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Source Control, Risk Management and the Complex Nexus Between PRPs and Regulators. Betsy Day and Jennifer Sampson October 30, 2009. EPA’s Contaminated Sediment Management Strategy (1998).

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Source Control, Risk Management and the Complex Nexus Between PRPs and Regulators

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Source Control, Risk Management and the Complex Nexus Between PRPs and Regulators

Betsy Day and

Jennifer SampsonOctober 30, 2009

EPA’s Contaminated Sediment Management Strategy (1998)

  • “Before initiating any remediation, active or natural, it is important that point and nonpoint sources of contamination be identified and controlled.”

EPA’s Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites

First Principle: Control Sources Early

  • “… identify all direct and indirect continuing sources of significant contamination to the sediments…”

  • “…assess which sources can be controlled and by what mechanisms”

  • “…evaluate the potential for future recontamination”

USEPA 2002. Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites, 2/12/02

Sources of Contamination

  • Nonpoint sources

    • Upland and shoreline erosion

    • Industrial runoff

    • Mining, quarry runoff

    • Agricultural runoff

    • Contaminated sediment

    • Upstream sources

    • Atmospheric deposition

  • Point sources

    • Combined sewer overflows

    • Storm drains

    • Wastewater treatment plants

    • Spills

    • Contaminated groundwater

Consequences: Sites with Recontamination

  • Anacostia River, DC

  • Bloomington, IN

  • Convair Lagoon, CA

  • Denny Way Cap, WA

  • Duwamish Norfolk CSO, WA

  • Duwamish/Diagonal CSO, WA

  • Eagle Harbor, WA

  • Ford Outfall/River, MI

  • Fox River SMU 56/57, WI

  • Housatonic River, MA

  • Lauritzen Canal, CA

  • Long Beach North Energy Island

  • Borrow Pit, CA

  • Pier 51 Ferry Terminal, WA

  • Pier 53-55, WA

  • Pier 64-65, WA

  • Puget Sound Naval Shipyard

  • Pier D, WA

  • Sitcum Waterway, WA

  • St. Clair Shores, MI

  • Thea Foss Waterway, WA

(Nadeau and Skaggs, 2008)


  • Complex relationships

    • PRPs, agencies, public

  • Agency funding to address sources

  • Lack of guidance

    • Approaches differ among sites

    • How do we know we’re ready to remediate?

    • How much source control is enough?

  • Technical feasibility and implementability

AOCs Address Source Identification Differently

  • Portland Harbor

    • Respondents will identify source areas that are contributing to contamination to the in-water portion of the Site

  • Lower Duwamish Waterway

    • No source identification task in AOC/SOW; does require documenting investigations of sources in Phase I RI (using existing data)

    • Slip 4 Agreed Order: EPA to ensure sources are adequately controlled prior to construction to minimize the potential for recontamination

Some Sites Have Source Control Remedial Action Objectives

  • Coeur d’Alene Basin

    • Reduce loadings of metals from soil/source materials to surface water so that loadings do not cause exceedances of surface water PRGs

    • Prevent transport of metals from soil/source materials to groundwater

  • Hudson River

    • Minimize the long-term downstream transport of PCBs in the river

Responsible Party Sensitivities

  • Preference to address source control where risks are unacceptable

  • Potential for expanded liability

    • Site expansion beyond “top of bank”

    • Upland site cleanup

    • Upriver or watershed cleanup

  • Cost to control someone else’s sources

  • Potential for focusing attention on own facility

  • Risk

Striking the Balance

  • Progress with source identification/control

  • Initiating remedy implementation versus more source control

  • How much recontamination is OK?

  • Adaptive management

    • Remedy implementation

    • Monitoring

Slip 4 Case Study: Remedial Planning and Source Control Timing Not Aligned

Sediment Cleanup Milestones

Investigation completed - 2004

Remedial design approved - 2007

Community enthusiastic

Responsible parties committed

Sources not adequately controlled

Slip 4 Early Action Area

PCBs in Surface Sediments

PCBs in Subsurface Sediments

Proposed Removal Action Boundary

Slip 4 Drainage Areas

Georgetown Steam Plant

King County Airport

Slip 4

North Boeing Field

Source Control: A Simplified History

1980s, 1990s

Extensive investigations

Some NBF storm drain lines were cleaned

Georgetown Steam Plant flume was cleaned


Contamination returned to the storm drain system and flume

Source Control Action Plan (2006)

Sampling by City, County, Boeing

Flume decomissioning (2009)

Slip 4 Source Control Today

  • Slip 4 Source Control Work Group

    • EPA, Ecology, City of Seattle, King County

  • City of Seattle

    • Business inspections in drainage basin

    • Catch basin solids sampling

    • In-line sediment traps

    • GTSP Flume demolition

  • King County

    • Inspections and sampling

  • Boeing

    • Catch basin solids sampling

    • Removal of contaminated joint caulking

EPA Perspective

  • Sources to Slip 4 not adequately controlled to prevent recontamination

  • Implementing PRPs (City and County) agreed with EPA’s conclusion

  • Slip 4 cleanup put on hold

Community Perspective

Community understands the options


Fully evaluate sources

Avoid recontamination

Habitat is important

Remediate only once

State Agency Perspective

  • Limited funding options and mechanisms

  • Just two full-time employees to address sources at the entire Lower Duwamish Waterway CERCLA site

Recent State Actions

  • Ecology issued an Agreed Order under MTCA to upland parties for RI/FS within drainage basin

  • Funded by City of Seattle, King County, and Boeing

  • Ecology is conducting an accelerated source control program

  • Clearly articulated decision framework still needed

Policy and Schedule

  • Agency and PRP senior policy managers commit to expediting source control to move cleanup forward in fall 2011

  • Must determine whether stormwater treatment is needed by December 2010

  • Accelerated source evaluation/control program being implemented by the state

Results of Source Control Delays

Cleanup delayed

Budget projections outdated

Significant pressure to prevent recontamination of Slip 4

Contamination remains in place

Lessons Learned

  • Prioritize source control

  • Understand sources and transport processes

    • Build into CSM during investigation

    • A CSM makes progress predictable, measurable

  • Define measures of success

  • Risk management decisions sometimes must occur in spite of uncertainty

  • Apply principles of adaptive management

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