Discharge Elimination System (NPDES) permit and an administrative order issued by the Washington State Department of Ecology (Ecology), which required the construction of a new outfall. Encouraged by Ecology to address several environmental problems at the same time, Simpson began in 1986 to investigate and implement better control of sources of pollution at the mill and, together with Champion International Corporation (who acquired the mill as a result of a merger with the St. Regis Corporation shortly before its sale to Simpson), to plan remedial action for the contaminated sediments. This remedial action planning for the St. Paul Waterway Problem Area proceeded in parallel with the federal remedial-investigation/feasibility-study (RI/FS) process for the Commencement Bay Nearshore/Tideflats Superfund site.

The project was the first completed Superfund cleanup in U.S. marine waters and the first natural-resource damages settlement in the United States without litigation and with all federal, state, and tribal trustees (EPA 1991). It addressed tribal fishing rights, Section 404, Endangered Species Act, Coastal Zone Management, and Growth Management issues, as well as sediment cleanup.

Strategy Chosen

Before proposing any actions, Simpson and Champion consulted with the Puyallup Tribe; environmental groups and interested citizens; federal, state, and local officials; and agency staff beginning in January 1987. Out of these discussions and after analysis of many remedial technologies, as well as their effectiveness in—and impact on—marine waters, a comprehensive environmental cleanup and restoration approach emerged (Weiner 1991). The approach included

  • A new outfall for the secondary treatment plant.

  • Permanent isolation of the contaminated sediments from marine life by capping the area with clean sediments from the nearby Puyallup River.

  • Habitat restoration and enhancement of nearshore and intertidal areas, including a long-term monitoring and adaptive management plan.

  • Preventive measures against future sediment contamination from the cap and the mill, including source control within the mill, monitoring, and contingency plans.

After site preparation and source-control actions initiated in December 1987, the 17-acre area was capped with clean sediment in July and August of 1988. The cleanup action was integrated with natural-resource restoration to produce new intertidal and shallow-water habitat in Commencement Bay, an



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