Restoring the Duwamish: What is at Stake? May 15, 2013 | 1
Lower Duwamish Waterway - Background 5-mile river segment listed due to historically contaminated sediments Legacy contamination - industrial discharges, stormwater, CSOs The Lower Duwamish Waterway Group (King County, City of Seattle, Port of Seattle, and Boeing) – formed in 2000 to work on sediment cleanup More than 100 “potentially responsible parties” identified by EPA to date | 2
Lower Duwamish Waterway – Economics Today, the waterway is home to: • 100,000 jobs • 38,000 residents • 25% of King County manufacturing • Businesses that handle 7.2 million tons each year of domestic and international traffic, valued at $7.5 billion • 84% of the industrial lands within the city (5,000 acres) • Three primary land uses: – Commercial (32%) – Industrial (26%) – Warehousing (23%) – Other uses include residential, parks, open space, military and vacant (another 19%) | 3
Duwamish Schedule - Key Dates • EPA Proposed Plan • Environmental Justice Analysis • Ecology Source Control Record of Decision Remedial Design Strategy (Feb) (Q1 2014) 2013 2014 2015 2016 2017 2018 Proposed Plan Negotiate Agreements Begin Construction Public Comment among PRPs and sign (Feb + 105 days) Consent Decree Early Actions Source Control | 4
Early Actions: Cleanup, Dredging, Source Control • Over $95 million invested in cleanup of 29 acres • LDWG-initiated early cleanups are predicted to reduce PCB sediment concentrations by ~50% • Projects include: Completed Duwamish/Diagonal sedimentation Underway remediation (King County) Boeing Plant 2 (Boeing) Norfolk CSO sediment remediation Jorgensen Forge (Jorgensen) (King County) Slip 4 remediation (City of Seattle ) T117 (City of Seattle/Port of Seattle) | 5
Sediment Goals Early actions predicted to get waterway to this level All alternatives in Feasibility Study Lake Washington & predicted to get Lake Sammamish waterway to this level EPA’s proposed goal is 2 ppb total PCBs 6 | 6
EPA Proposed Cleanup | 7
What’s at stake? • Taxpayers, utility rate payers, and local businesses will be responsible for paying for the cleanup. • If we don’t get started now, the Lower Duwamish will remain contaminated and there is uncertainty for the public and businesses. • Some may ask for more dredging, which will increase construction time, elevate risk, increase impacts to the community, and cost more. | 8
LDWG Priorities for the Cleanup Plan • Reduce risks to human health and the environment through sediment cleanup • Complete construction as soon as possible and focus dredging to maximize the benefits and minimize the impacts • Optimize cleanup technologies and commit to extensive follow-up monitoring • Provide an effective, reliable cleanup plan that does not defer substantive decisions and is supportable and implementable Protective, Cost Effective, and Timely | 9
EPA Proposed Cleanup Plan: “5C-Plus” • 7 years of construction and $305 million* • Combination of technologies (dredging, capping, etc.) • Institutional controls to limit consumption of resident seafood • Extensive monitoring and contingency requirements • Source control program led by Ecology • After 20-30 years: • Study whether additional cleanup is needed • Waive cleanup standards if natural background is not met *These costs are not reflective of all of the proposed plan’s elements and will likely be higher. | 10
EPA’s Proposed Plan – a good start How can it be improved? • Decrease construction by two years, reducing impacts to the community and environment • Achieve the same risk reduction, and faster • Provide a cost-effective approach to protect taxpayers, ratepayers, and the local economy | 11
Comparing cleanup options 8 450 Both options reach same long term risk reduction (2X10 -4 ) Construction times = Period of elevated risks 400 7 Risk of incremental cost This portion reflects (2 x 10 -4 ) increase of $65M for increased time additional tasks in the needed to complete 350 proposed plan: additional work 6 Total Net Present Value Costs ($ MM) primarily due to more Construction Time (years) (2 x 10 -4 ) - more monitoring for dredging. surface water and tissue 300 - It will result in 5 - more stringent SMS increased risk from compliance standards eating fish from the 250 river, during - larger remedial footprint 4 construction. and dredge volume 200 - It will not - more stringent water significantly reduce quality treatment 3 health or requirements, and environmental risks. 150 - pilot studies. 2 This additional work 100 will not significantly reduce long-term health or 1 50 environmental risks. 0 0 Suggested EPA Proposed Plan Suggested EPA Proposed Plan Improvements Improvements Note: incremental costs and length of construction may (Key Elements) Remedy (Key Elements) be higher due to new cleanup goals in proposed plan. | 12
EPA’s Proposed Plan – a good start New cleanup requirements will challenge success • Unachievable cleanup requirements for PCBs may delay the start of cleanup. - Natural background goal for sediment cleanup - Fish tissue cleanup goal is below levels seen in other local urban waters - Water quality cleanup goals are lower than the upstream Green River, and other area rivers such as the Snohomish and Puyallup • Unachievable cleanup goals will likely increase the construction well beyond the time frame and cost estimated in the proposed plan. • LDWG will ask that the fish tissue and water quality goals be removed, and a more achievable sediment cleanup goal be set that reflects a typical urban waterway. | 13
Summary • It is important to get started to eliminate uncertainty for our community and businesses and to quickly reduce health and environmental risk. • The water quality and fish tissue goals should be removed. Sediment goal should not be defined by natural background. • Additional dredging of isolated contamination increases human health risk, delays the final cleanup, and does not produce lower risk to people or to the environment. • Invest wisely. – Maximize most effective cleanup opportunities – Minimize public health impacts – Implement quickly with least disturbance to the community | 14
Supporting Slides | 15
Monitoring Will Play an Important Role Trends in total PCB concentrations in English sole fillets in the LDW 2,000 Winter 2003/2004 Duwamish/Diagonal, East Concentration of Total PCBs in English Sole Fillet 1,800 Waterway, Lockheed & Todd Shipyard Dredging (~600,000 cy) 1,600 1,400 1,200 (μg/kg ww) 1,000 800 600 400 200 0 1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 Year | 16
Fish tissue cleanup goal Fish Tissue Total PCB Concentrations in the Lower Duwamish and Surrounding Urban Areas 3,000 Note: A large quantity of sediment (~600,000 cy) was dredged in English sole Mean Concentration of PCBs in Whole-Body Fish 2003/2004 from several areas of LDW and East/West Waterways. Perch 2,500 Northern pikeminnow Yellow perch 2,000 Cutthroat trout Smallmouth bass (μg/kg ww) 1,500 Red-dotted line 1,000 indicates EPA's proposed tissue PRG of 1.8 to 12 500 ug/kg ww for fish in the LDW. 0 2004 2005 2007 Steady- Elliott Lake State Bay Washington LDW Empirical Data LDW FWM- Empirical Data from Nearby predicted Urban Areas | 17
Water quality goal Cleaner than Green River 6/5/2013, Filename.ppt | 18
Average upstream surface water PCB concentrations Lower Duwamish Waterway Green/Duwamish River Watershed 6/5/2013, Filename.ppt | 19
Total PCB concentrations (µg/kg ww, or ppb) in fish from EPA’s Proposed Tissue PRG range Puget Sound (0.4 to 12 ppb) compared to other common food sources Source: Ecology (2012) citing Puget Sound Action Team 2007 Note: Samples include fish from Puget Sound and results are reported in micrograms per kilogram sampled. Commercial foods were sampled as part of the U.S. Food and Drug Administration’s total diet study and market- basket survey. In most cases, data are limited by small sample sizes. 6/5/2013, Filename.ppt | 20
Background Arsenic • Average arsenic soil concentration in Lower Duwamish Waterway vicinity is ~13 mg/kg • EPA’s proposed plan PRG is 7 mg/kg Note: soil samples collected from parks, schools, yards 21 | 21
What EPA’s Proposed Cleanup Actions Accomplishes and Doesn’t Accomplish Achievable Outcomes: • Reduces risk from eating resident seafood by ~90% – Reaches lowest feasible levels quickly (~ 15-20 years); source control (led by Ecology) may further lower risk over time • Safe for other exposures (beach play; netfishing, etc) • Protects benthic organisms in sediments • Protects higher ecological receptors (e.g., otters) Unachievable Outcomes: • Natural background goal for sediment • Fish tissue and water quality goals 6/5/2013, Filename.ppt | 22
EPA’s Proposed Plan – a good start New cleanup requirements will challenge success Unachievable cleanup requirements may delay the start of cleanup. • Natural background goal for sediment cleanup • Fish tissue cleanup goal are below levels seen in other local urban waters, such as Lake Washington • Water quality cleanup goals are lower than the upstream Green River, and other area rivers such as the Snohomish and Puyallup | 23
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