poisoned waters

Steve Tochko

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He is an environmental remediation manager for Boeing, and works on the company's cleanup of Plant 2 on the Duwamish River in Seattle. This is the edited transcript of an interview conducted on Sept. 12, 2008.

“What do people expect from the Duwamish River? If people expect it to be … pristine, that's not going to happen.”

What was this plant historically?


The plant was built in the 1936-39 time period. It was built for production during World War II. The main thing we built were B-17 bombers. … It was a major facility where they manufactured the parts, produced the aircraft and delivered them on Boeing Field. ... They produced about 12,000 aircraft here. ...

... We are looking at what people call legacy pollutants. ... What are legacy pollutants?

The term "legacy pollutants" is historical practices. What was acceptable in the '40s and '50s, we would find very objectionable today. ... People did not know the damage that some of these materials caused at the time. They did not know the long-term effects of them that we do today. ...

... I've talked ... with the Washington [state] Department of Ecology, and they talk about people treating the Duwamish River as sort of an open sewer. ...

It's not atypical of any river in America. There was a lot of industrial activities that were concentrated out on the rivers in America. The Duwamish is not an exception to that. To say it was a sewer, that's a characterization. To say that people did not use it the way we would use it today, they were not stewards like we are looking at the river today, that's probably a fair statement. ...

If you were to ask your parents or your grandparents how were chemicals handled in the past, ... they would tell you a much different story than you see today. They didn't have hazardous waste roundups. They didn't have people concerned about what goes on in the sewer. They didn't see people cleaning catch basins and sewer lines. …

From Boeing's perspective, when does the problem of the contaminants here become not just known but a problem you've got to deal with? ...

Like the rest of the nation. The EPA [Environmental Protection Agency] came into being in the '70s. There was more of an environmental movement. Here in Puget Sound, people were woken up by Lake Washington. ... When Lake Washington died, people really got concerned about it. Instead of dumping sewage into Lake Washington, they started building treatment plants. ...

So for Boeing, starting in the '80s, the group that I work for was formed. We began doing active cleanups starting [around] 1985, and we've been working on it ever since. Boeing has demonstrated that we're trying to get some of these legacy situations dealt with. ...

[Initially you were aware of one major pollutant at this site, PCBs, and today there are 40 or so on the list. Are those pollutants themselves new, or is it just that our knowledge of the problem has expanded?]

First, the PCBs weren't the first thing we discovered. The reason why we are investigating this facility is environmental law [requires] of the people who handle hazardous chemicals and hazardous materials that they conduct an investigation, see if there are legacy problems. And as part of that, that's what started the investigation here at Plant 2. And then part of that is we started looking at all the known places where chemicals were handled.

There are several areas -- there were storage areas; there were wet-chemical-processing areas. And we looked at those, and that's what started the investigation. ...

We knew about PCBs because when we were working in transformers. We understand how transformers were dealt with, and we saw that there had been releases to the river. So the releases to the Duwamish River were known, but historically there have been other operations here, like degreasing and painting, and we knew that those activities had caused releases and that PCBs were just part of a bigger [problem]. ...

So once all the areas are identified, then you put together a comprehensive plan of how you are going to remediate that. ...

[You said you started working on this in 1985. Why is it taking so long?]

... One of the things that it's important to understand is that there is a complicated regulatory process that all of these sites go through. And it is very frustrating and it is very difficult to explain to people who are on the outside saying, "Well, why is this taking so long?" And it's frustrating to us as environmental professionals that it takes a long time to go through the processes that our environmental regulatory framework have created.

If it was up to Boeing and up to me as an individual, we would be out cleaning the river today. But just to give you an example, it's going to take 14 to 18 months to get a permit to dredge the Duwamish River. We're going to start that process in January, and hopefully we'll be dredging by next time you come up here. ...

Somebody told me that Boeing had a cleanup plan for the sediment in the riverbank a decade ago.

That's correct. ... We submitted a plan to EPA in 1999 to dredge -- we call it an interim measure -- to take what is adjacent to Boeing and excavate that material from the river.

The complicating thing is that our environmental laws are a very open process. There is a lot of dialogue and a lot of public process, and so it's taken us time to get through that. And the decision that has been made over time is that an interim measure isn't probably what we want to do. We want to make sure that we get it all at one time. And then we want to look at other factors in the river, and by doing that it kind of has dragged the process on.

Now, one of the things that's important in the river is that ... two to three months during the winter is the only time we can work in the river because of the salmon window -- the fish window, we call it -- which is when the salmon are migrating. ... So during the October/November/December/January time frame is the only time the migratory species are not moving.

You make it sound as though there is quite a lot of back-and-forth between Boeing and the EPA about whether or not whatever plan you have submitted is sufficient. ...

And that is the classic dilemma of environmental regulations in America, is how clean is clean? It's a very difficult concept. There are numerical cleanup levels, but then there is risk-based cleanup levels and there's political cleanup levels, and it's very hard to figure out what is going to be acceptable to the community, what is going to be the best thing for all parties. Coming to a cleanup level and agreeing on a boundary is sometimes more difficult than it would appear.

... We went out next to this plant near the river, and there are just scads of holes [where you've dug to test soil samples]. ...

There's over 500 sampling locations at this facility that have been drilled over time.

If you came here 10 years [ago], how many would there have been?

Fifty.

So hundreds more have been drilled since because of this back-and-forth with the EPA.

That's correct, yeah. … Everything needs to be fully bonded before we can start this investigation, and I think it's part of the process where we are trying to do one final remedy, we're going to do once and for all. I think it would be more in a lot of people's best interest if we took an interim approach, where we were able to do interim measures and clean it up in increments. ...

Is this exasperating you, this kind of back and forth with the EPA?

Yeah, it's a challenge, but I think the end results are worth it. ... We want this to be a better place. We want the Puget Sound area to be a place where we can have employees, that people want to come and work here. Boeing is very committed to this. ...

I'm trying to imagine this thing about the interim measures here. You are saying to EPA: "Look, we have found enough stuff. Here is a section; we can clean it up. Let's do it." ...

That is exactly it. You summed it up very well in saying that: "Here is an area that we can take on right now." ... [The EPA] allow[s] interim measures under their guidance, but ... they feel very uncomfortable that they may be second-guessed by the public, that there are people that want more. A good example is here at Plant 2, where people want to consider residential use for the facility we are sitting in today. People can say, well, maybe someday this will be a residential facility. That's not in anybody's planning. This is an industrial complex. It's in an area that is zoned industrial, and the cleanup levels should be appropriate to be industrial. ...

So you're saying the real standard for cleanup should be to that industrial level?

Yeah, I can't see residential use here, personally. We're adjacent to an airport; we have rail transportation. This area is very valuable industrial property. If you were to tour the Duwamish River and you would start at Harbor Island and you work your way up, you are going to see how many, many industries in Washington depend on the Duwamish River as a very valuable economic engine for this community. ...

You balance it with treating nature respectfully. We have habitat projects that improve that. We have a habitat for wildlife, migratory wildlife that goes through the system. We have an area that ... the community has public access to, and it's vibrant. That's what needs to happen in the Duwamish. ... All those things need to be blended together. ...

What are Boeing's ultimate plans for this plant? ...

... I don't think the ultimate disposition has been determined. I know it's going to get demolished. It's going to be redeveloped. ...

What is it you're proposing to the EPA that you do with the contaminated sediment, the riverbank, this old building? ...


Where we are is, we pretty much have agreed on what has to be done as far as a sediment project. But we've decided as part of this to do a kind of a comprehensive shoreline restoration, so when we go out on the river to clean up the sediments, we'll be restoring the bank. We'll be demolishing the parts of this building that will be hanging over the river so that we can get more of the sediment out. We can do a better job so basically we'll have a clean sediment, and then we'll have a habitat project.

And one of the things that we have agreed to, with the natural resources trustees, which are the people like NOAA [National Oceanic and Atmospheric Administration] and U.S. Fish and Wildlife and Washington Fish and Wildlife, is to do some project enhancements to improve the fish habitat in the river. One of the things we're going to do is up in the north end of the facility, we're going to build what's called off-channel flow. Off the main flow of the river is a quiet estuary where salmon can adjust to the transition from saltwater to freshwater. ... Two-thirds of a mile of the river will be relatively fish-friendly, and then the habitat project itself will be something of an enhancement that will make the river much better in the future. ...

The habitat project is something that we are creating as a kind of legacy. The shoreline buffer and the habitat project, that will remain virtually forever. Boeing has agreed that we are going to give up our waterfront use of the property, and so for the first 200 feet or so around the river that will be a natural buffer.

Then redevelopment will take place beyond that. We've had discussions with the city of Tukwila. This is in their master plan to be an industrial facility. ...

[Why has the area called Slip 4 specifically been so contentious between you and the state Department of Ecology?]

... Slip 4 is a former meanderer of the Duwamish River. It's an area that's used for industrial barge traffic, but it also is an area where a lot of stormwater, a very large part of the Duwamish drainage basin, comes into the system. There is a lot of industrial activities that go on there; ... all that water comes into the slip.

There are a lot of urban contaminants; there are PCBs. Those PCBs, the source of those is a soil-based issue.

I gather Boeing and the city don't agree on what the sources are. ...

At the current time, yeah. But I think we'll work that out. Over time, science is going to show where those PCBs have come from. We don't believe that we have those kind of activities that would generate the kind of PCB volumes that we see. ...

The city guys say the same thing: "We looked at our transformers. ... It's got to be coming from Boeing's side of the fence."

They're entitled to their opinion, and I think it's very important to understand that there is some legal context to that, and I think that's something that we'll resolve in the future.

Legal context meaning that the city has filed suit.

That's correct.

And that means?

That there is ongoing litigation. …

We talked to the Department of Ecology, and they said they finally stepped in and said they were going to do the investigation because the parties couldn't get together.

I think that might be an oversimplification. I think we -- the parties, the city, the county and Boeing -- went to the Department of Ecology and said we think the best way for you to do this is for you to handle the project so that we could do it more streamlined. ...

We knew that the state was going to issue an order to do this work. And historically, Boeing has taken a proactive approach, and we have typically managed these PRP [potentially responsible parties] groups to get cleanups done. ...

[A PRP is] a polluters group? ...

Yeah. Boeing, the city, the port, the county were working together to consolidate our efforts and work as a technical group to respond to the agency requests. …

... Can you say that the work done in recent years, during a period of some dispute among the parties, has actually led to some significant improvement? ...

Most definitely. And I think if you were to look and you were to see who's doing most of that work, it's Boeing. I think Boeing has taken the initiative to try to reduce the material going to Slip 4. Not all of the drainage on that area is Boeing. There is drainage that comes across Boeing Field, that flows through our property and goes into the slip. We just happen to be the last person before it goes into Slip 4.

And so we looked at where this material is coming from, and we know that there is soil out there that contains PCBs. We know that we did not have anything large enough to generate that kind of volume of soil to be contaminated. We know that soil was getting into the storm drain system, so we took the proactive approach to get the soil out. ...

The soil part of it has been resolved. Where the soil contamination came from, that's the $1,000 question. …

There was kind of a mystery at one point as to where some of the PCBs were coming from in terms of Boeing's own operations. What was the mystery, and what was the solution?

... We have a lot of flight-line areas, large, concrete, paved areas, that have expansion joint material between the concrete panels. There was a material that was used by Boeing and other industries and in the late '60s, early '70s that contained very high levels of PCBs. ... Looks like tar but it's actually a rubbery polymer. In the '60s and '70s, that material contained PCBs in it to make it more durable to sunlight and easier for it to be installed.

And how were they getting into the environment?

... What we have found is that most of the material that gets washed off is soil particles that have come in contact with the joint compound, and so by flushing out the storm drain system, that removes that material from the flight line. When we do catch-basin cleaning, you will see sediment in the catch basins. That material contains some PCBs in it. ...

We found 50 miles of this material throughout our facilities. At North Boeing Field, there's about six miles of PCB joint compound that have been removed. It's a very labor-intensive issue where we go in there. We saw the joints out, remove the PCBs and replace it with PCB-free material.

Big job.

It's a big job, and it took us seven years to complete, and now it's part of our regular routine of replacing joint material.

... How much money has Boeing spent over the past decade or so?

… The joint compound has been about a $12 million program for Boeing. It's part of our ongoing environmental liability, and it's something that we handle as part of our course of business. ...

We spend in the range of $30 to $50 million a year. ... The company's long-term reserves are several hundred million dollars ... for all of Boeing's remediation liabilities. ...

But by the time this thing is done, you get the place cleaned up and you put it in the habitat you were talking about, how much more are you going to spend?

By the time we get in all these projects and we kind of look at the whole Duwamish [River] area, we'll probably look at about $80 million. ...

So total, $130 million ballpark.

That's correct.

And how many years?

The cleanup of the river, the cleanup of the sediments and the habitat project are currently planned for the fish window of 2010, 2011, so that would be December 2010, January 2011. ...

The way the environmental framework is in the United States is that when people do cleanups like this, there is normally a post-closure monitoring period that goes on for 30 years. ... So at Plant 2 we're in the process of we'll do the river cleanup in 2010. At that point we should have most of the site also cleaned up, and so we will be into this 30-year monitoring period.

... Are Boeing and the EPA on the same wavelength on how clean is clean and what the cleanup standard will be?

I don't think at the time that we are. ... But I think the real issue here is, what is the scenario for the river? What do people expect from the Duwamish River? If people expect it to be pristine, expect it to be predevelopment time, that's not going to happen. If we were to clean up the river, if we were to remove every molecule of PCBs, within a year it would be recontaminated to a certain level. We call it background. I think there's an expectation that we're going to be able to go below background, and I don't think that's going to happen.

And so I think [what] people need to understand is that there are going to be certain uses of the Duwamish River that aren't going to be possible in the future. I'll give you an example. I don't think people are going to be able to subsistence fish out of the species that are in the Duwamish. I think you will be able to eat recreational volumes of fish, you will be able to crab there, you will be able to clam there, but you're not going to be able to get all of the seafood that you eat in a lifetime out of the Duwamish River. That's where there is some disagreement. ...

I think we have to set reasonable expectations for cleanup in industrial areas. I don't think that you can say it's going back to zero. I think there is going to always be some urban contamination. ... Whether it be PCBs, whether it be arsenic, whether it be carcinogenic pHs, these materials are in the environment. … We stopped using PCBs in 1980, and they are still in the environment. It's going to take time, and they'll come out, but if you want no carcinogenic pHs, we're going to have to change the way we build automobiles; we're going to have to change the way we use plastics, arsenic. …

... Do you think in the riverbank area just beyond this plant that you're going to see shellfish growing again or not?

No.

You don't think that's possible.

No, no. I think that people's expectations need to be adjusted. One of the things that people just don't understand is that when we go in here and we do these cleanups, we're going to disturb the natural environment.

When we're done it's going to be clean; that's true. But also, there's not going to be any biological organisms. When you remove sediment, the material you put back is sterile. It's kind of like potting soil that you buy at the grocery store or the Home Depot. All of the natural organisms are usually removed so that there's no weeds or anything. This is going to be the same way when we replace the sediment. There's not going to be the thriving community that's out there right now.

And when you do that, it's going to offset the balance in the river, and I think people need to understand that it's not going to be a really thriving community for many generations. ...

People talk about the tribal risk level -- meaning the exposure of Native American tribes who eat a lot of fish -- to eating fish and crabs and shellfish from the Duwamish. They say it should be safe enough for people to have their normal consumption. ...

I don't disagree with that; I just don't think that they eat that much seafood from the Duwamish. The assessment tools that we're using -- we call it the Food Web Model. The way the Food Web Model is, it relies on some unscientific surveys of what people can actually eat. ... Scientists on both sides can disagree. I think that that model needs to be looked at. I don't think that when we talk about consumption rates in the river, we don't think you can eat all of it from the Duwamish, but we also don't think the Duwamish is a healthy enough estuary. I don't think it's ever going to be a healthy enough estuary to produce those kind of fish volumes. ...

What happens if the EPA and Boeing and the city and the county and the port can't agree on a standard? How does that get resolved?

The framework in the U.S. law is that there is a deference given to the scientists from the Environmental Protection Agency and that at some point there will be a mediated dispute and it will be resolved.

… So what you're saying is, ... when all is said and done, the EPA scientists are going to be the ones that are going to call the shots.

That's pretty much the case -- or a federal judge. And a lot of these things are resolved in judicial proceedings. ... We hope to not get there. That's not where we want to be. We want to try to tell people that we are doing the best we can. We're making a reasonable or even what I would consider a better than reasonable attempt to restore the river to a better condition.

I don't think it's reasonable to expect that Boeing as an industry or even King County as the government or the city of Seattle or the Port of Seattle can be the ones that [are] going to suddenly restore the river. I think it's more a community-wide thing. I think [if] people want to see waterways restored like this, there are other things that have to take place.

We have to change the way we develop. ... [The Cascade Agenda] talks about sensible development. It talks about stormwater. All of those things are part of the thing that make the river better. We can do cleanups for the issues that are attributable to us, and that's really reasonable, and that's the way it should be. But when it comes to global issues in the river, it's a bigger deal, and it needs to be treated on a wider community. ...

... Do you see local activists as helpful, as a nuisance? ...


I think it's a vital part. ... It's very important to have them factor into what we do at different sites. And it's good to see a very vibrant community.

The issue is there needs to be a balance. And I think what we are seeing in this area is that the EPA is giving a lot of preference to the public community. ...

It's also important to have the industrial users, the marine applications, to hear their point of view, and I think we have not heard that as much till right now.

It's important to hear what the people in the state of Washington want. The people in the state of Washington are paying a large part of the cleanup of the Duwamish. It's being paid for by taxes. ...

And the question we all have to ask ourselves is, are we spending the right money? Is this where we should be spending our money? Is it important to have a river that's very clean, while other parts of Puget Sound might not be getting that attention? It's a decision that I think [the Department of] Ecology and EPA need to look at. ...

... If the EPA insists on a standard which Boeing and others regard as unreasonable, I gather you're prepared to go to court to challenge that.

I can't answer that at this time. I think what we really need to do is we really need to see the standard. I think the most unfortunate thing would be to have a standard that can't be met. …

Our scientists tell us that the river is going to recontaminate. There is material coming downriver, coming from the Green [River] system, coming from upstream that is going to recontaminate the river. ... The river is going to come back to a certain number. We think that's higher than what the EPA thinks it is, and so history will bear us out. We will do the cleanups that are necessary. We will take the appropriate steps, but the river is going to recontaminate. ...

What's the difference between what you proposed in 1999 and what you have done to date and propose to do when the EPA gives you a go-ahead?

... [I]nitially we talked about excavating a certain amount of material and putting what we call an engineered cap down. Since that time, ... what we have been able to do is say, OK, there are certain areas that we can actually take out less material because it's less contaminated. There are areas now that we know that have more material that are deeper, and we're going to get those deeper areas. So now we have instead of having what we called a uniform cleanup, we now have what is called a variable depth. So now this variable depth will remove more PCBs from the environment.

And the good news is that by removing those, we don't have to have an engineered cap. We would have more of a sand backfill. Now, what's the difference between those two? Well, when we did the project down at the developmental center which is upriver, we had to put down a carbon mat which helps absorb PCBs because we couldn't get all the PCBs out of the rocks. Things like the carbon mat, [other] things like that won't be necessary with the new cleanup. ...

... So if you look back at what you planned to do in 1999 and what you've done since ... what's the gain? Is there a gain?

There has definitely been a gain. We have spent a lot of money, and we have had progress, and I think the best way to kind of talk about the progress is talk about some of the improvements and some of the things that are now in our plan that weren't in the plan earlier. So we have the habitat project; we have an agreement with the resource trustees to find a way to improve the habitat in the river. That's been a big gain.

We've also had this time to remove some of the areas that have impacted the river, so we've removed some storm drain lines. We have removed things as the site has started to go to redevelopment. We have started to clean up areas, and we have had almost 20 interim measures to clean up the soil hot spots. There has been a lot of work done. ...

The issue is that it's not a uniform plan. … We have a better plan to clean up the river, better than the plan in 1999, yes, but we're still not to the point where we have EPA saying, "If you do this, it's going to be done." And that's the issue, is that the process is continuing to grind on. ...

... What you're saying is the scope of the work has been expanded since that plan of yours in 1999. The question is why? Is it just Boeing, or has EPA pressured to do more? …

There's been a lot of reasons why the scope has changed. ... Part of it is the body of knowledge and the results of the data we collect; we call it discovery. But it's also changed because there have been changes in the regulatory agencies. There have been changes in the overall approach to the project, and some of those approaches have been rather significant. There have been multiple EPA project managers. The projects here, just to give you an example, are further behind than other Boeing projects that have started the same time period. So Plant 2 is lagging behind for some reason.

[Does turnover in EPA project managers slow things down?]

Yeah, when we get a new EPA project manager, their history is different, and they manage the project slightly different. ... It's a challenge for us, and it's very difficult when a new person comes in. We'll lose a few months bringing them up to speed, and they may have a different philosophy about where we are going, and the environmental regulations are such where that can steer the project. And we've been through many project managers here at Plant 2. ...

posted april 21, 2009

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