Tru-Grit Remedial Action (Parcel 115) 2026

STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
IN THE MATTER OF AN ) ADMINISTRATIVE ORDER
ADMINISTRATIVE ORDER ) DOCKET #23535
AGAINST )
Port of Tacoma )
Anita Fichthorn )
To: Anita Fichthorn
Port of Tacoma
PO Box 1837
Tacoma, WA 98401-1837
Order Docket # 23535
Site Location 3401 Taylor Way, Tacoma, WA 98421
The Washington State Department of Ecology (Ecology) has issued this Administrative Order (Order)
requiring the Port of Tacoma to comply with:
* Chapter 90.48 Revised Code of Washington (RCW) - State of Washington Water Pollution
Control Act.
* Chapter 173-201A Washington Administrative Code (WAC) - Water Quality Standards for
Surface Waters of the State of Washington.
* Construction Stormwater General Permit WAR314131: National Pollutant Discharge Elimination
System (NPDES) and State Waste Discharge General Permit for Stormwater Discharges
Associated with Construction Activity.
This is an Administrative Order (Order) in accordance with General Condition G12 (Additional
Monitoring) as set forth in the Construction Stormwater General Permit. RCW 90.48.120(2) RCW
authorizes Ecology to issue Administrative Orders to accomplish the purposes of Chapter 90.48 RCW.
This Administrative Order replaces all previous versions of Administrative Order number 23535.
ORDER TO COMPLY
Port of Tacoma (Permittee) is subject to coverage under NPDES Construction Stormwater General
Permit WAR314131 for construction activities associated with the construction site known as Port of
Tacoma Parcel 105 Dredge Material Management Project. The Permittee reported that the site will be
managing contaminated dewatering water that has the potential to cause a violation of Water Quality
Standards. The Construction Stormwater General Permit does not have water quality sampling or
benchmarks for Arsenic, Cadmium, Chromium, Copper, Zinc, Benzo(a)anthracene,
Benzo(k)fluoranthene, Pyrene 1,2,3,4,6,7,8,9-Octachlorodibenzo-p-dioxin (OCDD) and 1,2,3,4,6,7,8-
Heptachlorodibenzo-p-dioxin (HpCDD); however, the permit requires compliance with the Water Quality
Standards for Surface Water of the State of Washington (Water Quality Standards).

Administrative Order # 23535
September 16, 2026
Page 2
The Order establishes Indicator Levels for the Port of Tacoma Parcel 105 Dredge Material Management
Project. Indicator Levels express a pollutant concentration used as a threshold, below which a pollutant
is considered unlikely to cause a water quality violation, and above which it may. Indicator Levels in this
Order were derived from the Model Toxics Cleanup Act (MTCA) Method A Cleanup Level
for Groundwater (WAC 173-340-900), the Freshwater Human Health Criteria, National Toxics Rule (40
CFR 131.36)], MTCA (WAC 173-340-747), Ecology's portioning coefficient from their 3-phase soil to
groundwater model (EQ747.1 with no dilution) and practical quantitation level.
For these reasons, and in accordance with RCW 90.48.120(2), it is ordered that the Port of Tacoma take
the following actions. These actions are required at the location known as Port of Tacoma Parcel 105
Dredge Material Management Project, located at 3401 Taylor Way, Tacoma, WA 98421. In the event of a
permit transfer to another Permittee, compliance with this Administrative Order and the actions listed
below is required.
Port of Tacoma must take the following actions to remain in compliance with NPDES Permit
WAR314131:
* Pump dewatering water from dredged material into a series of Baker Tanks directly from
transport barges.
* Install all pre-treatment and treatment systems prior to any discharge of dewatering water or
contaminated construction stormwater.
* Capture, contain, and treat all contaminated dewatering or contaminated stormwater prior to
discharge from the project area.
* Obtain written approval from an Ecology Environmental Engineer for any proposed treatment
system. Ecology must be notified in advance if any changes in the treatment are made, except
for routine maintenance.
* Contain and remove any and all contaminated dredge spoil during the life of the project.
Further:
* The treatment system must have enough capacity to hold the potentially contaminated
dewatering water or stormwater until it has been tested to determine if any of the Indicator
Levels listed in Table 1 have been exceeded. No potentially contaminated dewatering water or
stormwater may be discharged before it has been tested for the parameters listed in Table 1. If
any of the Indicator Levels listed in Table 1 are exceeded, you must stop the discharge of
potentially contaminated dewatering water or stormwater until it has been retested to
determine that all parameters are equal to or below the Indicator Levels in Table 1. If any of the
Indicator Levels are exceeded after being retested, install additional treatment capacity.
* Once the effectiveness of the treatment system has been determined, you may revert to a flow-
through treatment system after the minimum three sampling and testing events and upon written
approval from Ecology. The flow-through treatment system design must be submitted to Ecology
for review prior to use.

Administrative Order # 23535
September 16, 2026
Page 3
* If a flow-through treatment system is adopted, all dewatering water or contaminated stormwater
must be sampled weekly while discharging and tested for the parameters listed in Table 1.
* When using a flow-through treatment system, if any of the Indicator Levels listed in Table 1 are
exceeded, stop the discharge of dewatering water or stormwater from the project location until
it has been retested and determined that all parameters are equal to or below the Indicator
Levels in Table 1. If any of the Indicator Levels are exceeded after being retested, modify the
existing flow-through treatment system to increase its effectiveness, install an Ecology-approved
treatment system, or truck the contaminated stormwater or groundwater off-site for disposal in
an approved manner.
* Report sampling for the contaminants listed in Table 1 on the required Discharge Monitoring Report
(DMR) according to Permit conditions (S5.B Discharge Monitoring Reports).
* If sampling is conducted more frequently than required by this Order, include the results of this
monitoring in the calculation and report the data that is submitted in the DMRs.
* Immediately report any discharge to waters of the state above the Indicator Levels to the
Department of Ecology.
* Transport all captured sediment from the treatment of the dewatering water or contaminated
stormwater to an approved disposal facility based on the level of contamination.
* Immediately haul offsite contaminated soils excavated during construction without stock piling to
an approved disposal facility based on the level of contamination. When it is not feasible to
immediately haul soils offsite, place the soils on an impermeable surface and cover with plastic
sheeting to minimize contact with stormwater.
* All monitoring data must be prepared by a laboratory registered or accredited under the
provisions of Accreditation of Environmental Laboratories, Chapter 137-50 WAC.
* Report all sampling data monthly on DMRs electronically using Ecology's secure online system,
WQWebDMR, in accordance with permit condition S5.B. If the measured concentration is below
the detection level, report single analytical values below detection as "less than the detection
level (DL)" by entering "<" followed by the numeric value of the detection level (e.g. "<0.1"). All
other values above DL must be reported as the numeric value.
* Immediately report noncompliance with permit requirements or the provisions of this Order to
the Southwest Region Office of the Department of Ecology in accordance with Permit Condition
S5.F, Noncompliance Notification.
* Fully implement your Stormwater Pollution Prevention Plan (SWPPP) for the duration of the
project. Amend the SWPPP as needed.

Administrative Order # 23535
September 16, 2026
Page 4
* Submit a written request to Ecology if a modification of the Order is desired. If approved,
Ecology will issue an amendment to this Order.
Ecology retains the right to make modifications to this Order through supplemental Order, or
amendment to this Order, it if appears necessary to further protect the public interest.
This Order does not exempt the Port of Tacoma from any Construction Stormwater General Permit
requirement. This Order automatically terminates when NPDES Construction Stormwater General
Permit WAR314131 is terminated.

Administrative Order # 23535
September 16, 2026
Page 5
Table 1.
Port of Tacoma must use the specified analytical methods, detection limits (DLs) and quantitation levels (QLs) in the following table for
monitoring unless the method used produces measurable results in the sample and EPA has listed it as an EPA-approved method in 40 CFR Part
136.If the Port of Tacoma uses an alternative method, not specified in the order and as allowed above, it must report the test method, DL, and
QL on the discharge monitoring report.
Pollutant & CAS No. (if available) Sampling Sample Indicator Required Detection Quantitation Level
Frequency* Type Level, g/L Analytical Level value value stated in
unless Protocol stated in, g/L, unless
otherwise g/L, unless otherwise noted
noted otherwise
noted
METALS
Arsenic, Total (7440-38-2) Batch/Weekly Grab 69 b 200.8 0.1 0.5
Cadmium, Total (7440-43-9) Batch/Weekly Grab 42.25 b 200.8 0.05 0.25
Chromium, Total (7440-47-3) Batch/Weekly Grab 1100 c 200.8 0.2 1.0
Copper, Total (7440-50-8) Batch/Weekly Grab 5.78 b 200.8 0.4 2.0
Lead, Total (7439-92-1) Batch/Weekly Grab 220.82 b 200.8 0.1 0.5
Zinc, Total (7440-66-6) Batch/Weekly Grab 95.14 b 200.8 0.5 2.5
POLYCYCLIC AROMATIC HYDROCARBONS (PAHs) AND CARCINOGENIC PAHs
Benzo(a)anthracene (56-55-3) Batch/Weekly Grab 23.4 a 625.1 7.8 23.4
Benzo(k)fluoranthene (207-08-9) Batch/Weekly Grab 7.5 a 610/625.1 2.5 7.5

Administrative Order # 23535
September 16, 2026
Page 6
Chrysene (218-01-9) Batch/Weekly Grab 7.5 a 610/625.1 2.5 7.5
Fluoranthene (206-44-0) Batch/Weekly Grab 6.6 a 625.1 2.2 6.6
Pyrene (129-00-0) Batch/Weekly Grab 5.7 a 625.1 1.9 5.7
Construction Stormwater General Permit Benchmarks
Parameter Sampling Sample Benchmark Analytical Method
Frequency* Type
Turbidity Batch/Weekly Grab 10 NTU SM2130 c
pH Batch/Weekly Grab 6.5 - 8.5 SU SM4500-H+ B
NOTES
a No applicable surface water criterion; value is laboratory quantitation level.
b Acute - Marine Water Toxic Substances Criteria (WAC 173-201A-240) calculated
using conversion factors per Table 240.
c Or equivalent.
d Indicator Level total chromium is actually for hexavalent chromium using Acute
-Marine Water Toxic Substances Criteria (WAC 173-201A-240) because there is
no water quality standard for total chromium.
* If permission is granted for flow through, sampling will then be weekly.

Administrative Order # 23535
September 16, 2026
Page 7
FAILURE TO COMPLY WITH THIS ORDER
Failure to comply with this Order may result in the issuance of civil penalties or other actions, whether
administrative or judicial, to enforce the terms of this Order.
YOUR RIGHT TO APPEAL
You have a right to appeal this Order to the Pollution Control Hearing Board (PCHB) within 30 days of
the date of receipt of this Order. The appeal process is governed by Chapter 43.21B RCW and Chapter
371-08 WAC. "Date of receipt" is defined in RCW 43.21B.001(2).
To appeal you must do both of the following within 30 days of the date of receipt of this Order:
* File your appeal and a copy of this Order with the PCHB (see addresses below). Filing means
actual receipt by the PCHB during regular business hours.
* Serve a copy of your appeal and this Order on Ecology in paper form - by mail or in person (see
addresses below). Email is not accepted.
You must also comply with other applicable requirements in Chapter 43.21B RCW and Chapter 371-08
WAC.
Your appeal alone will not stay the effectiveness of this Order. Stay requests must be submitted in
accordance with RCW 43.21B.320.
ADDRESS AND LOCATION INFORMATION
Street Addresses Mailing Addresses
Department of Ecology Department of Ecology
Attn: Appeals Processing Desk Attn: Appeals Processing Desk
300 Desmond Drive SE PO Box 47608
Lacey, WA 98503 Olympia, WA 98504-7608
Pollution Control Hearings Board Pollution Control Hearings Board
1111 Israel Road SW PO Box 40903
Suite 301 Olympia, WA 98504-0903
Tumwater, WA 98501

Administrative Order # 23535
September 16, 2026
Page 8
CONTACT INFORMATION
Please direct all questions about this Order to:
Evan Wood
Department of Ecology
Southwest Region Office
300 Desmond Drive SE
Lacey, WA 98503
Phone: 360-706-4599 Email:
Evan.Wood@ecy.wa.gov
MORE INFORMATION
* Pollution Control Hearings Board Website
www.eho.wa.gov/Boards_PCHB.aspx
* Chapter 43.21B RCW - Environmental Hearings Office - Pollution Control Hearings Board
http://apps.leg.wa.gov/RCW/default.aspz?cite=43.21B
* Chapter 371-08 WAC - Practice and Procedure
http://apps.leg.wa.gov/WAC/default.aspx?cite=371-08
* Chapter 34.05 RCW - Administrative Procedure Act
http://apps.leg.wa.gov/RCW/default.aspx?cite=34.05
* Laws: www.ecy.wa.gov/laws-rules/ecyrcw.html
* Rules: www.ecy.wa.gov/laws-rules/ecywac.html
SIGNATURE
Andrew Kolosseus Date
Southwest Region Section Manager
Water Quality Program