developed in partnership that project. The facility will consist of a bioinfiltration swale (basic treatment) which will extend from S 23 th to S 21 st and provide treatment for 21 acres of Basin 235. Documented grain dust deposition into Thea Foss Waterway from grain elevator located at the mouth of the waterway. Completed Priority 2 tasks: OF245 PAHs: Monitoring for oil snakes to confirm the source is remediated. OF254 PAHs: Continue increased street vacuum sweeping. OF230 PCBs and phthalates source tracing in Branch FD18. Inspected Multi-Care campus, jail, courthouse, and Bates Community College OF230: Mercury source tracing in Branch FD3A. Inspected Multi-Care campus, jail and courthouse Completed Priority 3 tasks: OF235 PAHs (FD6B) and phthalates (FD6A) source tracing using upline sediment traps. Inspected St. Joseph and Multicare Hospital campuses. Ongoing Priority 1 tasks: OF254 DEHP: Conducting follow-up inspections at Northwest Detention Center. Continuing OF243 mercury and PCBs source tracing investigations. Preparing report for Tacoma Landfill Pervious Pavement Study. Continuing to administer the City s Surface Water Management Manual. Respond and track all complaints/spills in complaints database. Continuing to use/update the spills/complaints and business inspections database. Continuing Foss Stormwater Monitoring Water Year Participating with UWT and WSU Extension in Ecology Grant to develop a continuing TRC and TAPE program for Stormwater Treatment Technologies. Monitoring the major construction activities in Basin 230. Monitoring the major construction activities in Basin 235. Thea Foss and Wheeler-Osgood Waterways 8

5 Ongoing Priority 3 task: OF235: Construct pipe rehabilitation projects that have been identified on the City s CIP list. Within Basins 230 and 235, business inspections were concentrated in these basins to target the following areas and chemicals of concern: Priority 2 tasks: OF230: Mercury source tracing in the area draining to FD3A. OF230: PCB and phthalate source tracing in the area draining to FD18. Priority 3 tasks: OF235: PAH source tracing in the area draining to FD6B. OF235: Phthalate source tracing in the area draining to FD6A. OF235: PCB and mercury source tracing in the area draining to FD6. Activities Not Completed. Completion of each task is dependent on what is found during the preceding steps in the investigations, and therefore some tasks may require substantial amount of time and effort. Thus, some of the projected source control activities could not be completed due to the time and effort committed to the tasks completed above or that are ongoing. Activities outlined in the 2010 Work Plan that could not be completed in 2010 were as follows: Priority 1 tasks: OF237B: Re-inspect the FD31 branch, the Willard Staff School and the site of the neighborhood fueling station as possible sources of PAHs and TPHs. Priority 2 tasks: OF237A: Mercury and PCB source tracing in the area draining to FD2A. OF245: Investigate Quality Transport with TPCHD to locate possible source of phthalates. Priority 3 tasks: OFs 245 and 243: Source trace acenaphthene source in baseflow. OF237A: Mercury and PAH source tracing in the area draining to FD10. OF237A: Phthalate and PCB source tracing in the area draining to FD10C. OF237B: Review 2010 SPMM PCB data at FD35 and FD34, and if needed review activities in these areas of concern including the use of other source tracing techniques. OF237B: Review 2010 SPMM mercury data, and if needed review activities in these areas of concern including the use of other source tracing techniques. 2.2 CITY OF TACOMA PHASE I MUNICIPAL STORMWATER PERMIT On February 16, 2007, Ecology issued a new National Pollutant Discharge Elimination System (NPDES) Stormwater Permit for Phase I Municipalities including the City of Tacoma, City of Seattle, and Pierce, King, Thurston, Snohomish and Clark Counties. The 2007 permit replaces the existing NPDES Municipal Stormwater Permit issued in It regulates the discharge of stormwater to surface waters and ground waters of the state from Tacoma s municipal separate storm sewer system (MS4). This permit is designed to protect and improve the water quality of our receiving waters by implementing stormwater management activities. In 2010, we have Thea Foss and Wheeler-Osgood Waterways 9

6 revised Tacoma s Stormwater Management Program (SWMP) to guide the operation of Tacoma s Surface Water Management Utility during the upcoming five-year permit term (Tacoma 2010). During the five-year permit term, the City s program and its progress are summarized in an annual report. The NPDES Annual Report is used as a tool to assess the City s progress and determine any changes to the SWMP procedures or priorities required to fulfill the permit obligations. The SWMP is evaluated annually, and updated when necessary, based on the annual report and program assessment. Table 2-1 identifies program related activities as required under the Phase 1 Municipal NPDES Permit as part of the City s SWMP City of Tacoma Stormwater Management Program Tacoma s SWMP is divided into ten components as outlined in the NPDES Municipal Stormwater Permit Section S5 (Tacoma 2010). The SWMP components are summarized here: Legal: The City has the legal authority to control discharges to and from the municipal storm sewers owned by the City, Chapter of the Tacoma Municipal Code. Mapping: The City s stormwater system is updated with new information as it becomes available. Coordination: Internal and external coordination agreements/mechanisms will be established to facilitate cooperation between City departments and surrounding municipalities. Public Involvement and Participation: Opportunities are provided for in the SWMP. New Development and Redevelopment: The City of Tacoma Surface Water Management Manual (Tacoma 2008 Edition, 2009 Revision) provides a commonly accepted set of technical standards and guidance on stormwater management measures that will control quantity and quality of stormwater produced by new development and redevelopment of property. The minimum requirements in Ordinance require flow control and water quality treatment of new and redeveloped sites, private and public development, including right-of-way improvements in Tacoma. The minimum requirements for commercial and high traffic areas include treatment to remove at least 80 percent of the solids on an annual basis. Through implementation of this manual, more sediment should be removed in the future, thus helping to remove sediment-associated contaminants which may become entrained in municipal stormwater. This program should reduce the sediment and associated particulate-bound COCs discharging into the municipal stormwater system and its receiving waters. Structural Stormwater Controls: A program to prevent or reduce impacts to waters of the state caused by stormwater discharges must be developed and must consist of structural stormwater controls. Projects must be selected and an implementation schedule is required. Source Control: Inspections of pollutant-generating sources are required for commercial, industrial and multi-family properties including City-owned sites. Illicit Connections: Continue the ongoing program to detect, remove and prevent illicit connections and discharges, including spill response, for discharges into the City s separate storm sewer system (MS4). Operation and Maintenance: Maintenance standards and inspection programs are required for public and private stormwater facilities. Best Management Practices (BMPs) are also required for the maintenance and operation of public streets and roads to reduce stormwater impacts. Thea Foss and Wheeler-Osgood Waterways 10

7 Education and Outreach: Educational programs need to provide information to elected officials, policymakers, residents, businesses including home-based and mobile businesses, landscapers and property managers, industries, engineers, contractors, land developers, municipal permitting and planning staff, and others. The educational program will be designed to achieve improvements in the understanding of each target audience. Stormwater Management Goals and Challenges. The City considers itself a leader in responding to the issues of water quality related to urban runoff. Our activities have included pioneering efforts in water quality testing to identify pollutants in stormwater runoff as early as Current efforts include investigating source control and treatment of stormwater pollutants like phthalates. The Tacoma City Council and Tacoma s Surface Water Utility ratepayers have supported substantial rate increases in recognition of the importance of protecting and enhancing the water quality in Commencement Bay and our fresh water lakes, wetlands and streams in the face of increasing stormwater runoff and pollutant loads from urban development, increased traffic and population pressure. The City s goals established for the original Stormwater Management Program in 1999 under the first NPDES Municipal Stormwater Permit further emphasize the City s commitment to meeting the water quality goals under this permit. The goals of the City s Stormwater Management Program include the following: Manage stormwater to minimize flooding and erosion; Manage stormwater to minimize contact with contaminants; Mitigate the impacts of increased runoff due to urbanization; Manage runoff from developed properties and those being developed; Protect the health, safety and welfare of the public; Correct or mitigate existing water quality problems; and Restore and maintain the chemical, physical, and biological integrity of the receiving waters in the City for protection of beneficial uses. Tacoma s SWMP is administered by the Surface Water Section of the Environmental Services, Science and Engineering Division of the Public Works Department (Tacoma 2010). Staffing and budget are designed to meet the program goals and challenges described above. Our current work includes: Inspecting business activities and permitting and inspecting new construction projects. Collection and analysis of stormwater quality monitoring data. Implementing a source control and monitoring program focused in the watershed of the Thea Foss Waterway to protect the recently completed Superfund cleanup action, and enhancing habitat areas to restore beneficial uses. Mapping, maintaining and cleaning a stormwater system that includes over 440 miles of storm pipe, 10,000 manholes, 18,300 catch basins, and 21 stormwater ponds. Rehabilitating and replacing aging infrastructure and improving the storm system with capital projects to address identified water quantity and quality issues. With an Ecology Grant, Tacoma is launching a new program, Stormwater Rapid Assessment Program (STRAP). A specialized camera will be deployed in every pipe assessing not only its condition but also the need for sediment removal. This information will be stored in GIS and used to prioritize maintenance and capital improvement projects. Providing public education about stormwater and surface water management and sharing information with staff from federal, state and neighboring municipal governments, environmental groups, businesses and interested citizens. Thea Foss and Wheeler-Osgood Waterways 11

8 Participating in regional watershed councils and committees. The current City Surface Water Management Manual (Surface Water Manual) includes the BMP selection and design criteria that are equivalent to Ecology s 2005 Stormwater Management Manual for Western Washington (2005 Ecology Manual). The Surface Water Manual assists in meeting this permit s requirements to protect water quality, reduce the discharge of pollutants to the maximum extent practicable, and satisfy the state AKART requirements. The City s Surface Water Manual is implemented by the Environmental Services Surface Water Division (Tacoma 2008 Edition, 2009 Revision). The City is currently working on a 2011 update to the Surface Water Manual which will clarify language in the existing manual and correct errors Business Inspections/Spills/Complaints The City began conducting stormwater business inspections prior to 1984 as part of its delegated responsibility to implement Ecology s NPDES sanitary sewer pretreatment program. Currently, the City has a Source Control Program under the Consent Decree with the EPA for the Thea Foss Waterway Superfund Cleanup. The City s Source Control Program was expanded citywide to fulfill the NPDES permit requirements. The current program is managed by The Environmental Compliance Section and includes the following: Inspecting multi-family units (including four or more residential units) in addition to businesses and industries. Inspections address both stormwater and sanitary compliance. Providing information on BMPs and program literature directly to businesses during site visits (which are available in the Surface Water Management Manual Volume IV). Business BMPs in the Surface Water Manual, Volume 4, Chapter 4 are currently being updated. These changes were based upon Tacoma s field experience. These updates to the Surface Water Manual will be completed in Educating the general public and businesses on BMPs and City environmental programs. Inspecting and signing off on commercial drainage facilities. This inspection also provides an educational opportunity for Environmental Compliance inspectors to review operation and maintenance requirements with the builder or owner. Continuing to implement the City s IDDE Program which includes investigation and termination of illicit connections. The IDDE Program uses the City s database to track the complete process of screening, investigation, referral to responsible agencies (if other than the City), and enforcement. Uses a SQL/Access database, the Environmental Services Spills and Complaints Database, to track spills, complaints, business inspections and flooding claims since Regular updates and refinements have been made to facilitate advanced data management for tracking inspections. Investigating potential illicit discharges based on complaints, business inspection reports and stormwater monitoring information and responding to potential and confirmed illicit discharges using the same procedures applied to potential illicit connections. Business inspections/spill and complaints responses resulted in not only the field compliance form documentation but the generation of about 357 formal, level 1 enforcement letters with 198 related to stormwater issues. Citywide, 21 formal warning letters were sent in Three Notice of Violations letters were sent in 2010 with two in the Thea Foss Watershed. Out of the 1,523 business inspections, 977 spill/complaint responses and 436 treatment device Thea Foss and Wheeler-Osgood Waterways 12

9 inspections, only 21 formal letters were sent. That is 0.74 percent which shows that the City s education efforts are very successful and that the business community and City s residents are very supportive and engaged in protecting stormwater quality. Thus far, for the stormwater permit cycle (2007 to present), Tacoma has canvassed/inspected an estimated 85 percent of the City, inspecting both sanitary and stormwater compliance. The vast majority of the inspections find catch basins that have never been cleaned. Our inspection efforts have resulted in tons of catch basin sediment removal, drainage repair, sewer protection, and customer education. Tacoma also hosts an interagency bi-weekly inspectors meeting for training and coordination with staff from the Port of Tacoma, Ecology, Tacoma-Pierce County Health Department and other neighboring jurisdictions. In addition, Tacoma participates in the monthly Pierce County Code Enforcement Officers Group (PIC). Documentation for any of these activities is available upon request, however, is not presented herein Citywide Program Activities The following is a summary of City-wide activities. Those activities that are specific to the Thea Foss Watershed are further discussed in Appendix A. City-wide program activities for business inspections and spills and complaints response are discussed in Section Several special investigations were completed in 2010 including but not limited to: Supported Thea Foss work plan inspections and phthalate sampling, OF254; Documented and issued three Notice of Violations; Documented and issued 21 formal warning letters; Inspected WSDOT stormwater ponds (I-5, SR16, SR705, SR509) (OFs 237A, 235 and 243). Provided recommendations on maintenance issues; Completed focused inspections of St. Joseph s Hospital complex (OFs 235 and 230); Provided assistance with CTP Mapping, marked main trunkline manholes for easier identification; North Tacoma storm systems NT07-NT11 cleaned: 85,855 feet cleaned and 69.5 cubic yards of material removed; Completed focused inspections of the Bates Vocational complex (OF230); Completed focused Inspections of MultiCare Health Hospitals (OF230); Inspections completed at all Tacoma Public School and support facilities; Completed inspections of all City facilities: fire stations, street maintenance, parking structures, Cheney Stadium, theaters and solid waste. Developed and presented BMP Powerpoint; Conducted focused inspections in OF235 up to Center and Union; Moved to new Centers for Urban Waters (CUW) Building; Sampling and oversight on decontamination of BayView Painting Building (across from CUW on Thea Foss Waterway); Mapped private stormwater systems greater than four inches in 34 quarter sections for a total of 132 out of 254 for NPDES Permit requirement; IDDE: Smoked tested 5,362 addresses. Located nine cross-connections (six corrected and three in design); Completed focused inspections of sub-basin FD13 in OF 237A; Thea Foss and Wheeler-Osgood Waterways 13

10 WSDOT SR-16 Nalley Valley Project Coordination - Ongoing work with WSDOT and Atkinson Construction (general contractor for the project) has resulted in good communication and fast response to spills. Seven new stormwater ponds to monitor (OF237A); Found sanitary discharge to storm at Tacoma School District Maintenance Facility. Rerouted to sanitary; Facilitated East 11 th and D Street rail crossing correction. BNSF and City of Tacoma Streets and Grounds (OF207); Responded to KLB sweeper illegal dumping. Part of WSDOT contracts for SR16 westbound; Bill s Towing and Garage Notice of Violation and $10,000 fine on release to Thea Foss Waterway (OF237A). Non-dairy creamer containers broke was spilled in yard. Broken/unbroken containers were placed in dump truck which continued to leak and discharge to storm system; Repeated inspections and assistance to Nichols Trucking and First Student regarding track out (OF254). Maintenance (sweeping and BMP annual cleaning) required; Home BioDiesel fire resulted in release of diesel to waterway (OF237A); Classy Chassy Car Wash oil/water separator for car wash on Center Street was designed (OF237A); Follow-up inspections, sampling and dye testing at NW Detention Center (OF254); Trident Metals - heavy contamination of soil and waterway. Facility closed in June 2010; TFD Station #18 heating oil leak and poor chemical storage practices (OF207); Lowes Home Improvement. Stormwater detention and swale maintenance/remediation completed; Finalized Pierce County court and jail investigation (OF230); Participated in Pierce County dental educations outreach; Completed focused inspections of Republic and other private parking facilities (OFs 230 and 235); Black oily ash in Stadium District. Suspected to be from Naval ships docked at Sperry Dock in Commencement Bay; Documented multiple grain dust on the surface of the water in Thea Foss Waterway. TEMCO grain elevator is located near the mouth of Thea Foss Waterway; Identified and corrected shoestring side sewers in the north end around 23 rd and Fawcett. Tri-Pak - Coordinated compliance efforts at several Tri Pak yards, in particular Yard 3. Resulted in a Notice of Violation; Identified illegal asbestos disposal. Referred to PSCAA; Identification and correction of two gas stations connected to storm sewer. Oil/water separators installed and rerouted to sanitary; City inspections of Northshore Ponds (stormwater BMPs); Located UST at 7835 Pacific Avenue; Located five UST at 2415 Pacific Ave, Foremost (OF237A); and Issued Notice of Violation to The Bronze Works. Discharged elevated levels of arsenic, barium, chromium, lead, nickel, selenium, silver and zinc to storm drains (OF237A sub Basin FD2A). Other Major Program elements were developed or updated in 2010 including: The Public Works Environmental Services Emergency Flood Response Plan, including: - Attended Management SECO Meetings; - Response and radio training, PowerPoint update; - Phone list update; Thea Foss and Wheeler-Osgood Waterways 14

11 - PPE ordering and distribution; - Vehicle readiness and stocking; and - Refinement of the SEOC database. Provided daytime, evening and weekend pager coverage; Participated in the Inter-City spill response team; Maintained field and spill supplies; Car Wash Kit Program and Drain Marking Program transferred to EnviroChallenger Group. Provided training and manuals; Utilized the Washington Conservation Corps (WCC) for projects and provided program education regarding source control work; Completed list of cleaning and sweeper contractors ( ); CHB coordination; Completed first draft of new stormwater compliance policy. Updating Chapter 12.08; Provided source control BMP updates to Volume IV of the Surface Water Manual; Developed and distributed farmer markets flyer and medical waste flyer; and Provided ongoing oversight and certification of mobile washers. Training and coordination activities included: Attended quarterly Puget Sound Regional inspectors group meetings and made a formal presentation; Central Treatment Plant SWPPP presentation; Haz-Mat demonstration with WSDOT on drums along East E Street; Bi-weekly inspector meetings and training; Database training and provided suggestions for improvements; Thea Foss Superfund annual meeting, work plan and activity support/development. Discussed source control activities and watershed monitoring; Delivered formal presentations to Port of Tacoma tenants, SeaPort group/school teacher, Russell Foundation, and hosted a HOA workshop; Participated in monthly/quarterly meetings for stormwater and sanitary source control including: Pierce County Code Enforcement Officers Group (PIC), LINQ, King County IRAC, Pierce County LEPC; Assisted with program development and flyers for the Green Thea Foss Marina Day; All inspectors were trained in CESCL (Certified Erosion & Control Lead), two-day program; and Participated in the following community events: Tacoma Home Show and Puyallup Fair. All of these activities are expected to benefit the quantity and quality of stormwater discharges in Thea Foss Basin. Documentation for any of these activities is available upon request, however, is not presented herein. 2.3 SPECIAL STUDIES The primary COCs in waterway sediments are DEHP and PAHs. Other phthalates which are less frequently detected in the waterway sediments include dimethylphthalate, diethylphthalate and butylbenzylphthalate. However, DEHP reliably serves as a surrogate for the other phthalates in most instances. Phthalates are a class of industrial compounds commonly used as softeners in plastics; as solvents; as oil in vacuum pumps, electric capacitors and transformers; and as carriers in fragrances and pesticides. They have been reported in personal care products (King County Thea Foss and Wheeler-Osgood Waterways 15

12 and SPU, 2004). Their presence in the environment is an emerging issue of national and international scope and is beyond any one agency s capability to solve alone (King County/SPU 2005). The Sediment Phthalate Work Group, comprised of the City of Tacoma, EPA, Ecology, King County/Metro, and Seattle Public Utilities, concluded that: (1) DEHP is ubiquitous in the urban environment, and is believed to be derived primarily from off-gassing of commonly used vinyl and PVC residential/commercial building materials, such as flooring and siding; (2) DEHP in particulate matter in urban atmospheres is sufficient to account for the DEHP concentrations observed in municipal stormwater; (3) human exposure to DEHP occurs primarily via indoor and outdoor air; (4) the ubiquitousness of DEHP in modern society and urban atmospheres is not amenable to standard stormwater treatment approaches. The City is continuing to research the sources and treatment options of phthalates in stormwater. These efforts are described in the following paragraphs Wet/Dry Atmospheric Deposition Studies Tacoma completed a total of 20 rounds of atmospheric deposition sampling from May 2006 through September 2009 at five sampling locations in the Thea Foss Watershed. The monitoring report is attached in Appendix I. This study measured a combination of dry and wet deposition in urban/industrial neighborhoods. Atmospheric deposition flux results for the Tacoma stations (residential, highway, industrial and elevated) had generally similar ranges and median values for most part. However, lower median values were observed for the MD site, which was located on top of the municipal building and is believed to have no ground traffic and daily activity effects. The City compared the Tacoma data to King County s data that was summarized in the Lower Duwamish Waterway Passive Atmospheric Deposition Sampling (King County 2008). Between October 2005 and April 2007, King County conducted 16 rounds of passive atmospheric deposition sampling at five stations in the Lower Duwamish Waterway drainage basin. The average of the median data shows that the phthalate results are reasonably similar between Seattle and Tacoma, leading one to believe that the deposition rates are also similar in both areas of the Puget Sound basin. However, the same comparison data indicates that there is a difference in PAH values representing a ten times reduced rate of deposition in the Tacoma area WSDOT Stormwater Technology Studies Under an Interagency Memorandum of Agreement (IMOA) with City of Tacoma, the Washington State Department of Transportation (WSDOT) and the City of Seattle, Seattle Public Utility, Tacoma is conducting a study of structural stormwater controls. For the City, the overall intent of this IMOA is to work collaboratively to verify the performance of two permanent stormwater treatment technologies, and to evaluate the applicability of these technologies to the conditions in the Thea Foss Watershed. On September 9, 2004, the City received and the City Council accepted a $500,000 grant from the Federal Highway Administration, 2003 Transportation Community and System Preservation Pilot (TCSP) Program for the Thea Foss Waterway Stormwater Study. The application Thea Foss and Wheeler-Osgood Waterways 16

13 indicated that the City could use the grant to continue and expand the study and evaluation of the effectiveness of various treatment methodologies for stormwater from roads and highways using the Ship Canal Test Facility. Influent concentrations at the Test Facility compare reasonably well with stormwater data collected in the Thea Foss basins with the exceptions of slightly higher values for DEHP and din-octyl phthalate at the WSDOT Test Facility. Tacoma was interested in testing treatment technologies that may be used as a regional treatment system in the Thea Foss basin. Testing has been completed at the Ship Canal Test Facility on the StormFilter and AquaShield, AquaFilter. The StormFilter BMP final report summary was presented in the 2007 Stormwater Source Control Report (City of Tacoma 2008e). In general, the StormFilter was somewhat effective in removing the Thea Foss COCs. The StormFilter unit removed between 26.9% and 91.3% of TSS; from 28.7% to 35.1% of copper, lead, and zinc; between 10.9% and 41.5% of LPAHs; between 28.6% to 39.1% of HPAHs; and from 12.1% to 36.3% of phthalates. This technology does appear to be effective at removing the Thea Foss COCs and is appropriate for additional consideration. Testing of the AquaFilter was completed in December The final report is attached in Appendix I. Removal efficiencies for the Aqua-Filter technology were generally fairly low (25 percent or less) when looking at all flow rates collectively. Removal efficiencies for DEHP, one of the primary concerns for the Thea Foss basin, ranged from % to 55.8% with a median of 0.9%. Influent concentrations in the Thea Foss basin are generally slightly lower than those seen at the Test Facility, which may result in lower removal rates if the technology was applied in the Thea Foss basin. Since we are looking for a regional treatment system in the Thea Foss basin, this technology is not an appropriate choice. The City is evaluating the StormFilter technology s effectiveness, applicability and reasonableness for use of this technology within the Thea Foss Watershed using a GIS based model. This model and evaluation is described in Section Reasonableness shall take into consideration effectiveness, capacity, maintenance requirements, flood control, and cost of the treatment technology in comparison to the effectiveness achieved or expected to be achieved in reducing contaminant loads to Thea Foss Waterway. 2.4 BMP EFFECTIVENESS STUDIES Tacoma Landfill Pervious Pavement Study A 36,100 square foot paved area has been constructed to provide additional employee parking and storage areas for the Tacoma Landfill. Since the parking lot site is located on the existing landfill cover and cap, the location provided an opportunity for the City to study the use of impervious and pervious pavements. Pervious pavements allow rainwater to infiltrate through the pavement and into the landfill cover layer, prior to entering the landfill cap primary drainage system. Infiltration through the pervious pavement and cover material provides basic water quality treatment and reduces flow control requirements. To provide a comparison between pervious and impervious pavement, the new parking area was paved in sections. Each of the four sections (9,028 square feet each) was constructed with a different product. Pervious concrete, pervious interlocking concrete pavers, pervious asphalt, and a control area paved with standard asphalt were used in new paved area. Additionally, a grass area (also 9,028 square feet) adjacent to the site will be used as a control and tested for Thea Foss and Wheeler-Osgood Waterways 17

14 water quality and flow control. Test results for both impervious and pervious pavement areas will be compared and results will be used for future stormwater modeling of the landfill cap. In addition to helping the Tacoma Landfill improve its stormwater quality, reductions in stormwater contamination will provide information for the general City-wide stormwater program. Sampling results regarding the effectiveness of pervious pavements for flow control and water quality treatment will be used to support the City of Tacoma Surface Water Management Manual. To investigate the effectiveness of different pervious pavement types (concrete, asphalt, and interlocking pavers) to infiltrate and attenuate storm flow peak rate variations, results will be analyzed using correlations and parametric/nonparametric statistical tests. The study will evaluate flow control, the effectiveness of water quality treatment, maintenance requirements, and durability. Sampling was completed by summer 2010 and a draft report has been prepared. The final report will be complete by May This final report will be submitted with the 2011 Annual Report NPDES S8.F BMP Monitoring Section S8F of the Phase I NPDES Permit (NPDES S8F) requires Tacoma to conduct detailed performance monitoring on two stormwater treatment types that are standard technologies in our manual. The City has selected the following BMPs for evaluation monitoring: Two bioinfiltration facilities at the Salishan Hope VI Redevelopment (Salishan) - East 46 th and R Street Swale and East 44 th Street Pond: nd Two biofiltration facilities, East 32 Street and Trolley Court; and Three types of pervious pavement at the demonstration project located at the City Landfill (flow reduction strategy only). The selected bioinfiltration facilities provide enhanced treatment and the biofiltration facilities provide basic treatment. The pervious pavements provide flow reduction. The Salishan project is a residential redevelopment project consisting of over 1,200 housing units, including both single and multi-family. During redevelopment, the existing stormwater conveyance system was replaced with new infrastructure including a system of biofiltration and bioinfiltration facilities. East 46 th and R Street Swale and East 44 th Street pond facilities were designed to meet the requirements for basic and enhanced treatment as specified in the Tacoma Surface Water Management Manual (and 2005 Ecology Manual). The East 32 nd Street improvement required treatment of the improved street runoff. The land use in the area is residential on one side of the street and an office building with parking lot on the opposite side of the street. The East 32 nd Street improvement bioswale consists of two parallel bioswales that receive street runoff from catch basins along East 32 nd Street through a pair of 12-inch pipes, one for each bioswale. The Trolley Court development required treatment of the street, new residences, and one commercial building. The land use in the area is residential and commercial. The Trolley Court bioswale is located at 1712 State St. It receives runoff from surrounding streets and residences through a 12-inch pipe. These facilities were designed to meet the requirements for basic treatment as specified in the Tacoma Surface Water Management Manual (and 2005 Ecology Manual). Thea Foss and Wheeler-Osgood Waterways 18

15 The water analytes identified as parameters of concern by Ecology are those that will provide information regarding the effectiveness of basic and enhanced treatment BMPs. These parameters are: Conventionals: Hardness, ph, Particle Size Distribution (PSD), and TSS Metals (dissolved & total): Copper and Zinc, and Nutrients: Orthophosphate and Total phosphorus. In addition, Tacoma added chemicals of concern for Thea Foss Waterway Recontamination Evaluation including metals (dissolved & total) lead and mercury and organic compounds, PAHs and phthalates. It is anticipated that monitoring will be completed in A final report will be prepared following completion of the monitoring. The Pervious Pavement Project, described in Section 2.4.1, is intended to investigate the effectiveness of different pervious pavement types (concrete, asphalt, and interlocking pavers) to infiltrate and attenuate storm flow peak rate variations, results will be analyzed using correlations and parametric/nonparametric statistical tests. The study will evaluate flow control, the effectiveness of water quality treatment, maintenance requirements, and durability. Monitoring was completed 2010 and a final report will be prepared in Basin-Wide Sewer Line Cleaning: NPDES S8.E Program Effectiveness Section S8E of the Phase I NPDES Permit (NPDES S8E) requires Tacoma to select specific aspects of the SWMP for evaluation: (1) to evaluate the effectiveness of a specific action and (2) to evaluate the effectiveness of achieving a targeted environmental outcome (Ecology 2007). The City selected to evaluate maintenance practices for aging pipe systems: basin-wide sewer line cleaning. A Quality Assurance Project Plan (QAPP) was submitted to Ecology on August 16, The City has performed basin-wide sewer line cleaning of three entire drainage basins (254, 235, and 230) and part of a fourth basin (237A). The objective of the sewer line cleaning program is to remove residual sediments in the storm drains, some of which may contain legacy contamination from past years that may continue to contaminate stormwater or baseflow through resuspension and/or dissolution. Following are the dates of the City s sewer-line cleaning activities: Basin 254: January 26 through June 14, 2006 Basin 230: March 12 through May 14, 2007 Basin 235: May 15 through June 25, 2007 Basin 237A: April 28 through August 8, 2008 (only the northern half of this drainage basin was cleaned) Basins 230 and 235 now have over three full years of post-cleaning monitoring data, and Basin 254 has over four full years of post-cleaning data. Basin 237A now has two years of postcleaning data, and therefore this is the first year it is included in the statistical testing. There are between 23 and 38 post-cleaning monitoring events for these drains, and between 37 and 66 pre-cleaning events. This provides a sufficiently large data set to test for statistically significant differences in stormwater quality before and after cleaning. In Basins 230, 235, 237A, and 254, statistical analysis was conducted on the pre-cleaning versus post-cleaning data sets to assess the effectiveness of basin-wide sewer line cleaning. Summary statistics (minimum, median, mean, maximum, standard deviation, and standard Thea Foss and Wheeler-Osgood Waterways 19

16 error) were compiled for the pre-cleaning and post-cleaning data sets. Statistical tests were conducted (t-tests at 95 percent confidence level) to determine whether the sewer line cleaning activities resulted in statistically significant differences in stormwater quality. Any monitoring events within the window of cleaning activities were excluded from the analysis. Because Tacoma s stormwater data is well described by lognormal statistical distributions (City of Tacoma, 2009), the t-tests were performed using the logarithms of the data. The summary statistics and t-test results are compiled in Table 2-3. Box plots comparing precleaning and post-cleaning chemical distributions are shown on Figure 2-2. Following are the main conclusions regarding the effectiveness of basin-wide sewer cleaning on reducing contaminant concentrations in stormwater: TSS: Results for TSS are mixed, including one significant decrease, and one significant increase. Because the differences are either insignificant or inconsistent in direction, sewer line cleaning appears to have had no net effect on TSS concentrations. Lead: Basin 235 showed a statistically significant reduction of approximately 37 percent in lead, and Basin 237A showed a marginally significant reduction (92.8 percent confidence level) of approximately 17 percent. There is no longer a statistically significant reduction in lead in Basin 230, as seen in last year s data set. Zinc: Last year there were no significant differences in zinc between the pre-cleaning and post-cleaning data sets. Statistically significant reductions can now be seen in three of the four basins (Basins 235, 237A, and 254) with an estimated 18 to 31 percent reduction in mean zinc concentrations. PAHs. Differences in PAH composition are remarkable, and provide the best evidence for the effectiveness of storm line cleaning. Statistically significant reductions were evident in every test case, including each of the three index PAHs (phenanthrene, pyrene, and indeno(1,2,3-cd)pyrene) in each of the four drains. Sewer line cleaning resulted in 52 to 88 percent reductions in PAH concentrations. DEHP: Last year, there were no significant differences in DEHP between the precleaning and post-cleaning data sets. Statistically significant reductions can now be seen in two of the four basins (Basins 235 and 237A) with an estimated 56 to 59 percent reduction. Possibly, more differences in DEHP quality will be discernible in the future after more post-cleaning data are collected, given the higher variability of DEHP compared to PAHs. In summary, sewer line cleaning appears to have been effective at removing zinc (18 to 31 percent reductions in three out of four drains), PAHs (52 to 88 percent reduction in all four drains, including both light and heavy PAH fractions), and DEHP (56 to 59 percent reductions in two drains). Lead reductions were significant in one drain. No consistent reductions in TSS can be discerned from these data. These statistical comparisons will continue to be updated as more post-cleaning data are collected. The statistical power of this test should increase over time, and quite possibly statistical differences that cannot be resolved today may be distinguishable in the future GIS-Based Stormwater Pollutant Loading Model In addition to basin-wide sewer line cleaning discussed above, the City is developing a GISbased pollutant loading model to evaluate other stormwater BMPs that may be effective on a basin-wide scale. This study will include an evaluation of street sweeping, low-impact Thea Foss and Wheeler-Osgood Waterways 20