Communities for a Healthy Bay presents:
South Sound’s DIRTY DOZEN
Introduction: Industry, Injustice, and the Path Forward
The Industrial Legacy of Commencement Bay
For over a century, Commencement Bay has powered Washington’s economy. Shipyards, chemical plants, mills, and manufacturers turned Tacoma into a hub of trade and production. But that growth came at a cost: pollution of the bay’s waters, degradation of fish and wildlife habitat, and toxic exposure for nearby communities, especially the Puyallup Tribe.
In the 1980s, these cumulative harms led the U.S. Environmental Protection Agency (EPA) to designate the Commencement Bay Nearshore/ Tideflats as a federal Superfund Site, placing it among the nation’s top five groups of concern. This designation was a part of EPA’s first ever National Priorities List (NPL), used to identify sites that appear to present a significant risk to public health or the environment.
Cleanup and regulation efforts have been underway for decades, and while some progress has been made, portions of the bay remain unhealthy. Many of the same industries responsible for this contamination are still operating—some under stricter controls, others continuing harmful practices despite growing public concern for environmental and community impacts.
Why This Report, and Why Now?
This report was created to confront an uncomfortable truth: too many industrial facilities in Tacoma are continuing practices that contribute to environmental degradation. While cleanup has improved some conditions, certain companies continue to discharge toxic substances into our air, soil, and waterways, often with little public awareness and limited regulatory consequence.
In the South Sound, pollution isn’t evenly distributed. Many of the most egregious offenders are located on or near Tribal lands, and within communities already facing heightened environmental and health risks. These facilities don’t just raise compliance concerns, we believe they are contributing to patterns of environmental injustice and undermining decades of progress.
The sites profiled here were chosen not only for their individual exceedances, but to demonstrate the system that is in place—one of persistent noncompliance, weak enforcement and accountability, and preventable harm to ecosystems and public health. This report aims to support policy reform, community advocacy, and legal accountability by documenting ongoing exceedances and placing them within a broader historical and justice-oriented context.
What Good Industry Looks Like
Importantly, there are some South Sound industrial facilities that are doing good, proving that with investment, oversight, and a commitment to environmental health, it is possible to operate responsibly, even within the same legal and regulatory frameworks that others exploit.
• Auto Warehousing Company has demonstrated that with stormwater filtration upgrades and permit compliance, large-scale operations can significantly reduce runoff impacts.
• Georgia Pacific Gypsum, despite being in a traditionally heavy-polluting sector, has met stormwater benchmarks and avoided chronic permit exceedances through improved on-site management.
• MK Fibers, a recycling processor, has successfully stayed in compliance with water quality requirements through proactive infrastructure improvements.
• Globe Machine Manufacturing made operational changes that removed their need for a stormwater permit altogether, earning a Conditional No Exposure designation and setting a standard for innovation.
These facilities show that excessive pollution is not inevitable. When facilities choose to invest in infrastructure, training, and environmental performance, they not only avoid exceedances, but they also help restore community trust and ecological health.
Additionally, organizations beyond traditional industry, such as the University of Washington Tacoma and the Point Defiance Zoo & Aquarium, have embraced their role as stewards of place. Through green infrastructure, transparent emissions tracking, climate-responsive design, and a detailed “Climate Action Plan” to reduce greenhouse gas emissions, they model how development and environmental care can coexist.
Only 16 of 116 facilities met ISGP permit expectations over the last 5 years.
The DIRTY DOZEN: Chronic Harm, Compound Risk
In contrast, the facilities profiled here repeatedly exceed stormwater discharge limits, contribute to toxic air emissions, mishandle hazardous waste, or operate directly atop Superfund sites with little regard for ongoing risks. Some of the major concerns include:
• Simon Metals, which has experienced multiple fires and years of unmonitored stormwater discharges.
• Emerald Services, which ranks among Pierce County’s top air polluters despite having only a minor air permit.
• Occidental Chemical, which has left a nationally significant legacy of groundwater contamination so severe it stretches beneath the Hylebos Waterway.
These facilities don’t just pollute; they do so in areas already overburdened by legacy contamination and environmental injustice. Their continued operation under conditions of chronic noncompliance demands stronger enforcement, greater transparency, and sustained public pressure. If some facilities can comply, then the failure of others is a matter of choice—not impossibility.
Glossary of Terms and Permit Definitions
Understanding the pollution harming Commencement Bay starts with knowing the key players: the chemicals, the permits, and the loopholes. This glossary breaks down the terms you’ll see throughout the Dirty Dozen—and why they matter.
Permits & Regulatory Terms
NPDES (National Pollutant Discharge Elimination System) Permit: A permit under the Clean Water Act that regulates the discharge of pollutants into U.S. waters. Facilities with NPDES permits must monitor and limit pollutants in their stormwater or wastewater discharge.
ISGP (Industrial Stormwater General Permit): A type of NPDES permit specifically for industrial facilities. It requires facilities to monitor stormwater runoff for pollution, take corrective actions when benchmarks are exceeded, and implement best management practices (BMPs) to prevent contamination.
Industrial NPDES Individual Permit: A site-specific permit issued to an industrial facility under the Clean Water Act when the facility does not qualify for coverage under the Industrial Stormwater General Permit. It includes customized requirements for monitoring, pollution control, and best management practices based on the facility’s unique operations and discharge characteristics.
Construction Stormwater General Permit: A temporary NPDES permit for construction sites disturbing one acre or more. It requires erosion control and pollution prevention measures during land disturbance and construction activities.
PERMITS
Model Toxics Control Act (MTCA): Washington State’s cleanup law that guides how contaminated sites are identified, investigated, and cleaned up to protect public health and the environment.
RCRA (Resource Conservation and Recovery Act): A federal law governing the generation, transportation, treatment, storage, and disposal of hazardous waste. Often referred to as a “cradle to grave” system, it ensures hazardous waste is tracked and managed throughout its entire lifecycle.
Large Quantity Generator (LQG): A facility that generates 1,000 kg or more of hazardous waste per month and must meet strict storage, reporting, and emergency preparedness requirements.
Very Small Quantity Generator (VSQG): A facility that generates less than 100 kg of hazardous waste per month, with fewer regulatory requirements but still obligated to ensure safe handling and disposal.
Superfund Site: A federally designated site under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) that requires long-term cleanup of hazardous waste contamination.
Key Pollutants
Zinc: A heavy metal commonly found in stormwater runoff from galvanized metal roofs, vehicles, and industrial processes. Even in small amounts, zinc is toxic to aquatic life, especially fish and invertebrates, impairing their growth, reproduction, and survival.
Copper: A metal often present in brake dust, roofing materials, and pipes. Like zinc, copper is highly toxic to fish and aquatic organisms. It can damage gills, affect navigation and sensory systems in salmon, and disrupt aquatic food chains.
Turbidity: A measure of how cloudy or murky water is due to suspended particles. High turbidity reduces sunlight penetration, which harms aquatic plants, lowers oxygen levels, and can clog the gills of fish and other organisms.
PERMITS
Total Suspended Solids (TSS): Tiny particles of soil, metal, organic material, or other debris floating in water. High TSS can carry other harmful pollutants, smother aquatic habitats, and reduce oxygen levels critical to aquatic life.
Oil & Grease: Oily substances from vehicles, machinery, and industrial spills. These create slicks on the water surface, coat aquatic life, and interfere with fish reproduction and respiratory function.
pH: A measure of how acidic or basic water is. Extremely high or low pH levels can be harmful to fish and other aquatic organisms, damaging their skin and internal systems.
Community Impact
Pollution doesn’t stay neatly contained behind fences or property lines. Airborne contaminants drift into neighborhoods. Rain washes toxic runoff through public waterways. Contaminated groundwater seeps unseen beneath homes, parks, and gathering places. Every permit violation, every exceedance, and every regulatory failure spreads harm wider—damaging public health, cultural resources, and the ecosystems that people rely on every day.
Environmental Injustice:
According to Washington’s Environmental Health Disparities Map and the federal Environmental Justice Index (EJ Index), the neighborhoods surrounding these facilities rank among the highest in the state for pollution exposure, health risks, and socioeconomic vulnerability. These are communities where residents already face disproportionate rates of asthma, heart disease, limited access to healthcare, and fewer political resources to demand change.
PERMITS
Tribal Land Impacts:
Many of the facilities in this report operate on or adjacent to lands protected under the Treaty of Medicine Creek and stewarded by the Puyallup Tribe of Indians. Pollution here doesn’t just harm land and water—it attacks cultural survival. Contaminated fish runs, shellfish beds, and hunting grounds violate rights guaranteed by federal treaties, undercutting Indigenous sovereignty and food security.
When facilities pollute in these places, they are deepening generational harm against people, culture, and the future of the region.
Canoe
Facilities included in this report were selected based on recurring patterns of permit exceedances, significant impacts to local ecosystems or public health, and/or persistent concerns from the community. They are not listed in any order, nor does inclusion imply that these are the “worst” or most dangerous polluters in the region. Rather, they represent a sample of facilities whose documented practices and performance merit greater public awareness and regulatory attention.
This report is not intended to serve as a legal finding or comprehensive compliance audit. While every effort has been made to accurately interpret the data and provide context, readers are encouraged to consult official sources for the most current and complete regulatory records.
CARLILE TRANSPORTATION SYSTEMS, LLC
Long-Haul Pollution, Short-Term Accountability
Who They Are:
Carlile Transportation Systems is a freight carrier connecting the Pacific Northwest to Alaska and beyond. From its terminal on the Hylebos Waterway, Carlile moves goods— including hazardous waste—across land and sea. While their outward operations appear orderly, stormwater records tell a more concerning story.
What They Do:
Carlile operates a busy logistics terminal with container storage, truck maintenance, and hazardous waste transfer activities. The site sits atop one of Tacoma’s most contaminated industrial corridors, and polluted runoff from operations regularly discharges into impaired waterways during rain events.
Stormwater in the Fast Lane:
Over the past decade, Carlile’s stormwater sampling results have regularly exceeded permit benchmarks for copper, zinc, turbidity, and TSS. These pollutants are known to impair fish development, disrupt aquatic food chains, and worsen water quality in Commencement Bay. Continued exceedances raise serious concerns about pollution loading into sensitive ecosystems.
A Superfund Site with a New Tenant:
Carlile operates on land once occupied by U.S. Gypsum, part of the greater Commencement Bay Superfund Site. Though not responsible for the original pollution, Carlile’s ongoing stormwater benchmark exceedances could add to cumulative pollution impacts, potentially slowing ecosystem recovery efforts.
Hazardous Waste in Motion:
As a registered transporter of hazardous waste, Carlile moves toxic materials across state lines. While current records show compliance, the stakes are high. A single spill or mishandled load could trigger a multi-jurisdictional emergency, and in an ecosystem already vulnerable from decades of pollution, even a small mistake could prove catastrophic.
CONCRETE TECHNOLOGY CORP.
Building Blocks of Pollution
Who They Are:
Concrete Technology Corporation (CTC) has supplied girders, pilings, and slabs to the Pacific Northwest’s infrastructure since the 1950s. While their concrete supports bridges and piers above water, stormwater records raise concerns about impacts below the surface.
What They Do:
CTC manufactures precast and prestressed concrete products at its waterfront facility along the Blair Waterway. It also uses its pier for shipyard services and is permitted to discharge industrial stormwater and treated process water directly into the bay.
Hundreds of Exceedances, Decades of Issues:
With over 200 self-reported exceedances, CTC has one of the highest stormwater exceedance records in the region according to self-reporting records. Exceedances include turbidity, oil & grease, and TSS—pollutants known to degrade water clarity, choke aquatic plants, and damage fish habitat. Fluctuating pH levels have also been a persistent issue, posing physiological stress to marine organisms.
Superfund Site Connections:
Located within the Commencement Bay Superfund footprint, CTC is part of the industrial fabric that necessitated the designation in the first place. While historic contamination involved multiple industries over many decades, continued discharges of stormwater pollutants pose challenges to recovery efforts.
Concrete Operations and Environmental Risk:
While listed as a Very Small Quantity Generator (VSQG) of hazardous waste, CTC’s daily output of concrete slurry, dust, and chemical additives means that even minor mishandlings could pose environmental risks if they occurred. With heavy truck traffic and limited on-site containment, risk mitigation must go beyond paperwork.
EMERALD SERVICES, INC.
Toxic Recyclers, Troubled Record
Who They Are:
Emerald Services, a subsidiary of Clean Harbors, operates a hazardous waste processing and oil recycling facility in Tacoma’s tideflats. While the facility promotes recycling, its long record of pollution exceedances and toxic emissions reveals serious ongoing risks to public health and environmental recovery efforts.
What They Do:
Emerald collects and processes massive quantities of used oil, antifreeze, solvents, and other dangerous wastes across Washington and Oregon. As a Large Quantity Generator (LQG), it manages and stores millions of pounds of hazardous material on land already scarred by decades of pollution.
Air Pollution That Threatens Communities:
Despite holding only a “minor” air permit, Emerald consistently ranks among the highest reported air emissions in Pierce County. It releases lead, zinc, ethylene glycol, and carcinogenic PAHs—compounds linked to cancer, neurological damage, and childhood respiratory illness.
Stormwater Pollution is a Long-standing Pattern:
Over the past 15 years, Emerald has exceeded its NPDES permit more than 70 times. Stormwater samples routinely exceed limits for copper, ammonia, turbidity, and oil— pollutants known to reduce water clarity, poison fish, and accumulate in the already-impaired Commencement Bay ecosystem.
Toxic Legacy, Ongoing Risks:
Situated on polluted industrial land, the facility was previously part of an MTCA cleanup due to severe petroleum and solvent contamination. Though capped and marked “No Further Action” in 2010 by the WA Department of Ecology, the facility’s ongoing discharges continue to pose new risks to a waterway and community that have already endured decades of industrial damage.
KLEENBLAST DIVISION
Over a Decade of Dirty Runoff
Who They Are:
Kleenblast Division is a sandblasting and abrasive materials supplier located in the Port of Tacoma. It serves the construction and industrial maintenance industries by manufacturing and distributing abrasive products.
What They Do:
The facility manufactures and handles sandblasting equipment and materials, often stored or processed outdoors on bare ground or paved surfaces without containment. Its operations contribute to stormwater runoff containing heavy metals and fine particles.
Where Every Rainfall Carries Risks:
Since 2010, Kleenblast’s Industrial Stormwater General Permit (ISGP) discharges have routinely exceeded pollution benchmarks—especially for copper, zinc, oil & grease, turbidity, and TSS. These pollutants are toxic to fish and shellfish, smother aquatic habitats, and severely degrade water clarity, making recovery for Commencement Bay even harder.
Compounding a Toxic Legacy:
The facility is located within the Commencement Bay Nearshore/Tideflats Superfund Site. While not the original source of contamination, its ongoing stormwater discharges compound the environmental damage of the legacy pollution in the surrounding watershed.
MANKE LUMBER COMPANY, INC SUMNER
Treated Timber, Untreated Problems
Who They Are:
Manke Lumber is a long-standing wood processor and treatment company operating in the Tacoma area. With roots in forestry and construction, the company has shaped regional development for decades.
What They Do:
Manke produces and treats lumber products using various chemical preservatives. Its site processes large quantities of timber and stores chemically treated wood in outdoor yards, generating contaminated runoff during rainfall.
Stormwater Steeped in Metals:
Manke has reported copper, arsenic, chromium, and oil & grease permit exceedances for most of the last 15 years. Arsenic, copper, and chromium, often linked to wood treatment chemicals, are highly toxic and persistent in this environment. These are contaminants that bioaccumulate in fish, impair reproductive cycles, and threaten the survival of native aquatic species throughout the Puyallup watershed.
Dangerous Waste Handling Challenges:
Since 1993, Manke Sumner had 290 permit violations or triggers and faced 91 enforcement actions under their NPDES IP.
Designated a Large Quantity Generator (LQG) of hazardous waste, Manke’s history includes regulatory citations for dangerous waste mismanagement. In 2019, the WA Department of Ecology documented critical failures, including missing emergency plans. These problems triggered compliance orders and Immediate Action Letters when deficiencies remained uncorrected.
Soil Contamination Runs Deep:
As a cleanup site under Washington’s Model Toxics Control Act (MTCA), Manke’s property contains soil and groundwater tainted with arsenic, mercury, diesel-range hydrocarbons, and pentachlorophenol (a carcinogenic pesticide banned in most uses). Even today, groundwater monitoring confirms contamination persists near and beneath the facility.
SIMON METALS, LLC
Scrap, Smoke, and Silence
Who They Are:
Simon Metals, a scrap metal processor recently acquired by Metro Metals Northwest, operates just yards from the Puyallup River in Tacoma’s tideflats. The facility processes ferrous and non-ferrous metals and sits in one of the most environmentally vulnerable corners of the Port.
What They Do:
Simon handles large volumes of scrap, performing cutting, shredding, and storing metal outdoors. Operations involve high-risk industrial equipment, conveyor belts, and frequent truck traffic.
Stormwater Laced with Metals:
For over a decade, Simon has consistently failed to meet basic permit conditions, including required stormwater monitoring. Where sampling data exists, results reveal persistent exceedances for copper, lead, and zinc— pollutants that impair salmon reproduction, poison aquatic life, and bioaccumulate up the food chain. The facility’s stormwater is collected on-site, routed to a detention basin, and then discharged into the City of Tacoma’s stormwater system, ultimately reaching the Puyallup River largely untreated.
Safety Concerns Heat Up:
Simon Metals history of fire—including significant incidents in 2018 and 2023—has repeatedly sent massive smoke plumes over the tideflats. Both events forced nearby residents and workers to shelter indoors. Operations resumed following each incident, raising community concern over the adequacy of response, future fire prevention, hazardous materials, and overall public safety.
A Facility on Fragile Ground:
Though not responsible for the original contamination, Simon’s discharges and industrial activity sit atop the Commencement Bay Superfund Site. Ongoing pollution risks jeopardizing progress made through decades of cleanup work.
TACOMA WHEEL SHOP
Who They Are:
Operated by Greenbrier Railcar Services, the Tacoma Wheel Shop repairs and refurbishes railcar wheels in the heart of the Port of Tacoma. It’s a behind-the-scenes player in the region’s transportation network but its pollution is far from invisible.
What They Do:
The facility machines, inspects, and replaces rail wheels. These operations involve cutting fluids, metal shavings, lubricants, and outdoor storage, all of which generate runoff during rainfall events.
Runoff that Misses the Mark:
Tacoma Wheel Shop has exceeded its stormwater permit for five consecutive quarters (2023–2024), with repeated benchmark exceedances for copper, zinc, oil & grease, turbidity, and TSS. These pollutants impair fish respiration, smother salmon eggs, and reduce dissolved oxygen in Commencement Bay. Even minor exceedances add up when repeated month after month.
On Top of a Superfund Site:
Though not a legacy polluter, the facility operates atop the Commencement Bay Superfund Site. Stormwater runoff from daily operations undermines decades of cleanup efforts, keeping contamination levels elevated in already degraded waters.
Industrial Oversight Gaps:
Despite repeated permit exceedances, the facility has avoided formal enforcement. Years of inconsistent monitoring, lack of updated stormwater infrastructure, and minimal on-site improvements suggest that operations at the Tacoma Wheel Shop have little public accountability for their pollution.
CHB has documented dust emissions from TEMCO entering the water without a permit since the early 1990’s.
TACOMA EXPORT MARKETING COMPANY
Grain, Dust, and Industrial Drift
Who They Are:
Temco, one of the largest grain exporters in the Pacific Northwest, has operated its waterfront terminal in Tacoma since 1992. The company moves millions of tons of wheat, soybeans, and corn annually, serving as a critical node in global agricultural trade.
What They Do:
Grain arrives by rail and is transferred via conveyor systems and silos onto massive cargo ships. Temco’s 24/7 activity generates significant industrial noise, dust, and stormwater runoff, all from a site situated directly on Tribal land.
Dust in the Wind and Water:
Grain dust from Temco’s operations doesn’t just settle in the air—it ends up in the water, contributing to nutrient loading. Nutrient loading depletes oxygen levels in the water, which can impair aquatic life. Despite multiple complaints for dust pollution, concerns remain about its effects on both water quality and public health.
Stormwater Exceedances That Don’t Go Away:
Temco has reported stormwater exceedances for much of the past decade. Pollutants like zinc regularly exceed, and pollutants including copper, turbidity, TSS, and pH occasionally exceed permit benchmarks. These metals and sediments are known to harm fish gills, disrupt aquatic food chains, and cloud Commencement Bay, reducing its ecological function.
Burdening a Damaged Bay:
Temco sits squarely within the Commencement Bay Nearshore/Tideflats Superfund Site. While it isn’t responsible for legacy contamination, we believe its ongoing exceedances slow the bay’s recovery and add to the longstanding pollution burden in this area.
TRU GRIT ABRASIVES, INC
Slag Beneath the Surface
Who They Are:
Operating under the name Pony Lumber Company, Tru Grit Abrasives is a sprawling multi-use industrial facility—part sawmill, part abrasive manufacturer, part warehouse. Its site on Taylor Way in Tacoma has hosted polluting industries for nearly a century.
What They Do:
Tru Grit manufactures abrasive materials and handles freight logistics. Its operations span outdoor material storage, truck staging, and wood product handling, all within a zone of known environmental contamination.
Stormwater Failing the Test of Time:
From 2013 to 2024, Tru Grit has been out of compliance for at least 35 reporting quarters. Stormwater samples showed high levels of copper, zinc, oil, turbidity, and dangerously unbalanced pH. These discharges affect fish survival, reproduction, and the clarity of the waters flowing into Commencement Bay.
Slag in the Soil:
Tru Grit’s site was historically stabilized with 1,800 tons of smelter slag—waste left over from Asarco’s toxic legacy. That slag, laden with arsenic, copper, and lead, remains buried beneath the surface. Although WA Department of Ecology issued a “No Further Action” letter in 1995, periodic reviews continue and new contamination could compromise that closure.
Regulatory Red Flags:
Despite years of warnings and informal corrections, major problems persist. The company faced an $8,000 fine in 2024 after a failed stormwater treatment system spilled untreated runoff. An administrative order issued in 2021 underscored ongoing systemic failures. Instead of steady improvement, Tru Grit’s record suggests a troubling pattern: short-term fixes, long-term pollution.
QUALITY TRANSPORT & TRUCK RAIL HANDLING
Who They Are:
Truck Rail Handling is a logistics hub in the Port of Tacoma where freight moves from trains to trucks and back again. While the facility does not manufacture any longer, its footprint on the environment is anything but minimal, as a decades-long Superfund cleanup site.
What They Do:
Truck Rail’s operations involve bulk freight staging, container transfer, and vehicle activity across large, paved surfaces. These outdoor operations raise the risks of pollution via stormwater runoff, especially during the Pacific Northwest’s rainy months.
15 Years of Exceedances, 2 Letters of Warning:
For over 15 years, Truck Rail has failed to consistently meet stormwater standards, exceeding benchmarks in more than half of its reported quarters. Runoff routinely contains copper, zinc, TSS, and turbidity—pollutants that impair fish gills, smother spawning beds, and block the light needed for underwater ecosystems to thrive. Some TSS readings have been nearly 100 times the allowable limit, yet formal enforcement actions are rare.
Hazardous Waste—Low Quantity, High Risk:
Though officially listed as a Very Small Quantity Generator (VSQG), the facility’s location amplifies risk. Even a small spill here could quickly reach the Foss Waterway already burdened with industrial discharge and legacy contamination.
Superfund Zone, Same Old Story:
Truck Rail operates within the boundaries of the Commencement Bay Nearshore/Tideflats Superfund Site—a place long burdened by industry and still struggling to recover. Its continued benchmark exceedances erode decades of cleanup funded by taxpayers and fought for by the Puyallup Tribe and community groups.
Over the past 15 years, Truck Rail spent 32 of 58 quarters out of compliance under its ISGP.
Despite this, only 2 enforcement actions have ever been taken... both in 2011.
SUPERLON PLASTICS COMPANY, INC & OCCIDENTAL CHEMICAL CORPORATION
Historic Polluters, Persistent Threats
Superlon Plastics and Occidental Chemical are not relics of the past — they are active sources of contamination in Tacoma’s tideflats today. These sites reflect a long-standing pattern of industrial activity and delayed cleanup that continues to burden surrounding Tribal lands, waterways, and frontline communities. While production may have ceased, the contamination beneath both sites continues to leach into the surrounding environment, impacting our waters, fish, and public health.
Superlon Plastics (formerly Tacoma Wood Treating)
Pesticides and Wood Treatment:
Starting in the 1920s, this site was home to a lead-arsenate pesticide plant, followed by a wood treatment operation that used toxic preservatives like creosote and pentachlorophenol, substances now classified as carcinogenic and harmful to aquatic ecosystems. These poisons were never properly contained.
Buried Waste:
Historical records and sampling suggest that barrels of waste, including arsenic and solvents, were improperly stored or disposed of onsite. Today, carcinogenic volatile organic compounds (VOCs) like trichloroethylene (TCE) are still detectable in the groundwater beneath the tideflats.
Ongoing Hazards:
These contaminants are mobile and persistent. Recent sampling still shows arsenic and lead exceeding state cleanup thresholds, meaning community and ecosystem risks remain active today.
Bottom Line:
Despite decades of promises, the Superlon Plastics site remains an unhealed wound on Tacoma’s landscape.
Occidental Chemical Corporation (OxyChem)
Chlorine and Ammonia Production:
Operating from 1929 to 2002, OxyChem manufactured industrial chemicals through processes that created massive quantities of hazardous waste. For decades, these byproducts leached into the soil through unlined settling ponds and discharged directly into the Hylebos Waterway.
A Groundwater Plume That Won’t Go Away:
Over 100,000 pounds of volatile organic compounds (VOCs), including benzene and carbon tetrachloride, were released into the soil and groundwater. These contaminants have spread under the Hylebos and remain in concentrations far above safe limits, despite treatment efforts.
Glacial Cleanup Progress:
Though partial cleanup systems have been installed, large portions of the site still contain hazardous compounds at hundreds of times the levels considered safe.
Bottom Line:
OxyChem’s toxic legacy is not history—it’s an ongoing environmental crisis still unfolding beneath Tacoma’s tideflats.
Hylebos Waterway
NPDES - Individual RCRA - Cleanup
Long-Term VOC Plume & Stormwater Issues
Chlorine Chloroform
Hylebos Waterway
Why It Still Matters
Contamination Crosses Boundaries
Rainfall, tides, and groundwater movement ensure that pollutants don’t stay confined. Discharges from both sites continue to affect Commencement Bay and adjacent properties. This is not just legacy pollution, it’s ongoing exposure.
Cultural and Ecological Impacts
Both sites sit within Puyallup Tribal territory and affect Treaty-protected fishing and shell fishing areas. Pollutants from these operations compromise vital cultural resources and threaten the health of ecosystems relied upon for food, economy, and heritage.
Environmental Injustice Persists
Nearby neighborhoods rank high on Washington’s Environmental Health Disparities Map, with limited access to healthcare and increased exposure to pollution. Many residents are low-income or people of color that face disproportionate risks without adequate tools for advocacy or recovery.
Stalled Recovery of Commencement Bay
Despite decades of cleanup efforts, the pollution from Superlon and OxyChem slows ecosystem restoration and restricts the already dwindling supply of industrial land. In turn, we see sites encroaching further and further into communities already suffering from their proximity to industry. These sites remain a barrier to recovery for salmon, shellfish, and the communities working to protect themselves and the Sound.
More
Effort is Needed
The contamination at Superlon Plastics and Occidental Chemical continues to threaten the health of people, fish, and water in the South Sound. While both sites are under cleanup oversight, the pace and transparency of these types of cleanups fall short. Lasting recovery will require not only technical remediation but public accountability, Tribal consultation, and sustained investment in environmental justice.
CALL TO ACTION: Turning Knowledge into Power
The facilities outlined in this report are not outliers. They are part of a pattern—one that has allowed pollution, neglect, and environmental injustice to persist in Tacoma’s most vulnerable communities for decades. Their continued exceedances are not due to a lack of laws or science, but a lack of enforcement, transparency, and political will. Now that we know the extent of the harm, the question becomes:
What will we do about it?
For Community Members
• Know your rights—and your resources: Everyone deserves access to clean water, safe air, and healthy neighborhoods. Under state law and Treaty protections, communities have a right to be informed and a role to play in decision-making. Learn where pollution is happening, who’s responsible, and what agencies are supposed to be doing about it.
• Be the eyes on the water: Many pollution events go unaddressed because they go unreported. If you see oil slicks, discolored water, dead fish, dumping, or smell chemical odors, report it immediately to Communities for a Healthy Bay, the WA Department of Ecology, and if it is within city limits, the City of Tacoma via 311. Take photos, take notes, and help build the case for action.
• Demand better from your leaders and agencies: Regulators are supposed to work for the public, not polluters. If your neighborhood is seeing repeat exceedances and no enforcement, ask your city council, state representatives, and agency directors why. Call for stronger penalties, faster timelines, and public access to pollution data. When you tell your story, you put a human face on environmental harm— and push decision-makers to act.
• Honor Indigenous leadership and sovereignty: These facilities sit on lands and waters protected under Treaty rights. Trust and support the leadership of the Puyallup Tribe of Indians and Tribal environmental teams. Environmental justice must always include cultural justice.
For Policymakers & Regulators
• Strengthen and enforce the rules that already exist: Washington’s stormwater, air, and hazardous waste laws are clear—but they only work when enforced. Chronic violators should face real consequences, including fines that reflect the scale of harm, suspension of permits, or loss of business licenses. Too often, facilities receive informal notices or extended compliance deadlines without consequence. Without meaningful accountability, polluting becomes just another cost of doing business.
• Hold polluters—not taxpayers—responsible for cleanup: When companies contaminate soil, water, or air, they must be the ones to pay for cleanup. Many times, the public ends up footing the bill through Superfund settlements, state grants, or deferred remediation. This not only drains public resources but allows polluters to continue operating without changing their practices. Create stricter cost-recovery policies and ensure businesses take full financial responsibility for the damage they cause.
• Push for upstream prevention, not just downstream mitigation: Permit conditions and best management practices should prevent pollution before it happens, not just manage it after the fact. Encourage or require source-control upgrades, closed-loop systems, green infrastructure, and industrial process changes. Offer incentives for facilities that go beyond compliance—and prioritize enforcement for those who ignore it.
• Center environmental justice in enforcement: Direct agency resources and inspections to communities facing the greatest cumulative environmental and health burdens. Use Washington’s Environmental Health Disparities Map and the federal EJScreen tool to identify neighborhoods that need stronger protection and faster response. Ensure that Tribal governments are engaged as sovereign partners—not stakeholders—in all decision-making.
For Industrial Leaders
• Pollution isn’t profitable in the long run: The cost of persistent pollution is high—fines, cleanup liability, lawsuits, permit delays, public backlash, and reputational damage. These costs compound over time, especially for facilities operating in already vulnerable environments. Chronic exceedances can derail operations and expose companies to public scrutiny, loss of government contracts, and shareholder pressure.
• Make the case that you can operate responsibly: Even now, our existing policy framework shows routine favor to the systemic power of industrial operations. While we use every tool available to us to hold polluters accountable, many still concede that some industries aren’t possible unless they can offload some portion of their costs or impacts to the public. Historical pollution and environmental injustice should not set the bar for what people expect of these operations. Being truly accountable to the external costs of your business and working with the public to prevent harm is a fundamental part of operating responsibly.
• Compliance is cheaper than cleanup: Investing in filtration systems, covered storage, spill prevention, and employee training costs money upfront. However, it’s a fraction of what it costs to remediate groundwater, rebuild public trust, or defend against litigation. The Clean Water Act is built on the principle that facilities must implement pollution controls using the Best Practicable, Best Conventional, and Best Available Technologies—a tiered approach that balances cost with effectiveness. Choosing to delay or avoid these investments doesn’t just risk legal exposure, it undermines the very foundation of water protection in the United States.
• Your brand is your license to operate: In today’s economy, communities, investors, and governments expect transparency and sustainability. Operating cleanly isn’t just good ethics—it’s a competitive advantage. Green infrastructure, public engagement, and responsible practices attract top talent, improve community relations, and build resilience against regulatory and climate-related disruptions.
We’re Not Asking for Perfection.
We ARE asking for:
Accountability for chronic polluters
Equity for communities disproportionately harmed
Restoration of ecosystems damaged by decades of neglect
A new standard of industrial behavior rooted in transparency and justice
Recognition of the Puyallup Tribe’s sovereign rights to clean water and healthy fisheries
Use this report. Share it. Speak up. Show up. Take action!
Because every time we allow pollution to go unchecked, we send a message about whose health and whose future matters. It’s time to send a different one.
About Communities for a Healthy Bay
At Communities for a Healthy Bay, we take bold action to protect the health of Commencement Bay, the South Sound’s waters, and the people who rely on them. Through community advocacy, environmental justice, and corporate accountability, we fight for clean water and healthy communities, because everyone deserves a safe environment.
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The Commencement Bay tideflats don’t have to be a sacrifice zone. They can be a place where economy and ecology work in balance, where industry respects the land it profits from, and where communities, especially those long-silenced, are finally heard.