United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R10-92/047
September 1992
N°/EPA Superfund
Record of Decision:
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8
NOTICE
The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement. but adds no further applicable information to
the content of the document. All suppIemen1aI matenal is, however, contained in the administrative record
for thiS site. .
. .
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REPORT DOCUMENTATION 11. REPORT NO. 2. 3. Recipienl'a Acceaalon No.
PAGE EPA/ROD/R10-92/047
4. Tide and SUbtitle S. Report Do1e
SUPERFUND RECORD OF DECISION 09/29/92
Wyckoff/Eagle Harbor, WA
6.
First Remedia I Action - Subsequent to follow
7. Author(a) 8. PerlomUng Organization Rept. No'
9. Perlonning Orgalnization Name end Add..... 10. ProjectlTuklWort Unit No.
11. ContraCl(C) or GronIIG) No.
(C)
(G)
12. Sponsoring OrgarUolion Nome end Addr..... 13. Type of Repor1 & Period Co-
u.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. SUpplementary NoleS
PB93-964618
16. Abstract (Limit: 200 words)
The 3,780-acre Wyckoff/Eagle Harbor site is located on the east side of Bainbridge
Island, in Central puget Sound, Kitsap County, washington. The site consists of an
inactive 40-acre wood treating facility owned by Wyckoff, the adjacent SOD-acre Eagle
Harbor and other upland sources of contamination to the Harbor, including a former
shipyard. Land use in the area is predominantly residential, with some commercial and
industrial uses. The harbor supports several fish resources, a wide variety of
resident and migratory birds, and other wildlife. The shipyard operated from 1903 to
1959 on the northwest shore of Eagle Harbor, resulting in releases of metals and
organic contaminants. From 1905 to 1988, wood treating operations were conducted on
the southeast shore involving pressure treatment with creosote and pentachlorophenol.
Preservative chemicals, which were delivered to the facility by barge and ship, were
stored in tanks on the property. Contamination of soil and ground water at the wood
treatment facility led to seepage into adjacent sediment s . Wastewater was discharged
into Eagle Harbor for many years, and the practice of storing treated pilings and
timber in the water continued until the late 1940's. In 1984, NOAA investigations of
(See Attached Page)
17. Document Anelyois L De8cripeora
Record of Decision - Wyckoff/Eagle Harbor, WA
First Remedial Action - Subsequent to follow
Contaminated Media: sediment
Key Contaminants: organics (PAHs), metals (arsenic, chromium, lead)
b. IdentifieraJOpen-Ended Tenna
c. COSA T1 FieIdIGroup
18. Availabili1y SIotement 19. Security CIsso (Thia Report) 21. No. 01 Pages
None 124
20. Secui1y as.. (This Poge) 22. Price
None
1 272 (4-77)
~
-
50272.101
(See ANSl-Z39. 8)
See Instructions on Re'ffHM
(FonneJty NTlS-35)
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2?A/ROD/RIO-92/047
Wyckoff/Eagle Harbor, WA
First Remedial Action - Subsequent to follow
Abstract (Continued)
the Harbor revealed that sediment, fish, and shellfish from Eagle Harbor contained
elevated levels of PAHs. Later in 1984, EPA required the Wyckoff Company to conduct
environmental investigation activities under RCRA, and the state required immediate
action to control stormwater runoff and seepage of contaminants. In 1991, EPA defined
three operable units at the Wyckoff/Eagle Harbor site: East Harbor (OU1), Wyckoff (OU2),
and West Harbor (OU3). This ROD addresses subtidal/intertidal sediment and upland
sources of contamination in the West Harbor (OU3), where significant sources from former
shipyard activities are believed to have been controlled. Future RODs will address
PAH-contaminated sub-tidal sediment in the OU1 and OU2, the contaminated East Harbor
(OU1), and contaminated ground water, soil, and intertidal sediment at the adjacent
facility (OU2). The primary contaminants of concern affecting the subtidal/intertidal
sediment and upland sources are organics, including PAHs; and metals, including arsenic,
chromium, and lead.
The selected remedial action for this site includes dredging, dewatering, excavating
approximately 1,000 to 7,000 cubic yards of intertidal sediment that exceed levels of 5
ng/kg mercury and/or lower moderate PAH concentrations, followed by treatment using
solidification/stabilization, if necessary, to comply with LDR as determined by bench
scale tests; transporting sediment, which cannot be treated to meet LDR offsite for
disposal at a RCRA-permitted landfill; treating wastewater from the dewatering process
using carbon adsorption before discharge into the harbor; capping over sediment in areas
of high concern with a 1-meter thick layer of clean sediment; placing a thin layer of
clean sediment in subtidal areas of low to moderate concern to enhance natural sediment
recovery; conducting long-term environmental monitoring; and implementing institutional
controls to prevent exposure to contaminated fish and shellfish. The estimated present
worth cost for this remedial action ranges from $6,200,000 to $16,000,000, which includes
a present worth O&M cost of $1,100,000 for 10 years.
PERFORMANCE STANDARDS OR GOALS:
Sediment clean-up goals are based on the State of Washington Sediment Management
Standards (Sediment Standards), which provide chemical criteria for both a minimum
clean-up level (MCUL) and the more stringent .sediment quality standards (SQS).
Chemical-specific goals for defining cleanup areas include anthracene 1,200 mg/kg;
chrysene 460 mg/kg; naphthalene 170 mg/kg; pyrene 1,400 mg/kg; and mercury 0.58 mg/kg
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u.s. Environmental Protection Agency
Region 10
Seattle, Washington
West Harbor Operable Unit
Wyckoff/Eagle Harbor Superfund Site
RECORD OF DECISION
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CONTENTS
Page
iv
LIST OF FIGURES
v
LIST OF TABLES
VI
LIST OF ACRONYMS
DECLARATION
Site Name and Location
Statement of Basis and Purpose
Assessment of the Site
Description of the Remedy
Statutory Determinations
1
1
1
1
2
DECISION SUMMARY
1. OVERVIEW
4
2.
SITE LOCATION AND DESCRIPTION
2.1 Site Location
2.2 Current Land Use
2.3 Environmental Setting
5
5
5
8
3.
SITE HISTORY AND ENFORCEMENT ACfIONS
3.1 Site Background
3.2 Site Listing
3.3 CERCLA Enforcement Actions
3.4 Eagle Harbor RIIFS
11
\l
\l
12
12
4.
COMMUNITY RELATIONS ACfIVlTIES
14
5.
SCOPE AND ROLE OF OPERABLE UNITS
WITHIN THE SITE STRATEGY
15
6.
SITE CHARACTERISTICS
6.1 Scope of RIIFS
6.2 RI Sampling
. 6.3 Nature and Extent of Sediment Contamination
6.4 Sources of Contamination
6.5 Other Contaminated Media
6.6 Depth of Concern
6.7 Routes of Migration
6.8 Potentially Exposed Populations
6.9 Principal Threat
16
16
16
17
21
22
22
22
27
27
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7.
SUMMARY OF SITE RISKS
7.1 Human Health Risk Assessment
7.1.1 Identification of Chemicals of Concern
7.1.2 Toxicity Assessment
7.1.3 Exposure Assessment
7. 1.4 Risk Characterization
7.2 Ecological Assessment
7.2.1 Chemicals of Concern
7.2.2 Biological Effects
7.3 Summary of Risk Assessment
1.4 Special Site Characteristics
8.
DESCRIPTION OF ALTERNATIVES
8.1 Estimated Cleanup Areas
8.2 Common Components of Alternatives
8.2.1 Institutional Controls
8.2.2 Source Control
8.2.3 Natural Recovery
8.2.4 Sampling During Remedial Design
8.3.5 Monitoring
8.3 Description of the Alternatives
8.4 Applicable or Relevant and Appropriate Requirements
9.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
9. 1 Threshold Criteria .
9.1.1 Overall Protection of Human Health and the Environment
9.1.2 Compfhmce with ARARs
9.2 Primary Balancing Criteria
9.2.1 Long-Term Effectiveness and Permanence
9.2.2 Reduction of Toxicity, Mobility, or Volume Through Treatment
9.2.3 Short-Term Effectiveness
9.2.4 Implementability
9.2.5 Cost-Effectiveness
9.3 Modifying Crit~!".!~
9.3.1 State ari.a Tribal Acceptance
9.3.2 Community Acceptance
9.4 Summary
10.
SELECTED REMEDY
10.1 Cleanup Objectives
10.1.1 State Sediment Management Standards
10.1.2 Site-Specific Goals and Objectives
10.2 Problem Areas and Actions
10.2.1 Mercury Hotspot
10.2.2 Mercury HAET Areas
10.2.3 Intertidal HPAH
10.2.4 MCUL Areas
10.2.5 SQS Areas
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28
28
28
28
31
32
35
36
36
37
37
39
39
43
47
47
47
48
48
49
57
69
69
69
69
70
10
11
11
12
12
12
13
13
73
74
14
14
15
16
16
80
80
81
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10.3 Source Control
10.3.1 Stormwater
10.3.2 Marine Operations
10.3.3 Contaminated Upland Areas
10.4 Institutional Controls
10.5 Monitoring
10.5.1 Monitoring for Environmental Conditions
10.5.2 Monitoring Human Health Risks
10.6 Implementation
10.7 CERCLA Five-Year Review
10.8 Costs
11.
STATUTORY DETERMINA TlONS
11.1 Protection of Human Health and the Environment
11.2 Compliance with ARARs
11.3 Cost Effectiveness
11.4 Utilization of Permanent Solutions and Alternative Technologies
11.5 Preference for Treatment as a Principal Element
12.
DOCUMENT A TlON OF SIGNIFICANT CHANGES
12.1 Low-Impact Capping/Thin Layer Placement Methods and Costs
12.2 Basis for Defining Capping Subareas
12.3 Further Definition of Future Source Control Efforts
12.4 Clarification of Appropriate Disposal for Excavated Sediments
12.5 Elimination of Requirement for Additional Biological Testing
12.6 Consideration of Natural Recovery
12.7 Reevaluation of Areas Failing MCUL Biological Criteria
12.8 Summary .
REFERENCES
Appendix A: Proposed Plan
Appendix B: Letter of Concurrence
Appendix C: Responsiveness Summary
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83
83
83
84
84
85
85
86
86
86
88
90
90
90
93
93
94
95
95
96
96
97
97
97
97
98
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List of Figures
Figure 1. Regional Setting 6
Figure 2. Area Map 7
Figure 3. Site Operable Units 9
Figure 4. Land Use Map 10
Figure 5. Eagle Harbor Sample Locations 18
Figure 6. Subtidal Background Locations 19
Figure 7. Intertidal Metals Relative to Background 23
Figure 8. Subtidal Mercury Concentrations 24
Figure 9. Subtidal Concentrations of TPAH 25
Figure 10. Areas of Ferry Propeller Influence 26
Figure II. Areas Exceeding Sediment Standards Chemical Criteria 45
Figure 12. Areas Exceeding Sediment Standards MCUL Biological Criteria 46
Figure 13. Cleanup Areas Identified in West Harbor Selected Remedy 79
Figure 14. Framework for the Timing of Remedial Activities 87
Figure 15. Changes in Areas Above MCUL Biological Criteria After
Recalculation 99
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List of Tables
Table 1 List of Technical Memoranda for Eagie Harbor 13
Table 2 1988 AETs for Puget Sound 20
Table 3 Potential Exposure Pathways Retained for Risk Assessment 29
Table 4 Chemicals of Potential Concern for Human Health 30
Table 5 Human Toxicity Factors of Chemiea1s Retained for Risk Quantification 33
Table 6 Exposure Assumptions for Human Health Risk Assessment 34
Table 7 Screening of Alternatives 40
Table 8 Sediment Standards Chemical Criteria 41
Table 9 Sediment Standards Biological Criteria 42
Table 10 FS Preliminary Area$/Volumes for the West Harbor 43
Table 11 Summary of Common Components of Remedial Alternatives 44
Table 12a Cost Estimates for Preliminary Intertidal Mercury Area 50
Table 12b Cost Estimate for Prel iminary Intertidal P AH Area 50
Table 12c Cost Estimate for Lower-End Subtidal Mercury Area 51
Table 12d Cost Estimate for Higher-End Subtidal Mercury Area 51
Table 13 Estimated Time to Implement Remedial Alternatives 54
Table 14 Summary Table of Key ARARS associated with Remedial Alternatives 58
Table 15 Chemical Levels, Selected Remedies, and Potential Modifications 78
Table 16 Summary of Estimated Costs for West Harbor Selected Remedy 89
Table 17 Comparison of Cost Estimates for Low-Impact CappingfThin Layer
Placement 96
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List of Acronyms
AET
AKARTs
ARAR
BMP
CERCLA
COE
Ecology
EPA
HPAH
LPAH
MCUL
MFS
NCP
NOAA
NPDES
NPL
PAH
PCB
PI
POlW
PRP
PSAMP
PSDDA
PSEP
PSWQA
RCRA
Rfd
RIfFS
ROD
RME
SF
SQS
TBC
UST
Apparent Effects Threshold
All Known Available and Reasonable Methods of Treatment
Applicable or Relevant and Appropriate Requirement
Best Management Practice .
Comprehensive Environmental Response, Compensation, and Liability Act
U.S. Army Corps of Engineers
Washington Department of Ecology
U.S. Environmental Protection Agency
High Molecular Weight Polynuclear Aromatic Hydrocarbons
Low Molecular Weight Polynuclear Aromatic Hydrocarbons
Minimum Cleanup Level
State of Washington Minimum Functional Standards
National Contingency Plan
National Oceanic and Atmospheric Administration
National Pollutant Discharge Elimination System
National Priorities List
Polynuclear Aromatic Hydrocarbon
Polychlorinated Biphenyl
Preliminary Investigation
Publicly Owned Treatment Works
Potentially Responsible Party
Puget Sound Ambient Monitoring Program
Puget Sound Dredged Disposal Analysis
Puget Sound Estuary Program
Puget Sound Water Quality Authority
Resource Conservation and Recovery Act
Reference Dose
Remedial Investigation/Feasibility Study
Record of Decision .
Reasonable Maximum Exposure
Slope factor
Sediment Quality Standards
Other Factors To Be Considered
Underground Storage Tank
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DECLARATION
. FOR THE
RECORD OF DECISION
SITE NAME AND WCATION
Wyckoff/Eagle Harbor Superfund Site
West Harbor Operable Unit
Bainbridge Island, Washington
STATEMENT OF BASIS AND PURPOSE
This decision document presents the remedial action selected by the U.S. Environmental Protection
Agency for the West Harbor operable unit (aU), one of three operable units at the Wyckoff/Eagle
Harbor Superfund site, located at Bainbridge Island, Kitsap County, Washington.
The remedy was chosen in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended, and, to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on
the Administrative Record for this site.
The State of Washington concurs with the selected remedy (see Appendix B).
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by implementing
the response action selected in this Record of Decision (ROD), may present an imminent and
substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
The remedy selected in this Record of Decision addresses contaminated sediments in the West Harbor
operable unit, one of three operable units at the Wyckoff/Eagle Harbor site. This is the first Record
of Decision to be completed for the site.
Mercury contaminated sediments containing 5 mg/kg or more of mercury are considered a "principal
threat" at this operable unit. Concentrations of mercury exceed levels acutely toxic to marine life by
factors of ten or more and are significantly higher than concentrations of mercury measured in other
parts of the site. The selected remedy addresses this principal threat by requiring removal of these
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The major ~mponents of the selected remedy for the West Harbor au include:
.
further evaluation and control of potential upland sources of contamination to West Harbor
sediments;
.
excavation, solidification/stabilization (if necessary), and upland disposal of sedimentS
exceeding 5 mg/kg mercury (dry weight);
.
placement of a cap of clean sediment over areas of high concern for adverse biological effects
and potential contaminant resuspension and bioaccumulation;
.
thin-layer placement of clean sediments to enhance sediment recovery in areas of moderate
concern;
.
natural recovery and monitoring in areas predicted to achieve the long-term sediment cleanup
objective without sediment remedial action;
.
continued institutional controls to protect human health from exposure to contaminated fish
and shellfish; and
.
long-term environmental monitoring to evaluate the effectiveness of the remedy.
EPA will be the lead agency for implementing sediment remediation in the West Harbor. Source
control efforts will be coordinated with the Washington State Department of Ecology.
STATUTORY DETERMINATIONS
The selected remedy is protective of the marine environment and human health, complies with federal
and state requirements that are applicable or relevant and appropriate for this remedial action, and is
cost-effective.
The remedy uses permanent solutions and alternative treatment technologies to the maximum extent
practicable for this site. Most sedimentS in the West Harbor au are characterized by relatively low
concentrations of contamination over large areas. For this reason, treatment was not judged
practicable for most areas addressed by the selected remedy. For low levels of contamination,
sediment containment is an appropriate remedy.
The principal threat at the West Harbor au are sediments containing 5 mg/kg or more of mercury.
These more contaminated sedimentS may require treatment by solidification if they exceed regulatory
limits for the Toxicity Characteristic Leaching Procedure (TCLP). In this case, the remedy will
satisfy the statutory preference for treatment of the principal threat as an element of the remedy. If,
according to test results, sediments do not require treatment, the remedy will not satisfy this statutory
preference.
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This remedial action will result in hazardous substances above health-based and environmentally-based
cleanup levels remaining at the West Harbor QU. Consequently, a review will be conducted within
five years after commencement of remedial action, to ensure that the remedy continues to provide
adequate protection of human health and the environmenL Initiation of the 5-year review period will .
be scheduled by EP A.
9~/92
Date -
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, Dana Rasmussen
Regional Administrator
U.S. Environmental Protection Agency
Region 10
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1. OVERVIEW
The Decision Summary provides a description of the site-specific factors and analysis that led to
selection of the remedy for the West Harbor operable unit of the Wyckoff/Eagle Harbor Superfund
site. It includes information about the site background, the nature and extent of contamination, the
assessment of human health and environmental risks, and identification and evaluation of remedial
alternatives. Further information about these topics is provided in the Administrative Record for the
site, specifically in the Remedial Investigation (RI) Report (November 1989), subsequent technical
memoranda (See Table I), the Revised Risk Assessment (May 1991), and the Feasibility Study (FS)
(November 1991).
The Decision Summary also describes the involvement of the public throughout the process, along
with the environmental programs and regulations that may relate to or affect the alternatives. The
Decision Summary concludes with a description of the remedy selected in this Record of Decision
(ROD) and a discussion of how the selected remedy meets the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) and the National Contingency
Plan (NCP).
The Decision Summary is presented in the following sections:
Section 2
Section 3
Section 4
Section 5
Section 6
Section 7
Section 8
Section 9
Section 10
Section 11
Section 12
Describes general characteristics of the site and individual operable units,
Provides site history and previous investigations or enforcement activities,
Presents highlights of community participation.
Describes the scope of the response action in the context of the overall site strategy,
Presents site characteristics,
Provides a summary of site risks,
Describes the cleanup alternatives evaluated, .
Compares the analyses in terms of the EPA evaluation criteria,
Presents the selected remedy,
Documents the conformance of the selected remedy with statutory requirements, and
Describes significant changes between the preferred alternative presented in the
proposed plan and the remedy selected in the ROD.
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2. SITE WCATION AND DESCRIPTION
2.1 Site Location
The WyckofflEagle Harbor Superfund site is located on the east side of Bainbridge Island, in Central
Puget Sound, Washington (Figure 1). The site includes an inactive 40-acre wood-treating facility, the
adjacent Eagle Harbor, and other upland sources of contamination to the harbor, including a former
shipyard (See Figure 2).
Groundwater and soils at the wood-treating facility (the Wyckoff Operable Unit) are contaminated
with chemicals from the wood treatment process, primarily creosote-derived polynuclear aromatic
hydrocarbons (p AHs) and pentachlorophenol. A groundwater and oil extraction system and treatment
plant have been in operation at the facility since 1990 as part of an Expedited Response Action (ERA)
aimed at controlling releases of contamination to the harbor. Additional source control efforts and a
Remedial Investigation and Feasibility Study (RIfFS) are planned for the facility to address remaining
contamination in soils and groundwater.
Sediments in areas of the Harbor are also contaminated with PAHs and other organic compounds, as
well as metals, primarily mercury. The Environmental Protection Agency (EPA) Remedial
Investigation (RI) (CH2M Hill, November 1989) of the sediment contamination in Eagle Harbor
initially addressed the Harbor as a single unit; however, after completion of the Feasibility Study (FS)
(CH2M Hill, November 1991), EPA proposed an administrative separation of the Harbor into. two
areas, or "operable units."
Although wood-treating operations have ceased, the East Harbor Operable Unit (East Harbor OU, or
OU-I) is subject to continuing contamination from the Wyckoff facility through seeps. An interim
ROD will be completed separately for the East Harbor OU to address severely contaminated
sediments where ongoing seepage is not a significant source. A final ROD for the East Harbor is
anticipated once significant sources to remaining East Harbor areas have been controlled.
This ROD specifically addresses sediments and sources of contamination in the West Harbor
Operable Unit (West Harbor OU, or OU-3), where significant sources are believed to have been
controlled or are readily controllable. Figure 3 shows the location of the West Harbor and East
Harbor Ous, as well as the Wyckoff OU (OU-2).
2.2 Current Land Use
More than 15,000 people live on Bainbridge Island. Land use on Bainbridge Island, recently
incorporated as a city, is principally residential, with some commercial and industrial use (Figure 4).
The former City of Winslow (population 2,800) lies on the north side of the Harbor. Residences,
commercial centers, a city park, several marinas, a yacht repair yard, a bulkhead enterprise, and a
ferry terminal characterize the northern shoreline. The western and southern shores are primarily
lined with residences, farms, marinas, and a boatyard. On the south shore at the harbor mouth, the
former wood-treating facility extends into the harbor on fill.
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I
a-
Lynnwood
KITSAP PENINSULA.
SEATTLE
o
5 Miles
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10 Kilomolol'a
Mountlako
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Figure 1.
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I Wyckoff Facility
2 Bainbridge Island Boalyard (proposed)
3 Tyee Vacht Club
4 Eagledale Moorings
5 Eagle Harbor Marin.
6 Harbor Marina
7 Winslow Wharf Marina
8 Queen Cily Vachl Oub
9 City or Winslow Public Pier
10 Bainbridge Marine Services
I I Eagle lIarbor Boat Repair
(Lased from Bainbridge Marine Services)
12 DOT Ferry Maintenance Facilily
13 DOT ferry Tennin.1
Yeomalt
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Scale in Meiers
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Figure 2.
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A significant use of the harbor is ferry transport of vehicles and passengers between the City of
Bainbridge Island and Seattle. Currently, approximately twenty runs are made per day. The harbor
is also used for moorage of pleasure boats, house boats, and working boats. Fishing, crabbing, and
clam-digging were common recreational activities until 1985, when the Bremerton-Kitsap County
Health District issued a health advisory to address bacterial and chemical contamination of seafood in
Eagle Harbor. The advisory, recommending against the harvest and consumption of fish and
shellfish, has significantly reduced recreational harvest of seafood from the harbor.
Eagle Harbor is within the usual and accustomed fishing area (U & A) of the Suquamish Tribe,
whose reservation is located on the Kitsap Peninsula north of Bainbridge Island. The Suquamish
Tribe retains the right to harvest fish and marine invertebrates and to have fishery resource habitat
areas protected within the Suquamish Tribe's U & A.
2.3 Environmental Setting
Eagle Harbor is a Puget Sound embayment approximately 202 hectares (500 acres) in area, with a
watershed (Figure 4) of approximately 1327 hectares (3,280 acres). The upper harbor is shallow, but
the central channel is between 6 and 15 meters (20 to 50 feet) in depth. Several small creeks feed the
harbor, and at the harbor mouth a long sandbar called Wing Point extends southward from the north
shore.
The harbor supports several fish resources. Coho and chum salmon once used the creek on the north
shore to spawn, and fingerlings are released there regularly. The creek at the head of the harbor is a
salmon nursery, and chum may use the drainage on the south side as a spawning ground and nursery.
Eagle Harbor may also be a spawning ground for surf smelt and Pacific sand lance (Washington
Department of Fisheries, 1992). Other fish and invertebrates present in the harbor include several
flatfish species, rockfish, pile perch, cod, lingcod, crabs, and shrimp. Several shellfish species are
present in intertidal and subtidal areas.
Bainbridge Island supports a wide variety of resident and migratory birds and other wildl ife. Major
bird groups represented include waterfowl, shorebirds, gulls, songbirds, and raptors. Although
residents report sightings of bald eagles, no critical habitats are formally designated near the site.
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SEMDIOUS.RDIECM.2-DWISK GA 21
WYCKOFF/EAGLE HARBOR SITE
CITY OF
BAINBRIDGE ISLAND
EAST HARBOR OU
WEST HARBOR OU
'"
WYCKOFF OU
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150
300
600
Scale in MeIers
Figure 3
SITE OPERABLE UNITS
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CRySTAL
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-------
'"
3. SITE HISTORY AND ENFORCEMENT ACTIVITIES
3.1 Site Background
Eagle Harbor was used as a Suquamish Indian village and burial site prior to non-Indian development
in the mid-nineteenth century, and was an important shellfish harvest area for the Suquamish Tribe.
Subsequent land use was residential, timber-related, or agricultural. Starting in 1903, a major
shipyard was established on the north shore of Eagle Harbor, and wood-treating operations began on
the south shore in 1905. .
The early days of the shipyard emphasized wooden ship-building. After flourishing during World
War I, the yard slumped during the 1930's. In the 1940's and 50's, the emphasis was on construction
and repair of mil itary ships, conversion of ships to wartime use, and postwar decommissioning under
contracts with the Navy, Army, Coast Guard and other military entities. Repair contracts dwindled
into the late 19508, and in 1961 the property was sold and subsequently divided.
Wood treating operations at the Wyckoff OU began in 1905 and continued until 1988 through several
changes of ownership. Pressure treatment with creosote was the primary method of wood
preservation, although pentachlorophenol also came into use. Preservative chemicals were delivered to
the facility by barge and ship and stored in tanks on the property. Spills, leaks, and drip page entered
the ground directly or through unlined sumps. Wastewater was discharged into Eagle Harbor for
many years, and the practice of storing treated pilings and timber in the water continued until the late
1940's.
During the 1970's, efforts were made to address oil seepage on beaches adjacent to the Wyckoff OU
through inspections and recommendations. In March 1984, the National Oceanic and Atmospheric
Administration (NOAA) advised EPA and the Washington Department of Ecology (Ecology) that
samples of sediments, fish, and shellfish from Eagle Harbor contained elevated levels of P AHs in
both sediments and biota (Mal ins, 1984a, 1984b).
In August of 1984, EPA issued a Unilateral Administrative Order (UAO) requiring the Wyckoff
Company to conduct environmental investigation activities under the Resource Conservation and
Recovery Act (RCRA) Section 3013 (42 U.S.C. 96924), and Ecology issued an Order requiring
immediate action to control stormwater runoff and seepage of contaminants. Data Collected at the
time revealed the presence of significant soil and groundwater contamination.
3.2 Site Listing
The Wyckoff/Eagle Harbor site was proposed to the National Priorities List (NPL) in September
1985. Under the Washington State Hazardous Waste Cleanup Program, Ecology completed a
Preliminary Investigation of sediment contamination in Eagle Harbor (November 1986). In 1985,
NOAA completed a study relating the presence of P AHs in sediment to the high rate of liver lesions
in English Sole from Eagle Harbor (Mal ins, 1985). In March 1987, the Wyckoff Company entered
into an Administrative Order on Consent (AOC) under CERCLA with EPA for further investigation
of the facility.
-------
The site. including Eagle Harbor, the wood-treating facility, and other sources of contamination to
Eagle Harbor. was added to the NPL in July 1987. with EPA as lead agency. EPA separated the site
into the Wyckoff au and the Eagle Harbor au. initiating the RIfFS for Eagle Harbor, and using
enforcement authorities to address ongoing releases of contamination from the wood-treating facility.
3.3 CERCLA Enforcement Actions
EPA enforcement actions at the wood-treating facility after the site listing on the NPL include the
following:
.
A July 1988 AOC. under which the Wyckoff Company agreed to conduct an Expedited
Response Action (ERA). The ERA. intended to minimize releases of oil and contaminated
groundwater to the East Harbor, called for a groundwater extraction and treatment system and
other source control measures.
.
A June 1991 UAO requiring the Wyckoff Company (now Pacific Sound Resources) to
continue the ERA with some enhancements. The UAO calls for increased groundwater
ex.traction and treatment rates, improved system monitoring. and removal of sludge stored or
buried at the Wyckoff au.
A potentially responsible party (PRP) search was initiated in 1987 to identify parties potentially liable
for response costs for Eagle Harbor. and ten parties were initially notified of potential liability in
1987 and early 1988. Continued PRP search efforts resulted in the notification of an additional party
in January 1992. The liability of one of the ten parties was resolved ina bankruptcy settlement in
1991.
-'..
3.4 Eagle Harbor Remedial Investigation (RI) and Feasibility Study (FS)
CH2M Hill conducted the Eagle Harbor Rl under EPNs REM IV contract. RI fieldwork began in
early 1988. and the Rl Report was issued November 1989. Subsequent field activities were
conducted in 1989 and 1990 by CH2M Hill under the ARCS contract. These activities were
described in technical memor~~a and summarized in the FS, issued November 1991. Key technical
memoranda are listed on Table 1.
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"
.
Table 1. List of Technical Memoranda for Eagle Harbor
Memorandum Title OU" Date rmalized
Technical Memorandum on Baseline ARARs Analysis (#1) EH/WH September 1989
Technical Memorandum on Alternatives Identification and EH/WH September 1989
Screening (1f2)
Technical Memorandum on Development of Remedial Action EH/WH December 1989
Objectives (#3)
Technical Memorandum on the Geophysical Survey (#6) EH December 1989
Technical Memorandum on the Sedimentation Rate Evaluation EH/WH December 1989
(#4)
Technical Memorandum on Fish Tissue Sampling (#8) EH/WH , March 1990
Technical Memorandum on the Need for Treatability Studies (#9) EHfWH May 1990
Technical Memorandum on the Subsurface Hydrology Study (#1) EH March 1990
Technical Memorandum on Source Identification (#5) EHfWH October 1990
Technical Memorandum on Northshore Sampling (#10) WH July 1990
Technical Memorandum on Deep Sediment Sampling (#11) EH July 1990
Technical Memorandum on Marine Biota Tissue Sampling and EHfWH April 1991
Analysis (#13)
. The focus of each document is noted as EH (East Hamor OU) or WH C'Nest Harbor OU)
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4. COMMUNITY RELATIONS ACTIVITIES
Section 113(lc)(2)(B) and Section 117 of CERCLA set forth the minimum requirements for public
participation at sites listed on the NPL. The EP A has met these requirements and maintained an
active community relations program at the site.
A community relations plan for the WyckofflEagle Harbor site was prepared by Ecology in 1985 and
adopted by EPA after the site was listed on the NPL in 1987. Notice of the listing of the site was
published in the local paper, and a mailing list was compiled from a c\ip-out portion of the notice.
Currently, the mailing list comprises over 650 addresses. Fact sheets have been mailed to interested
citizens three or four times a year since the site listing.
The community has shown consistently high interest in the site. EPA and Ecology coordinated with
the Eagle Harbor Task Force, which was active from 19S5 to 1987. In 1988, public notice of the
availability of funds for a technical assistance grant (fAG) was published, and the Association of
Bainbridge Communities (ABC) applied for and received the grant. The group's volunteer technical
advisory committee and a consultant hired with the grant monies have been active in EP A's Eagle
Harbor Technical Discussion Group and regularly update the community in the ABC newsletter. The
technical advisory committee and TAG consultants meet with EPA approximately bimonthly. The
community relations plan was revised in late 1990 to reflect the existence of the TAG.
The Eagle Harbor RI Report was released to the public for review in November 1989. In December
1989, a public meeting was held to discuss the RI and to provide updated information on the Wyckoff
facility ERA. Approximately thirty residents were present.
Throughout the RIIFS, key documents were kept at the Bainbridge Island branch of the Kitsap County
Regional Library for public review. The Eagle Harbor administrative record was placed in the
library in July 1991, and is updated regularly.
In December 1991, the draft final FS and Proposed Plan for Eagle Harbor were added to the
information repository, and copies of the Proposed Plan were sent to citizens on the site mailing list.
A sixty-day public comment period began on December 16, 1991. EPA held a public meeting on
January 15, 1992 to provide information and answer community questions. An opportunity for
formal public comment was provided at a second meeting on January 30, 1992. At the request of the
public, the comment period was extended ten days to February 25, and comments from one party
who received late notice of its potential liabil ity were accepted until March 7.
Over 40 letters commenting on the proposed plan were submitted to EP A, and at least 70 citizens
were in attendance at each of the January meetings. The Responsiveness Summary (Appendix C of
this ROD) outlines and responds to the concerns voiced by the community in these forums.
The remedy selected in this ROD was selected in accordance with CERCLA, as amended, and with
the NCP. The decision is based on information in the Administrative Record for the site.
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s. SCOPE AND ROLE OF OPERABLE UNITS WITHIN THE SITE STRATEGY
Different environmental media, sources of contamination, public accessibility, enforcement strategies,
and environmental risks. in different areas of the WyckofflEagle Harbor site led to the division of the
WyckofflEagle Harbor site into operable units. As stt.ted in Section 2, the current division of the site
. is as follows:
-ou 1: East Harbor OU (subtidal sediments)
-ou 2: Wyckoff au (soil, groundwater, East Harbor intertidal sediments)
-ou 3: West Harbor OU (subtidal/intertidal sediments, and upland sources)
Coordination between the operable units is an important element of the overall site cleanup. This
ROD presents the final selected remedy for cleanup of OU 3 (the West Harbor OU) only.
This West Harbor OU ROD is intended to address chemical contamination of marine sediments,
impacts to marine organisms, and related human exposure pathways. The focus of the actions
described in Section 10 of this ROD is to control potential upland sources of contamination to the
West Harbor; address highly contaminated sediments near the shipyard which may be acting as a
source of contamination to other harbor areas, and reduce or eliminate environmental and human
health risks associated with remaining contaminated sediments.
Other types of environmental or public health problems within the site boundaries are the
responsibility of other federal, state, tribal, or local programs. Examples of problems beyond the
scope of the Eagle Harbor project include problems related to bacterial contamination and impacts to
marine organisms from physical disturbances such as propeller wash or shoreline uses. EPA
coordinates with these other programs as appropriate.
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6. SITE CHARACTERISTICS
This section summarizes information obtained during the RIIFS, including sources of contaminants,
affected media, and the characteristics of the contamination.
6.1 Scope of Remedial Investigation/Feasibility Study
The RI/FS considered Eagle Harbor as a whole. The focus of the RI was to determine the nature and
extent of contamination in the harbor, identify significant sources of contamination, and assess threats
to human health and the environment due to chemical contamination.
Existing data which met EPA's quality assurance/quality control criteria were incorporated in the
RI/FS, including data collected by Ecology in the 1986 Preliminary Investigation. As much as
possible, RIfFS field sampling, laboratory analytical and biological testing methods, and processes for
evaluating biological effects were consistent with methods and approaches developed for evaluating
conditions in Puget Sound and later incorporated in the State of Washington Sediment Management
Standards ("Sediment Standards"). The Sediment Standards are the primary Applicable 0\ Relevant
and Appropriate Requirement (ARAR) for the site.
6.2 Remedial Investigation Sampling
InitialRI field work was conducted in 1988 and included:
.
intertidal and subtidal sediment sampling and chemical analysis to determine the nature and
extent of contamination;
.
shellfish tissue sampling and analysis to evaluate biological uptake and potential human health
risks;
.
laboratory bioassays to evaluate potential acute biological effects of the contamination on
marine organisms;
.
studies of the benthic (sediment-dwelling) community to evaluate potential chronic biological
effects; and
.
collection of oceanographic data for modeling contaminant fate and transport.
Ecology's 1986 Preliminary Investigation (PI) had identified a general problem area and problem
chemicals, and had located a hotspot area of high PAH contamination. The problem areas and
chemicals were determined based on exceedance of Puget Sound Apparent Effects Thresholds (AET),
concentrations of contaminants which indicate possible biological effects.
Developed as part of the State of Washington's efforts to establish chemical standards for sediment
quality, AETs were used in the RIIFS. For a given chemical, an AET is the chemical concentration
in sediment above which specific biological effects have always been observed in Puget Sound
-------
studies. Chemical-specific AETs for Puget Sound have been developed for several different
biological tests. Table 2 lists chemical-specific AETs (for four biological tests) available in 1988.
Further discussion of AETs is provided in Section 7.
During the March 1988 field sampling for the RI, BPA collected subtidal sediment samples on an
extensive grid and analyzed them for PAHsand metals to fill data gaps from Ecology's PI (Figure 5).
These were compared to specific AETs in order to identify areas of potential biological effects.
Areas where sediment concentrations of PAHs exceeded AETs for benthic effects (i.e., effects on the
abundance of sediment-dwelling organisms) were sampled in June 1988 for an expanded list of
contaminants, including PAHs, nine Nitrogen-Containing Aromatic Hydrocarbons (NCACs), four
chlorophenols, other volatile and semivolatile compounds, and metals. The June sampling also
included collection of sediment samples for laboratory bioassays (using amphipods and oyster larvae)
and for evaluating the abundance and diversity of benthic organisms at the sample locations. The
same sampling was conducted at ten sample locations in uncontaminated embayments near Eagle
Harbor for comparison (Figure 6).
Intertidal sediment sampling was conducted in May and June, 1988, including a high, medium, and
low tide sample from each of 16 beach transects. Samples were analyzed for the same chemicals as
the June 1988 subtidal samples. At each transect, shellfish were collected and a composite sample of
tissue from each transect was analyzed. Intertidal locations near and outside the harbor mouth were
identified as background sampling transects (Figure 5, transects 1, 2, 3, 14, 15, and 16). Samples
from the intertidal background locations contained PAHs at levels comparable to the subtidal
background areas. Mercury was undetected at 0.1 mg/kg, comparable to subtidal background.
Subsequent field activities, conducted in 1989 and 1990, included sampling of beach sediments on the
north shore of Eagle Harbor to further define an intertidal hotspot and to evaluate potential PAH
contamination along the north.:shore of Eagle Harbor. Tissues of fish from Eagle Harbor and Port
Madison (See Figure 6) were analyzed for metals. In the East Harbor, a diver survey, deep sediment
coring, subsurface hydrology studies, and a geophysical investigation were conducted to determine the
extent of a known subtidal sediment hotspot, investigate potential transport of contamination from the
Wyckoff au through the subsurface, and estimate the depth of contamination. Additional fish;
shellfish, and sediment sampling was conducted in 1990 to provide more complete information about
human health risks. The results of activities subsequent to the RI were presented in the technical
memoranda listed in Table I and incorporated in the FS (November 1991).
"""","...
6.3 Nature and Extent of Sediment Contamination
The nature and extent of contamination is discussed by contaminant type (organic and inorganic) and
by location (intertidal or subtidal sediment).
Intertidal samples from Eagle Harbor were found to exceed the maximum concentrations measured at
background locations for a number of metals (Figure 7). The greatest number of metals detected and
the highest concentrations were detected near the former shipyard on the north shore. In subtidal
samples, copper and lead exceeded background by two to four times in much of the harbor, and a few
locations exceeded background values for zinc, cadmium, and arsenic. Subtidal mercury
concentrations exceeded maximum background values by betWeen two and tWenty times throughout
the harbor and were particularly high near the former shipyard (Figure 8).
-------
SEA8910US,RDIECFW-tH2IDISK EH
21 fO'"
CITY OF
BAINBRIDGE ISLAND
.837 .
825 . 801. 717
.
.843 .836 . 800.
824 8~2 . 716
EH15 .
.842 ..811 799 EH16
835 . 787. . 715
. 823. EH23 .775 . 727. .
.841 751
.834 EH21.
,.... .786 . .
.822 .810 .798 EH14 714
C» WEST HARBOR OU 774 . . .
EH20. 762 750
EH13. 713
.
Note: Samples taken during the Preliminary
Investigation (June 1985) and the Remedial
Investigation (March 1988, June 1988)
~
LEGEND
704
.
EH12
.
703
EH11
.
6848
.660
. EH06
671
. .659
. .634
EH05
. .65B
670
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669.
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...
1
. EH02
.692
.656
EAST HARBOR OU
.
631
.680
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.
643
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629.
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.
689
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...12
.628
WYCKOFF
FACILITY
...13
.627
...14
o
150
300
600
.628 Sampling station (June 1985, March 1988,
June 1988)
...9 Rllntertidal sampling transect
Scale in Meters
Figure 5
EAGLE HARBOR
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107
. .
i
I
N
I
8
SAMPLED IN MARCH 1988
SAMPLED IN MARCH AND
JUNE 1988
BREMERTON
. ~O:):J t.."t~t#S
II.JII - - -
o
2
Figure 6
Subtidal Backgrou~d Locations
.~
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Table 2
1988 Puget Sound AET for Selected Chemicals
Appan:Dt Eff- Thtabold
(Normalizcd ID Dry Weigh!)
Cbanical Amphipod' Oyste" BcothiC MicrolDx"
Metals (mrlkr dry weirht: I>I>m)
Antimony 200" ' 150' .
Anc:uic 93 700 57' 700
c..ImNm 6.7 9.6 5.1' 9.6
Chromium 270 ' 260' .
Copper 1.300'~ 390 530' 390
!.-I 660 660 450' 530
Mercury 2.1' 0.59 2.1' 0.41
Nickel >140'- ' >140"" °
Silver 6.J." > 0.56" >6.1'" >0.56"
Zinc CJ6O'~ 1.600 410' 1.600
Onanic Comoounda CIA-elk!! drY wci2ht: f)pb)
Low molecular weiaht PAH 24.000" 5.200 13.000" 5.200
Napblhalenc 2.400' 2.100 2.700 2.100
Acemphthylcne 1.300 >560' 1.300" >560'
Ac:euaphthene 2.000" 500 . 730' 500
F1uo=e 3.600 540 1.000" 540
Pbeuanthrene 6.900" 1.500 5.400" 1.500
Aalhnlceoe 13.000'~ 960 4.400" 960
2- MdbylDaphlhaleoc 1.900 670 1.400 670
Hiab molecular "'eight PAH 69.000'~ J7.ooo 69.000"" 12.000
Fhwnan1bene 30.000'~ 2.500 24.000'~ 1.700
Pyreae 16.000'~ 3.300 16.000'~ 2.600
8enz(0)8DIbnoenc 5.100" 1.600 5.100'-' 1.300
C\uy8CDC 9 .200'~ 2.800 9.200" 1.400
Beozonuonnthenea 7.800 3.600 9.900'~ 3.200
Bcuzo(o)pyrene 3.000' 1.600 3.600" 1.600
IDdc:oo( 1.2.3-od)pyrene 1.8OO'~ 690 2.600" 600
Dibenzo(o.b)anthraceoe 54()1' 230 97()1' 230
Bcuzo(g.b.i)perylcne 1.400'~ 720 2.600" 670
PbcDoIa
PbeDoI 1.200'~ 420 1.200 1.200
2-Mdbylpbcool 63 63 72' >71'
4-Mdbylpbcool 3.600 670 1.800' 670
2.4-Dimelbyl pbeaol 72' 29 210' 29
PeuIacbJoropbcool 360' >140' 690' >140'
"Baaed OD 287 818Iiooa (including rec=1lUrveys in Eagle Hubar. Elliott Bay. and Everdl HubarDOt includ~ in \be pTeYioua gcaeralioa of 1986 AE1).
"Baed OIl 56 IUIiooa (aU from C~ Bay Remediallovealigatioo 8Dd Blair W8\ervtay drulging 81Udy); .....banged.ince 1986.
ou.Ol iDcluded in the
pn:vioul gencraUoo of 1986 AE1).
"Baed OIl SO III8ticma (aU from Comma>cement Bay Remediallaveatigatioo).
~ value IIbowD exc:eecb AET pn:aenLcd in Beller et 01. (1986) bc:c8use of addition of Puget SoUDd d81l from \be Eagle Hubar. E\1ioIt Bay. or Everet1
Harbor lAUYeys.
'The value abowD it leA tbao AET preaented in Beller et aI. (1986) because of the excluaioD of chemically or biologially IIItIOtII&Ioua III8ticma from the
AET cI-.
'The value IIbowD exc:eecb AET c:IIt8blisbcd from C- Bay R<:mcd iallDveatigotioa data (Banick cI aI.. 1985) becouae of addition of Puget
Souad data preaented in Beller cI aI. (1986).
"IDdicaJa Ibat 0 dermal AET could DOt be c:IIt8bliabcd becauae there were 00 'cffcd8" ""tiOOl with cbemicaI ccmceotratioaa above \be bigbeat
eoo<:en1nIioolUDOtl3 "00 effccta' 1UIiooa.
N~ AataW: (0) indicates AET data DOt ovailable.
Sow-oe: P11. 1988<:.
-------
P AHs were extremely high in intertidal sediments adjacent to the Wyckoff facility (in the East Harbor
aU) and, to a lesser extent, near the ferry terminal (West Harbor aU). Sediment PAH
concentrations adjacent to the former shipyard in the West Harbor were lower, but were still higher
than at intertidal background stations. Subtidal samples showed heavy P AH contamination in the East
Harbor, with several high values near the fonner shipyards in the West Harbor. Estimated average
concentrations of HPAH, the high molecular weight subgroup of PAH compounds, were highest north
of the Wyckoff facility and in the central harbor, consistent with the initial PI problem areas, and
were significantly higher than background values. Concentrations of total PAH (TPAH), low
molecular weight P AH (LP AH), and NCACs followed the same general pattern. Although two of the
four chlorophenols were detected, contamination by pentachlorophenol is not widespread. Figure 9
shows ranges of TPAH measured in subtidal sediments.
On the basis of their widespread prevalence above AETs, mercury and the sixteen PAH were selected
as indicator contaminants to define areas for remediation. Areas of contamination by other organic
compounds and metals are encompassed within areas defined by PAH and mercury.
The results of the bioassays and benthic evaluations are discussed under Section 7.2 (Ecological
Assessment), while seafood contamination is discussed under Section 7.1 (Human Health Risk
Assessment).
6.4 Sources of Contamination
A technical memorandum was developed (see Table 1) to identify sources of contamination to the
harbor. Based on historical information and chemical data from RifFS sampling, the memorandum
listed probable major and minor sources of contamination to Eagle Harbor, including both historical
and ongoing sources. The wood treating facility was identified as the major source of PAH,
particularly in the East Harbor, through both past operating practices and ongoing contaminant
transport through the subsurface.
In the West Harbor, PAH contamination in nearshore sediments appears to be from combustion
products, minor spills, and pilings and piers, while subtidal PAH contamination in the West Harbor is
believed to reflect a combination of these sources, disposal practices at the former shipyard, and
releases from the Wyckoff au. Elevated concentrations of metals, particularly near the fonner
shipyard, are clearly associated with past shipyard operations, including the application, use, and
removal (by sandblasting) of bottom paints and antifoulants.
Ongoing operations at the former shipyard include a bulkhead construction business, a yacht repair
yard, and a ferry maintenance facility. These operations could be associated with continuing sources
of contamination to the harbor. Other minor sources of contamination may include other boat yards
and marinas, surface water and groundwater from contaminated areas of the shipyard, and storm
drain releases from paved parking areas and streets.
-------
. -
.
6.S Other Contaminated Media
The primary media of concern affected by contaminants in Eagle Harbor are intertidal and subtidal
sediments, as described in previous sections. Other media considered were marine surface water,
groundwater, and air.
Marine surface water and ail were not identified as media of concern. Concentrations of
contaminants in the air were considered negligible at the harbor, because the contaminants are
primarily associated with sediments which remain under water all or much of the time. Contaminant
concentrations in the marine surface water were expected to be highly dilute relative to sediment
concentrations, and would pose negligible human health risk from direct contact relative to exposure
to contaminated sediments. Ecology samples of surface water from ten Eagle Harbor locations
(provided in the FS, Appendix B3) did not exceed water quality criteria.
. EPA does not consider groundwater a medium of concern for the West Harbor au. Groundwater is
not significantly affected by the sediment contamination. Similarly, since the major source of
contamination to the West Harbor au was past direct discharges to the marine environment, the
potential for groundwater transport of contamination to the sediments is low. Wyckoff facitity
groundwater, intertidal seeps, and soil contamination are not significant sources of contamination to
the West Harbor au. These sources, and their influence on the East Harbor au, are being
addressed as part of the ongoing studies at the Wyckoff facility and East Harbor aus.
Although they are not considered environmental media, fish and shellfish tissues are of interest in
Eagle Harbor as indicators of exposure of ecological receptors to contaminated sediments. Also,
contaminated seafood may be consumed by the public. Mercury and PAR concentrations in fish and
~hellfish tissue from Eagle Harbor indicate elevated concentrations of the contaminants of concern
relative to uncontaminated areas of Puget Sound.
6.6 Depth of Concern
Sampling to evaluate the depth of contaminated sediment in the West Harbor was limited. However,
most contamination in this area appears to be in the upper half meter with the possible exception of
areas adjacent to the former shipyard where sandblasting wastes were disposed of. RI sediment
sampling focused primarily on contamination in the top ten centimeters of marine sediment,
considered the most biologically active zone in Eagle Harbor sediments.
6.7 Routes of Migration
PAR and mercury in the environment tend to adsorb to soils or sediments, particularly marine
sediments. Modeling of fate and transport of sediment-bound contaminants was conducted during the
RIfFS. East Harbor subtidal areas were identified where propeller wash (generated primarily by
ferries waiting at the terminal) creates high water velocities near the harbor bottom (Figure 10). In
these areas, fine sediments and any attached contaminants could be remobilized. The fine particles
and potentially some intermediate-sized particles may be carried up into the harbor or out of the
harbor mouth, depending on the direction of tidal flow. Coarser-grained material stirred up by
-------
WINSLOW
EH-6H
Zn4.5
~H'5H
~ Zn 6.5
V«
,,'
. ~ ""- EH.5L
'" Pb 4.5
Zn 11.6
Maximum Blekground
Sodlmlnl Conelnlfliiona
moiko
7,'
As Arsonic
N
W
I
EH.7L
Cu 6.6
Pb 24.8
lig 29.0
Zn 2.5
11
31.9
9
Cu Coppor
HO MerOJry
Pb Lead
0.\
8,0
Sb Antlmony 7.0
Zn Zinc
51.6
~
o
150
300
600
LEGEND
EH10' Station
Cu Metal
13.3 Factor Over Background Maximum
(of 31.8 mgl1<.g for Cu)
Scale in Meters
NOTE: Background stations include transects 1, 2, 3,14,15 and 16.
Figure 7.
-------
8£AS910"'8.R~AINC02""IDIS'!M II
WINSLOW
A826 AEH24
A837 @ 813
825 @ 801.
,
FERRY (
'~O
7420 0
AEHt7
@741
@765 @
753
Efil8
(!) @752
EH16
@ A
751
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8430
A836 A (Q)
824 812
o
EHI5
842@
8410
835
@
@811 799
A823 EH23 @ 787@
727@
A
EHI4
@775
EH210
@798 A786 A
, 774
EH20 0
A
834
@822 A
810
@
762
~750
N
~
EH130
~
o
150
300
600
NOTE: Background concentrations woro
less Ihnn 0, I mglKg,
, Scale In Meiers
0660
6MA 0 EH06
671
EH09 0 683h. A h.659
0 EH05 0634
.
0718 682A 0 A658
EH08 0 68IA 670
7~ @693 669@) A657 oEH03 A633
'116 704 0668 0 EH02
@ @ A692 A2.656 EAGLE
715 7~ EH070@ 680 HARBOR
@ . EHI2 0 EH04 0
0 631
67 0667 643
oEHOI
@714 0 0630
642
725 713
o A (QJ
, 701
----1"-
WYCKOFF
0628
0629 0617
0627
Measured
Mercury Concentration
(mglKg, dry welgh1)
o ~ 0.20
A 0.21. 0.40
@ 0.41.0.58
@ 0.59.0.81
@ 0.82.1.22
. 1.22.2.44
A. 2.45. 4.90
. > 4.91
Figure 8
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N
\J1
WINSLOW
o
o
150
300
600 Meters
-
LEGEND
., >1,000,000 ~glkg
B1 >100,000 ~glkg
/D > 10,000 ~glkg
V > 1,000 J.191kg
o >100 ~gl1
-------
-
/
N
a-
LEGEND
Velocities:
BoMom
. 4S em/see
30 em/see
' ~ 20 em/see
2 15 em/see
3 . 12 em/see
4 10 em/see
5 -+ .
-+ ber 01
6 . dieate num
boat leng ,
300
Scale in Melars
-
WING
POINT
_.~
1 fJ U(:
F'igure 10 . Prope1.ler n .
f Ferry
-------
.;.
propeller-induced flows would not be transported a significant distance, but would resettle in the same
general area.
On steep slopes or in shallow areas with active. boat traffic, movement of contaminated particles may
contribute to contaminant migration. In some ir..tertidal areas, wave action can suspend fine
sediments. Sheltered intertidal areas where fine particles have accumulated, such as near the mouth
of the ravine near the form~r shipyard, are unlikely to experience significant resuspension of particles
because. wave and current action in such areas is limited.
Both mercury and PAHs can be redistributed in the environment through uptake by plant and animal
speci"es and accumulation in tissues; this requires the microbial transformation of inorganic mercury to
bioavailable forms. Although generally metabolized by vertebrates, PAHs can accumulate in
invertebrate tissues. Photodegradation, chemical decay, and microbial action degrade individual PAH
compounds at different rates.
In summary, in the absence of sediment remediation, contaminant transport pathways are likely to
continue to redistribute contamination in sediments and biota in and near the harhor.
6.8 Potentially Exposed Populations
Human populations potentially exposed to contamination include children and adults who consume
contaminated fish and/or shellfish, and individuals, particularly children, who might be exposed to
contaminated intertidal sediments through dermal exposure (skin contact) or incidental ingestion.
Waterfront residences, a public park, and fishing piers provide access to potentially contaminated
intertidal beaches and harvestable seafood.
Marine organisms potentially exposed to contaminated sediments include sediment-dwelling organisms
in three major taxonomic groups: mollusca (e.g. clams), polychaeta (worms), and crustacea (e.g.
amphipods). Marine animals such as bottom-feeding fish and crabs are exposed to both contaminated
sediments and contaminated prey organisms. Animals higher in the food chain may in turn be
exposed. Thus, although the biological tests may indicate impacts to specific sediment-dwelling
organisms, these organisms are a building block of the marine ecosystem. Adverse effects at their
level signal potential impacts on the overall health of the harbor.
6.9 Principal Threat
The NCP (Section 3oo.430(a)(1» outlines expectations for Superfund actions to address "principal
threats" through treatment. Principal threats include wastes with high concentrations of toxic
compounds (e.g., several orders of magnitude above levels that allow for unrestricted use and
unlimited exposure). RI sediment samples from locations adjacent to the former shipyard contained
concentrations up to 95 mg/kg mercury, over 100 times higher than concentrations acutely toxic to
oyster larvae. Other metals are also present, and acute bioassays indicate adverse biological effects in
this area. EP A has defined sediments containing concentrations of 5 mgikg or more mercury as the
principal threat in the West Harbor. At this concentration, the oyster larvae measure is exceeded by
less than 10. Most of the remaining sediments contain less than 1.0 mg/kg mercury and, while of .
concern, are not defined as principal threats.
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7. SUMMARY OF SITE RISKS
CERCLA response actions at the West Harbor operable unit as described in this ROD are intended to
protect the marine environment and human health from risks related to current and potential exposure
to hazardous substances in the West Harbor.
To assess the risk posed by site contamination, human health and environmental risks assessments
were completed as part of the Eagle Harbor RI. Additional information gained during the preparation
of the FS was incorporated in a Revised Risk Assessment for human health. Although risks were
assessed for the harbor as a whole, this section emphasizes results from the West Harbor au.
7.1 Human Health Risk Assessment
Cancer and noncancer risks to human health were evaluated using chemical data from Eagle Harbor
and background areas. Table 3 shows the potential exposure pathways evaluated. Other exposure
pathways considered were eliminated because risks associated with these routes were not expected to
add significantly to human health concerns related to the site.
Human exposure to contamination was considered of concern in intertidal areas, where dermal contact
with and ingestion of contaminated sediments IS possible. Harvest and consumption of contaminated
fish and shellfish was also of concern. For this rf'.ason, risks from four exposure routes were
calculated, including ingestion of contaminated clams and crabs, ingestion of contar:ninated fish,
ingestion of contaminated intertidal sediments, and dermal contact with contaminated intertidal
sediments.
7.1.1 Identification of Chemicals of Concern
Sixty-five chemicals were detected in intertidal sediments and/or fish and shellfish. The risk
assessment identified 42 of these as chemicals of potential concern for human health, based on the
frequency and magnitude ot measurements in sediments and seafood from Eagle Harbor. Of these,
13 were eliminated because .~!.l.fficient information was lacking to characterize the risk or because the
concentrations observed did n6t add significantly to the total risk. The remaining 29 chemicals (fable
4) were carried forward for calculations of risk.
7.1.2 Toxicity Assessment
Toxicity information was provided in the risk assessment for the chemicals of concern. Generally,
cancer risks are calculated using toxicity factors known as slope factors (5fs). while noncancer risks
rely on reference doses.
SFs have been developed by EPA's Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic contaminants of concern. SFs are
expressed in units of (mg/kg-day)"\ and are multiplied by the estimated intake of a potential
carcinogen, in mglkg-day, to provide an upper-bound estimate of the excess I ifetime cancer risk
-------
N
\D
Table 3
Potential Exposure Pathways Retained for Risk Assessment
Contaminated
Media Exposure Point Exposure Route Potential Receptors Rationale
Intertidal sediments Residential beaches Ingestion Residents Beaches readily accessible to residents
Dermal absorption and visitors.
Intertidal sediments Industrial beaches Ingestion Workers or visitors Beaches readily accessible to workers and
Dermal absorption visitors.
Intertidal sediments Public beaches Ingestion General public Beaches readily accessible to public.
Dermal absorption
Shellfish Residential beaches Ingestion Residents Beaches readily accessible to residents
and visitors. Clams exist at beaches.
Shellfish Industrial beaches Ingestion Workers or visitors Beaches readily accessible to workers and
visitors. Clams exist at beaches.
Shellfish Public beaches Ingestion General public Beaches readily accessible to public.
Clams exist at beaches.
Pelagic or bottomfish Deeper waters within Ingestion General public Presence of fish and recreational
Eagle Harbor fishermen.
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VJ
o
Table 4
Chemicals of Potential Concern for Human Health
Chemicals Retained~ Chemicals Excluded
Semi volatile Compounds
~!:~ttRWj!1iiW1)iWj@M# r,MM! Benzoic acid 2,4.5- T richlorophenol
Dibenzofuren 2.3.4.5- T elrechlorophenol 2-Mclhylphenol
fMii¥W~~@1 4-Melhylphenol
Polycyclic Aromatic Hydrocarbons (PAH)
N@~~fi\h~!# m1~I~f~~M\f.gM~
Acenephlhylene
IE~ Fluorene
g~~Mn';!;~;$~Jmf¥.
2-Methylnephthelene
H~phm~!~M
Benzo[g.h.lJperylene Phenenthrene
Illr~~@i.M~ ~it~@
Nitrogen-Containing Aromatic Compounds (NCACs)
Acridine Indole Q¥M!1~~
Benzoquinolina Isoquinoline
!'#mU!i.~ Methylcerbazola
Volatile Organic Compounds (VQCs)
III_~ Acetone Cerbon disulfide Melhylene chloride Toluene
2-Butanone Ethylbenzene Slyrene Xylenes
Metals
~_\W Ili& Ir li~ Aluminum Cobalt Manganeae SiI,:,er
Berium Iron POlessium Sodium
. ij~Wj\@i\ Leed Celcium Megnesium Selenium Venedium
~Highlighted chemicala were evalualed quenlitatively in the RA.
Note: In Ihe intertidal aediment and shellfish semples thet were enalyzed from Eagle Harbor. 65 chemicals were detected at Icast once. The detected chemicals are presented
-------
associated with exposure at that intake level. The term "upper bound" reflects the conservative
estimate of the risks calculated from the SF. Use of this approach makes underestimation of the
actual cancer risk highly unlikely. SFs are derived from the results of human epidemiological studies
or chronic animal bioassays to which animal-to-human extrapolation and uncertainty factors have been
applied (e.g. to account for the use of animal data to predict effects on humans.)
Reference doses (RIDs) have been developed by EPA for indicating the potential for adverse health
effects from exposure to contaminants of concern exhibiting noncarcinogenic effects. RIDs, which
are expressed in units of mg/kg-day, are estimates of lifetime daily exposure levels for humans,
including sensitive individuals. Estimated intakes of contaminants of concern from environmental
media (e.g. the amount of a contaminant of concern ingested from contaminated drinking water) can
be compared to the RID. RIDs are derived from human epidemiological studies or animal studies to
which uncertainty factors have been applied.
The risk assessment relied on oral SFs and RIDs. Because dermal toxicity factors have not been
developed for the chemicals evaluated, oral toxicity factors were used in estimating noncancer risks
from dermal exposure. The noncancer toxic endpoints (e.g. the affected organs) are similar for .
dermal and oral exposure. Cancer risks from dermal exposure could not he calculated. The toxicity
factors, shown on Table 5, were drawn from the Integrated Risk Information System (IRIS) or, if no
IRIS values were available, from the Health Effects Summary Tables (HEAST). The oral SF of
benzo(a)pyrene was used for all seven carcinogenic P AHs in estimating cancer risks from ingestion.
pathways. This approach is intended to address uncertainties in the toxicity of the remaining 6 P AHs.
7.1.3 Exposure Assessment
The exposure assessment identified potential pathways for contaminants of concern to reach the
exposed population. Exposure assumptions were based primarily on EPA regional and national
guidance, except where tailored to specific site conditions {Table 6).
A 1988 Puget Sound Estuary Program (PSEP) study of seafood consumption in Puget Sound (Tetra
Tech, 1988) provided a high (95th percentile) Puget Sound consumption rate of 95.1 grams per day
of fish. This rate corresponds to 230 servings of 1/3-lb of fish over the course of a year. The high
rate for shellfish consumption was estimated to be 21.5 g/day, equivalent to a 1I3-lb serving a week.
(The study estimated that an average consumer eats at most 30 such servings of fish and 3 such
servings of shellfish per year).
The high rates above were used for the reasonable maximum exposure (RME) assumption for adults.
These assumptions were modified to develop ingestion rates for children, based on body weight
ratios. Soil ingestion and site-specific dermal exposure assumptions were also developed.
For carcinogens, risks are estimated as the incremental probability of an individual developing cancer over a
lifetime as a result of exposure to the carcinogen. Excess lifetime cancer risk is calculated by multiplying the
SF (see toxicity assessment above) by the .chronic daily intake" developed using the exposure assumptions.
These risk are probabilities generally expressed in scientific notation (e.g., 1 x 1(6). An excess lifetime cancer
of 1 x 1 Q45 indicates that an individual has a 1 in 1,000,000 chance of developing cancer as a result of site-
. related exposure to a carcinogen over a 7D-year lifetime under the specific exposure conditions assumed.
-------
The potential for noncarcinogenic effects is evaluated by comparing an exposure level over a specified time
period (e.g. lifetime) with a reference dose (see toxicity assessment above) derived for a similar exposure
period. The ratio of exposure to toxicity is called a hazard quotient. Hazard quotients are calculated by
dividing the chronic daily intake by the specific Rfd. By adding the hazard quotients for all contaminants of .
concern that affect the same target organ (e.g., liver), the hazard index can be generated.
The RME provides a conservative but realistic exposure in considering remedial action at a Superfund site.
Based on the RME, when the excess lifetime cancer risk estimates are below I X I~ or when the noncancer
hazard index is less than 1, EPA generally considers the potential human health risks to be below levels of
concern. Remedial action is generally warranted where excess cancer risks exceed 1 X 10-" (one in ten
thousand). Between 1~ and 1~, cleanup mayor may not be selected, depending on individual site conditions,
including ecological concerns.
Both average and RME risks were estimated for each of the four exposure pathways to show a range of
uncertainty. Because EPA policy dictates the use of the RME in evaluating human health risks, only RME
results are discussed in the following sections.
7.1.4 Risk Characteri7.ation
The following discussion presents summarized non-cancer and cancer risk characterization results separatdy.
Non-cancer risks:
The lifetime and child noncancer hazard indices for ingestion of contaminated intertidal sediments were well
below 1. Calculated noncancer risks from dermal contact with PAH-contaminated beach sediments (using oral
exposure Rfds) were significantly below I for both lifetime and child exposures.
Clam tissue data from 1988 and 1990 were used to evaluate noncancer risks from consumption of clams. The
1988 data yielded lifetime hazard indices from 0.6 to 1 for most Eagle Harbor and background clam sampling
locations (for child exposure assumptions, these hazard indices were between 1 and 2). Because of differences
in the mercury results, the highest hazard index based on 1990 clam tissue data was 0.07, which was lower than
1988 results.
Noncancer risks were evaluated both for consumption of fish and consumption of shellfish. Data from 1989 and
1990 fish tissue sampling were used and, as with the clam data, the 1990 results were lower. Fish tissue data
from the 1989 sampling resulted in lifetime hazard indices approaching or exceeding 1 (up to 2 for the child
exposure), while data gathered in 1990 produced hazard indices considerably less than 1 (and less than 2 for
children).
Cancer Risks:
Cancer risks from sediment ingestion were within or below EPA's acceptable risk range of 1~ to 1~. As
. noted, slope factors were unavailable to calculate cancer risks from dermal exposure to carcinogenic P AHs in
sediments.
Two data sets (1988 and 1990) were used in estimating the total excess lifetime cancer risks for consumption of
clams and yielded comparable results. Clams collected in 1988 in the West Harbor (near the ferry terminal
and the former shipyard) resulted in risk estimates from 4 x 1~ to 9 x 1~, with 1990 results as high as to 1 x
.10.3. The highest risk of 3 x 10.3 was associated with clams adjacent to the Wyckoff facility. Background clam
tissues collected near the mouth of Eagle Harbor produced risks from 1 x 1~ to 5 x 10".
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Table 5 - Human Toxicity Faclors of Chemicals Relained for Risk Quantification
Weight of Evidence Oral Slope Faclor Oral Chronic Rm
COMPOUND (mglkg-ila y)" I (mg/kg-ilay)"
Semivolatile Compounds
Bis(2~th ylhexyl)phlhalatc 82 0.014 0.02
Penlachlorophenol 82 0.\"2 0.03
Phenol 0.6
Polynuclear Aromatic Hydroc:arboos
Acenapl1lhene 0.06
Anthracene 0.3
Benzo(a)anthracene 82 11.5
Benzo(a)pyrene 82 11.5
Benzo(b)f1uoranthene 82 11.5
Benzo(k)f1uoranthene B2 11.5
Chryscne 82 11.5
Dibenzo(a,h)anthracene 82 11.5
Fluoranthene 0.04
Indeno(I.2,3)pyrene 82 11.5
Naphthalene 0.004
Pyrene 0.03
Nilrogen-Con!8ining Aromatic Compounds
(NCACs)
Carbazole ,-. 82 0.02
Quinoline C 12
Volatile Organic Compounds
Chloroform 82 0.0061
Chloromethane C 0.013 0.01
Metals
-"'-.~.'
Antimony A 1.75 0.0004
Arsenic 82 4.3 0.001
Beryllium 0.005
Cadmium 0.001
Chromium (VI) 0.005
Copper 0.037
Mercury 0.003
Nickel (in soluble salts) 0.02
Thallium (m soluble salts) 0.00007
Zinc 0.2
EPA Carcinogenic Classification: A ;: Human Carcinogen
B2 ;: Probable Human Carcinogen
C ;: Possible Human Carcinogen
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w
~
I
Table 6 - Exposure Assumptions for Human Health Risk Assessment
Exposure Assumptions for Ingestion of Seafood
Age: 2.3 yr 4-6 yr 7.9 yr 10-12 yr \3-\5 yr \6-\8 yr 19.75 yr
Reasonable Maximum Exposure (RME) for Clams and Crabs
IR: Ingestion rate (kg/meal)'" 0.047' 0.059' 0.076' 0.097' 0.122' 0.\38' 0.151'
FI: Fraction ingested (unitless)' 1 I I 1 I 1 1
EF: Exposure frequency (meals/year)' 52 52 52 52 52 52 52
ED: Exposure duration (years)' 2 3 3 3 3 3 57
BW: Body weight (kg)' 12 17 25 36 51 671 70
ATn: Averaging time for noncarcinogenic effects (days' 730 1,095 1,095 1,095 1,095 1,095 20,805
ATc: Averaging time for carcinogenic effects (days)' 27,375 27,375 27,375 27,375 27,375 27,375 27,375
Reasonable Maximum Exposure (RME) for Fish
IR: Ingestion rate (kg/meal)'" 0.206' 0.260' 0.336' 0.428' 0.540' 0.609' 0.668'
FI: Fraction ingested (unitless>' 1 I I 1 \ I I
EF: Exposure frequency (meals/year)' 52 52 52 52 52 52 52
ED: Exposure duration (years). 2 3 3 3 3 3 57
BW: Body weight (kg)' \2 17 25 36 5\ 61 70
ATn: Averaging time for noncarcinogenic effects (days)' 730 1,095 1,095 1,095 1,095 1,095 20,805
ATc: Averaging time for carcinogenic effects (days)' 27,375 27,375 27,375 27,375 27,375 27,375 27,375
Equation fnr ingestion of fish ond shellfish (EPA, July 1989c):
Intake (mg/kg-day) '" concentration (mR/kR) x IR x FI x EF x ED
BW x AT
'Tetra Tech, 1988.
'P. Cirone, EPA Region 10, personsl communication, 1991.
'EPA, July 1989c.
'EPA, January 1990.
'The amount ingested was scaled down to lhe 2/3 power oflhe ratio of child to adult body weight (P. Cirone, EPA Region 10, personal communication, 1991)
'0.151 kg shellfish/meal x 52 mcals/year x I year/365 days x 1,000 g/kg = 2t.5 g/day. This is the high ingestion rate computed from the Puget Sound study (Tetra Tech, (988).
-------
A single data set from 1990 was available to evaluate cancer risks from Consumption of fish and crabs. Risk
levels depended on the type of tissue (whole fish, fish muscle, crab muscle, hepatopancreas). The highest risk
from this route was 1 x lO"3 for consumption of whole perch. For all other tissues, both Eagle Harbor and
background samples produced results in the to-" range; however, the data for the PAR contributing most to the
risk calculations for fish consumption were qualified as estimates in these samples.
Summary:
The risk assessment discussed uncertainties associated with the calculated risks. Among the uncertainties are the
absence of complete toxicity information for all chemicals measured, uncertainties and variability in site data,
the potential for other contaminants such as polychlorinated biphenyls (PCB) and dioxin in seafood, and
uncertainties associated with exposure assumptions. The uncertainties can result either in underestimates or
overestimates of the true health risks associated with the site.
In summary, chemical concentrations in Eagle Harbor sediments and seafood are elevated with respect to
background locations, but the associated human health risk estimates are within or below EPA's range of
acceptable risks for exposure to sediment contaminants through dermal contact and sediment ingestion. For
seafood ingestion, calculated cancer risks are generally between lQ4 and lQ-6 at both Eagle Harbor arid
background locations. Consumption of shellfish from specific areas (such as West Harbor areas near the former
shipyard and the ferry terminal) result in risks above lQ4. While similar results were obtained for certain
tissues, such as whole perch, sole muscle, and crab hepatopancreas, uncertainties in the data should be
considered. Similarly, while noncancer hazard indices for seafood consumption at both Eagle Harbor and
background locations were as high as 1 in 1988, subsequent data resulted in significantly lower values.
Human health risks for Eagle Harbor are thus primarily associated with the consumption of contaminated
shellfish. In the West Harbor, the cancer risks in the 10"3 range were associated with clam tissues from areas
near the ferry terminal and the former shipyard.
7.2 Ecological Assessment
The Eagle Harbor ecological assessment focused on biological effects in subtidal areas. During the RI,
sediment chemical and physical data were collected, laboratory bioassays were conducted on subtidal sediments,
and evalUations of the existing benthic communities were completed. Available information from previous
studies and research was incorporated as appropriate. Although clam tissue and sediment chemical data were
developed for evaluating intertidal areas, the emphasis in intertidal areas was on evaluating potential human
health risks.
The assessment of ecological risks relied on the "triad approach" which links contamination to specific adverse
ecological effects using a preponderance of field and laboratory evidence. The three elements of sediment
chemical analyses, laboratory toxicity tests (bioassays), and evaluation of the abundance of benthic organisms
from specific locations are used in combination as the three elements of the triad approach. The approach was
used to develop the Puget Sound AETs, and these chemical concentrations, in conjunction with site-specific
biological data, formed the basis of the ecological assessment in Eagle Harbor.
As described in Section 6, an AET, or" Apparent Effects Threshold,. is the concentration of a chemical in
sediment above which a particular adverse biological response has always been observed. Generally, for any
one chemical, different biological indicators are associated with different levels of chemical contamination,
leading to a range of AETs (e.g., for benthic effects, amphipod toxicity, oyster larvae effects, and microtox
responses) for each compound (See Table 2, Section 6). .
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7.2.1 Chemicals of Concern
RI sampling of Eagle Harbor sediments included a broad range of metals and organic compounds of potential
concern for environmental risk. Contaminants of concern were identified for the ecological assessment based on
information about their effects in the marine environment. For this reason, not all were the same as the
contaminants of concern identified for human health.
Sediments in Eagle Harbor exceeded 2.1 mglkg, the high AET (HAET) for mercury, at several stations sampled
during the RI, and exceeded two AETs (for oyster larvae and microtox) in most remaining contaminated areas.
Above the HAET, AETs for four biological measures are exceeded. Individual P AHs exceeded ,their respective
benthic AETs in much of the harbor, and at several locations all sixteen PAH compounds exceeded their benthic
AETs. Based on the comparison of the concentrations in Eagle Harbor samples with the 1988 benthic AETs for
Puget Sound, EPA selected mercury and all sixteen PAHs as contaminants of concern. These contaminants are
used as indicators of the extent of contamination. Toxicity information for P AH and mercury was summarized
in'the ecological risk assessment.
Contaminants that exceeded AETs at only one or two locations were not carried forward as contaminants of
concern for the ecological risk assessment. These locations are included within areas of concern for mercury or
PAHs, and cleanup for PAHs and mercury would also address these contaminants.
7.2.2 Biological EfTecl~
Laboratory bioassay results from Eagle Harbor samples were grouped by sediment grain size and statistically
compared with control samples and background samples. Bioassays for acute toxicity indicated that sediments
from the majoriiy of sampled locations in the East Harbor, and from several locations in the West Harbor, were
toxic to amphipods, oyster larvae, or both. In general, the bioassay responses were most severe in areas of
high PAH contamination.
The test species used in amphipod toxicity tests (Rhepoxyn;us abronius) resides in Puget Sound and is a member
of a crustacean group that forms an important part of the diet of many estuarine fish. Amphipods are sensitive
to many chemical contaminants, and species such as R. abronius have a high pollutant exposure potential
because they burrow into the sediment and feed on sediment material. The oyster larvae used as a test species
(Crassostrea gigas) resides in Puget Sound and supports commercial and recreational fisheries. The life stages
tested (embryo and larva) are very sensitive stages of the organism's life cycle. The primary endpoint is a
sublethal change in development that has a high potential for affecting larval recruitment.
Benthic infauna are valuable indicators because they live in direct contact with the sediments, they are relatively
stationary, and they are important components of estuarine ecosystems. If sediment-associated impacts are not
present in the infauna, then it is unlikely that such impacts are present in other biotic groups such as fish or
plankton unless contaminants are bioaccumulating at levels significant for higher food~hain organisms.
During the RI, replicate benthic infauna measures were not conducted at each station in Eagle Harbor.
Consequently, statistical comparisons of benthic abundance data between individual stations was not possible.
Overall, there was a greater abundance of polychaetes in Eagle Harbor than in the background areas, which
could indicate a predominance of pollution tolerant organisms. However, no statistically significant difference
relative to background areas was observed for molluscs, amphipods, and other crustacea.
Other benthic studies of Eagle Harbor tend to support the indication in the RI that, while sediment
contamination is present above the AETs, adverse effects on benthic communities may not be occurring at the
-------
level of major taxa (polychaeta, molluscs, amphipods, other crustacea) in most subtidal areas of the West
Harbor.
Additional evidence of biological effects in Eagle Harbor includes the prevalence of liver lesions and tumors in
English sole, as documented by NOAA (Malins, 1985). The high incidence of such effects in Eagle Harbor
relative to other Puget Sound embayments was confirmed in the Puget Sound Ambient Monitoring Program
1991 sampling. This and laboratory research citing the effects of PAH and other sediment contaminants on
marine organisms add to the preponderance of evidence already indicating potential damage to Eagle Harbor
marine life. In addition, PAR and metals in the tissues of fish and shellfish indicate uptake of sediment
contamination. Mercury tends to bioaccumulate in fish, while PAHs can bioaccumulate in some invertebrates.
Uncertainty in the ecological assessment is associated with data variability, spatial variability of contamination
and benthic communities, potential biological effects of organic enrichment, grain size, and physical
disturbance, and the availability of appropriate background locations for comparison.
In summary, biological risks due to contamination in the West Harbor are evidenced by documented acute
toxicity of sediments near the former shipyard and at some locations in the central channd, by predicted adverSe:
effects of other sediments above AETs, and by the widespread presence of mercury and PAHs, whith can
accumulate in the tissues of food chain organisms.
7.3 Summary of Risk Assessment
Actual or potential releases of hazardous substances from the West Harbor OU, if not addressed by
implementing the remedial action selected in this ROD, may present an inumnent and substantial endangerment
to public health or welfare, or the environment.
Based on the RI, the risk assessments, and available information, cleanup of the West Harbor OU is warranted.
Consumption of shellfish from certain intertidal locations of the West Harbor pose a human health risk above
the acceptable risk range. Sediment cleanup is expected to result in reductions of contaminant levels in fish and
shellfish, and over the long term, sediment cleanup and natural recovery may eventually reduce risks to levels
comparable to background. However, the correlation between fish or clam tissue contamination and sediment
chemical concentrations is not sufficient to develop sediment cleanup levels corresponding to specific reductions
in human health risks.
Adverse biological effects have been documented in portions of the West Harbor and are predicted by the
contaminant concentrations present. Most of the biological effects observed are associated with areas of heavy
sediment contamination. Potential redistribution of contaminants through sediment redistribution from heavily
contaminated areas is also of concern, as is the potential for uptake by marine organisms. Where chemical
information predicts significant adverse effects on benthic organisms but redistribution and biological uptake are
not of concern, cleanup is warranted unless the absence of adverse biological effects at levels of concern is
documented.
7.4 Special Site Characteristics
Investigation and remediation of sediment contamination pose inherent challenges. as hriefly indicated below:
1) the accumulation of contaminants at the sediment-water interface. a significant zone for habitat and
food sources, creates complex and sensitive ecological conditions and can lead to contaminant transfers
through the food chain;
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2) contaminants that accumulate in sediments are generally dispersed from their sources, resulting in
relatively large areas of low level contamination;
3) surface sediment contamination reflects both historical and on-going contamination, because marine
biological activity in the biologically active tlJp layer mixes recently deposited sediments with existing
sediments and because physical disturbances such as cUlTents or propeller wash can redistribute surface
contamination;
4) the relatively large volumes of sediments requiring remediation can present problems regarding
disposal site availability and capacity; and
5) underwater conditions compound the technical challenges associated with assessing, controlling, and
remediating contamination of environmental media.
Remediation of Eagle Harbor sediments is further complicated by the active use of the harbor. Cleanup
activities will require coordination and planning in nearshore areas, subtidal leased lands, residential moorage
locations, and the navigational pathways used by the Washington State Ferries. These and other special features
of a marine sediment site have been considered in the RifFS and this ROD.
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8. DESCRIPrION OF ALTERNATIVES
This section briefly summarizes the identification of cleanup areas in the West Harbor, discusses common
elements of the cleanup alternatives developed in the November 1991 FS, and provides infonnation"about
alternatives, including estimated costs and volumes.
The FS identified a number of sediment cleanup technologies, of which nine were developed into detailed
alternatives and further evaluated. The active remedial alternatives included in-place alternatives involving
treatment or containment options and removal alternatives requiring excavation or dredging of sediments with
subsequent treatment andlor containment of the sediments. No Action, or allowing the site to recover naturally,
was also evaluated.
In addition to the nine FS alternatives above, the Proposed Plan, issued December, 1991, introduced
Supplemental Alternative N (Low-Impact CappinglThin Layer Placement). This alternative was developed as a
means of accelerating the harbor recovery rate by providing a source of clean sediment for distribution in areas
with marginal exceedance of the Sediment Standards chemical cleanup levels.
Three other alternatives, Alternative F: Removal, Consolidation, and Upland Disposal, Alternative 1: Removal,
Treatment by Soil Washing, and Disposal, and Alternative K: Removal, Treatment by Solvent Extraction, and
Disposal, were eliminated from detailed evaluation for a variety of reasons including uncertainty about waste
characteristics, process complexity, treatability, and the availability of more suitable options.
Table 7 lists the alternatives evaluated and indicates the areas for which they were evaluated. Descriptions of
the alternatives retained are provided in Section 8.3.
8.1 Estimated Cleanup Areas
As noted in Section 6, the State of Washington Sediment Management Standards (Sediment Standards) are a
primary ARAR for this site. Promulgated on April 27, 1991, the Sediment Standards provide a process for
defining sediment cleanup sites by comparing site chemical data to chemical criteria. Collection of biological
data is optional, but if specific biological information meets the biological criteria of the Sediment Standards,
these results determine whether or not sediments meet the Sediment Standards. The Sediment Standards provide
biological and chemical criteria for both a minimum cleanup level (MCUL) and the more stringent sediment
quality standards (SQS), as shown in Tables 8 and 9.
Figure 11 shows where sediments exceed these chemical criteria, indicating a minimum and maximum cleanup
area on the basis of MCUL and SQS chemical criteria alone. In the West Harbor QU, this results in potential
cleanup areas ranging from approximately 220,000 m2 (based on the MCUL chemical criteria) to 330,000 m2
(based on the SQS chemical criteria), or from 55 to 82 acres. Present biological data for the harbor do not
completely satisfy the biological requirements of the Sediment Standards. However, they do suggest that many
portions of the Harbor are less toxic than the chemistry would indicate.
For this reason, reduced areas of probable biological effects were estirnated in the FS using available acute
toxicity data, assumptions about potential chronic biological effects, and best professional judgment. The
purpose of estimating these preliminary areas was to estimate costs and compare cleanup alternatives. (Areas
and costs are further refined in Section 10. Additional refinement will be necessary during the remedial design
phase. )
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Table 7 - Screening of Alternatives
Problem Area
Intertidal
Sediments
Subtidal
Sediments
Alternative
Mercury
PAH
Mercury
A.
No Action
. .
. .
. .
. .
. .
.
.
.
.
B.
Institutional Controls
C.
Capping
D.
Removal, Consolidation, and Confined Aquatic
Disposal
.
E.
Removal, Consolidation, and Nearshore Disposal
-
G.
Removal, Consolidation, and Upland Disposal at
a Commercial RCRA Landfill
H.
Removal, Treatment by Incineration, and
Disposal
Removal, Treatment by Solidification!
Stabilization, and Disposal
-
-
I.
L.
Removal, Treatment by Biological Slurry, and
Disposal . .
In Situ SolidificationlStabiliution
M.
N.
Low-Impact CappinglThin Layer Placement
.
.
.
. Alternative carried forward for area and contaminant indicated.
Not carried forward.
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Table 8
Sediment Standards Chemical Criteria
for Mercury and PAR'
ContamiDant SQS> MCUL'
Men:ury 0.41 mgflcg (dry weight) 0.59 mgflcg (dry weight)
IDdividual PAHs &lid PAil groups units of mgflcg organic carbon' units of mg/lcg organic .carbon'
LPAH' 370 780
Naphthalene 99 170
Acenaphthylene 66 66
Acenaphthene 16 57
Fluorene 23 79
Phenanthrene 100 480
Anthracene 220 1,200
2-Methylnaphthaler.e 38 64
HPAH" 960 5,300
Fluoranthene 160 1,200
Pyrene 1,000 1,400
Bcnz(a)anthracene 110 270
Chryaene 110 460
TOIal benzofluoranthenes' 230 450
Bcnzo(a)pyrene 99 210
lndeno(l,2,3-c,d)pyrene 34 88
Dibenzo(a,b)anthracene 12 33
Bcnzo(g,b,i)perylene 31 78
I Where laboratory analysis indicates a chemical is not detected in a aediment sample, the detection limit sbaIl be reported and shall be
at or below the criteria value shown in this table. Where chemical criteria in this table repreaent the sum of individual compounds or
isomers, and a cbemical analysis identifies an undetected value for one or more individual compounds or isomers, the detection limit
shall be used for calculating the sum of the respective compounds or isomers.
. Sediment Quality Standards
. Minimum Cleanup Level
. The listed chemical parameter criteria repreaent concentrations in par1S per million, "normalized," or expressed, on a total organic
carbon basis. To normalize to total organic carbon, the dry ,weight concentration for each parameter is divided by the decimal
fraction repreaenting the pen:ent total organic carbon content of the aediment.
. The LPAH criterion represents the sum of the following "low molecular weight polynuclear aromatic hydrocarbon" compounds:
Napthalene, Acenapbthylene, Acenapbthene, Fluorene, Phenanthrene. and Anthracene. The LPAH criterion is not the sum of the
criteria values for the individual LP AH compounds as listed.
6 The HPAH criterion repreaents the sum of the following "high molecular weight polynuclear aromatic hydrocarbon" compounds:
Fluorantbene, Pyrene, Bcnz(a)anthracene, Chryaene, Total Bcazofluorantbenes, Benzo(a)pyrene, lndeoo(l,2,3,-c,d)pyrene.
Dibenzo(a,b)anthracene, and Bcnzo(g,b,i)perylene. The HPAH criterion is not the sum of the criteria values for the indivisual
HPAH compounds as listed.
, The TOTAL BENZOFLUORANTHENES criterion represents the sum of the concentrations of ,the "B,", "J," and "K", isomers.
-------
SQS. Biological Criteria
Table 9- Sediment Standards Biological Criteria
MCULb Biological Criteria
Sediments are detennined to have adverse effccts on
biological resources when anyone of the confirmatory
marine sediment biological tests of WAC 173-204-
315(1) demonstrate the following results:
(a) Amphipod: The test sediment has a higher mean
mortality than the reference sediment and the test
sediment mean mortality exceeds 25%, on an absolute
basis.
(b) Larval: The test sediment has a mean survivorship
of normal1arvae that is less" than the mean normal
survivorship in the reference sediment and the test
sediment mean normal survivorship is less than 85%
of the mean normal survivorship in the reference
sediment (i.e.. the test sediment has a mean combined
abnormality and mortality that is greater than 15%
relative to time-final in the reference sediment).
(c) Benthic abundance: The test sediment has less than
50% of the reference sediment mean abundance of any
one of the following major taxa: Crustacea, Mollusca,
or Polychaeta, and the test sediment abundance is
statistically different' from the reference sediment
abundance.
(d) Juvenile polychaete: The tcst sediment has a mean
biomass of less than 70% 01 the reference sediment
mean biomass and the test sediment biomass is
statistically different' from the reference sediment
biomass.
(e) Mierotox: The mean light output of the highest
concentration of the test sediment is less than 80% of
the reference sediment, and the two means are
statistically different.
The MCUL is exceeded when any two of the
biological tests exceed the SQS biological criteria; or
one 0 f the following test determinations is made:
(i) Amphipod: The test sediment has a higher mean
mortality than the reference sediment and the test
sediment mean mortality is more than 30% higher
than the reference sediment mean mortality, on an
absolute basis.
(ii) Larval: The test sediment has a mean survivorship
of normal larvae that is less" than the mean normal
survivorship in the reference sediment and the test
sediment mean normal survivorship is less than 70%
of the mean normal survivorship in the reference
sediment (i.e., the test sediment has a mean combined
abnonnality and mortality that is greater than 30%
relative to time-final in the reference sediment).
(iii) Benthic abundance: The test sediment has less
than 50% of the reference sediment mean abundance
of any two of the following major taxa: Crustacea,
Mollusca, or Polyehaeta and the test sample
abundances are different' from the reference
abundances.
(iv) Juvenile polychaete: The test sediment has a
mean biomass of less than 50% of the reference
sediment mean biomass and the test sediment biomass
is statistically different' from the reference sediment
biomass.
. Sediment Quality Standards
b Minimum Cleanup Level
, Statistical Significance is defmed with a test, p less than or equal to 0.05.
Test results from at least two acute effects tests and one chronic effects test shall be evaluated. The biological
tests shall not be considered valid unless test results for the appropriate control and reference sediment samples
meet the performance standards described in WAC 173-204-315(2).
-------
The preliminary cleanup areas from the FS (listed in Table 10) are used in the following discussion and are
identified by predominant contaminant (i.e., mercury or PAR) and physical location (i.e.; intertidal or subtidal).
For subtidal sediments, areas and cost estimates include a lower and a higher estimate.
Cleanup areas in the West Harbor include the subtidal mercury area (low and high estimates), intertidal mercury
area, and the intertidal PAH area. Costs for cleanup of the West Harbor intertidal PAH area (adjacent to the
ferry terminal) were calculated as one third of the FS cost estimates for the intertidal P AH areas in the harbor
as a whole. The area estimates in Table 10 fonned the basis for the costs summarized on Tables 12a, 12b, 12c,
and 12d. .
Table 10
FS Preliminary AreaslVolumes for the West Harbo~
Area Volume
Prohlem Area (sq m) (cu m)
Intertidal Mercury 14,000 7,000
Intertidal PAH 20,000 10,000
Subtidal Mercury
Lower-bound area 50,000 25,000
Upper-end area 125,000 63,000
. Volume estimates assume a depth of 0.5 meters. Most contamination in the west harbor is not
expected to exceed this depth.
The dark shading of Figure 12 indicates where the Eagle Harbor bioassays failed one or more of the MCUL
biological effects criteria. In remaining areas above the chemical criteria (Figure 11), uncertainty exists about
potential adverse biological effects. In order to meet the Sediment Standards biological criteria, at least three
different biological measures-two acute and one chronic-must meet the criteria.
A number of locations in the West Harbor met criteria for two acute tests or for a chronic and an acute test.
No location has complete information for comparison to the biological criteria, however. Areas of the West
Harbor may meet the biological criteria if tested. Without further testing, however, actual cleanup areas must
be based on chemical data onl y .
8.2 Common Components of Alternatives
A number of remedial alternatives evaluated in the FS share certain components. For alternatives involving
dredging or capping, common elements include methods of sediment removal and placement, field analytical
methods, and the need for turbidity control. For alternatives which include treatment. common elements include
the need for sediment storage areas, pretreatment processing, treatment sites. treatahility studies, wastewater and
stormwater storage and treatment, and fugitive air emission controls. Table 11 shows which elements are
associated with the alternatives considered. Further detail is provided in the FS. Potential navigational
constraints were considered for all of the active remedial alternatives.
-------
~
~
Table 11
Summary of Common Components for Remedial Alternatives
Type of Dredsins,
Excavation I or MixinS Prclreatmenl
Tu~idity Tempo",ry Neanhore T reatmenl 01 Debri. Sediment Slo",se and Treotment S-year review
AlternoLive Mcchonicol Hyd",ulic Control Sedimenl SIo",S<' Wyckoff Property Removol ReoizinS DewOlcrinS or WD.ltewlter Mandoted by CERCIA'
A. No Acllon .
B. In.litulionol Control. .
C. CoppinS ., .0 . . .
D. Removol, COnJolidoLion,
and Confined Aquolic . .' . . .
Di.po.ol .:~
E. Removal, COlUloltctation. . .' . . .
and Neanhore Di.poool
O. Removal, Consolidation,
and Upland Di.po.ol 01 o . . . . . . .
Commerciol RCRA LondfiU
H. Removol, Treatment by . . . . . . . . .
Incine",lion, ond Diopoool
\. Removal, Trutment by
Solidificolionl Stabiliulion, . . . .1 . . .
and Diopoool
L. Removal. Trutment by
Biologicol Slurry, and . . . . . . . . .
Dispo.al
M. In Situ SOlidificolionl . . . . .
Stabilizolion
N. Low.lmpact CappinslThin . . . . .
layer Plocement
'It h.. been ..ourned thai impot1ed fiU for the inlCrtidal cap would be mcchonicaUy placed.
'It h.. been ...urned that clean oedimenl for the lubtidal Clp would be hyd",ulicoUy dredsed.
'II h.. been ..ourned thol the CAD pil would be hyd",ulicaUy dredged.
'It h.. been ...urned thai the cop would be hyd",ulicaUy dredged (excluding the ourface loyer that would be imported fiU).
'If only 0 .mon volume of .ediment io treated (e.s. inlCrtidal mercury) then ICmpo"'ry neonhoR .edimenl.loroge would nol be needed.
~f only the mercury orca io treated, the treotmtnllocolion h.. been ...urned 10 be the .hore. i
'1be S.yeor Rview would be conducted with oU allCrnaliv...
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SEA69104.PS.RO/ECRI8.19-92/DISK EH 21
~
\J1
CITY OF
BAINBRIDGE ISLAND
EH138
~RBaR au
. ~ 688
Note: Samples taken during the Prelimina!y
Investigation (June 1985) and the Remedial WYCKOFF
In~veNstiga110n (March 1988, June 1988) f LEGEND FACILITY
8628 Sampling station (June 1985, March 1988,
June 1999)
o Only one PAH exceeds Sedi",ent Cleanup Levels
Chemical Criterion .
lSSJ Exceeds SeJiment Quality Standards Chemical Criteria
£SZ:J Exceeds Sediment Cleanup Levels Chemical Criteria
tZZJ Intertidal HPAH area
I
13
701
689
o
150
300
600
Scale in Meters
., 8816
'. t I
Figure 11
AREAS EXCEEDING
SEDIMENT STANDARDS
-------
9EAB9101.P9.RDlECIW.:\09:M)19K EH
21/GFA
CITY OF
BAINBRIDGE ISLAND
. 660
684-
- EH06
.659
.634
-658
I
J:'-
a-
20
8EH17
8837 8;5 ~"3 "~89 ~1'~)5 87538741
.,., .,,. ,;. ,~, ~eH,' 'H" E~" .",
799 EH16
.842 835 ,811. 787- 8
8841 8 8238 EH23 - 775 7~1
EH21-
.834 - 822 - 81 0 . 798 . 786 774 (f:ii!j11) -
EST HARBOR OUEH20. \\1~2' 750
- 657 8 EH03 - 633
-668
- EH02
8656 EAST HARBOR OU
Note: Samples taken during the Preliminary
Investigation (June 1985) and the Remedial
Investigation (March 1988. June 1988)
~
. EH04
8667
-
643
-
631
8EH01
-630
(~IIII~t1
~EGEND
.628 Sampling station (June 1985. March 1988.
June 1988)
rrr} Approximate area showing sediment cleanup
-.-.J bioassay failures
o
150
300
600
Scale in Meters
Figure 1 2
AREAS EXCEEDING SEDIMENT
STANDARDS MCUL
-------
In addition, all the alternatives include one or more of the following elements:
-institutional controls
-source control
-natural recovery
-sampling during remedial design
-monitoring during and after cleanup
A brief discussion of each is provided below.
8..2.1 Institutional Controls
Institutional controls for Eagle Harbor consist mainly of public warnings to reduce potential exposure to site
contamination, particularly ingestion of contaminated seafood. Provided the controls protect public health and
the environment and meet existing state and federal environmental requirements, institutional controls alone can
be considered a remedial alternative.
At Eagl~ Harbor, continuation of the existing health advisory was considered as an individual altern2tive
(Alternative B). It was also considered in conjunction with. all of the active remedial alternatives because
implementation of remedial action may take several years and may not reduce contaminant concentrations in
seafood to acceptable levels for some time. In any event, the Kitsap County Health District is likely to continue
its health advisory due to bacterial contamination of Eagle Harbor shellfish.
8.2.2 Source Control
Source control in a dynamic environment such as a harbor can be difficult to achieve. Sources may include
discharges, runoff, or spills directly to the beaches or the water, as well as releases through more indirect
pathways such as groundwater transport, seepage, or air deposition. In addition, more heavily contaminated
sediments in one area of a harbor may be dispersed to other less contaminated areas.
During the RI/FS, EPA evaluated sources of contamination to Eagle Harbor. Based on this evaluation, past
practices contributed to initial contamination, and environmental processes continue to transport contaminants to
other areas. EPA expects that potential ongoing releases from West Harbor upland areas are minor and can be
readily controlled. Cleanup actions at the Wyckoff OU are anticipated to control significant contaminant
sources to East Harbor sediments, and it is anticipated that potential transport of contaminated sediments from
the East Harbor will be minimized by coordinated sediment remediation in heavily contaminated areas of the
East Harbor au.
Source control as an element of remedial action would be required for all of the active remedial alternatives.
For No Action and Institutional Controls, cleanup of other operable units would be the only contribution to
source control conducted under Superfund authorities. Details anq costs of source control efforts are not
included in the individual FS alternatives. They will be refined during remedial design.
8.2.3 Natural Recovery
Mathematical modeling was conducted during the RIfFS to evaluate the potential for natural recovery of
contaminated Eagle Harbor sediments. A watershed model was used to estimate sedimentation rates (See Table
1, Technical Memorandum #4, 1989). Since Eagle Harbor is not fed by a river or other major upland sources
of sediment, estimated sedimentation rates in Eagle Harbor were relatively low. Contaminant sources were
-------
assumed to be controlled, and existing information was used to develop estimates for.HPAH degradation rates,
loss by advection (sediment movement), and other natural processes (Feasibility Study, Appendix Dl).
For the West Harbor, na~ral recovery was predicted to be most effective in intertidal areas containing PAHs
but without metals contamination. Intertidal areas have an active water regime and are exposed to light and air,
which encourages microbial and chemical degradation of PAH. .
All of the subtidal sample locations in the West Harbor, except one near the fonner shipyard, were predicted to
achieve the sediment cleanup objective (MCUL) for PAHs within ten years. Mercury does not degrade,
however, and site-specific information about rates of mercury methylation, biological uptake and dispersion
through the food chain is limited. Sedimentation is anticipated to be the primary means of natural recovery.
Due to the low sedimentation rates estimated, only minor reductions in subtidal metals concentrations are
predicted over the ten year period. In the more heavily contaminated areas near the fonner shipyard, natural
recovery is very unlikely.
The Sediment Standards allow mathematical modeling as a means to identify areas where natural recovery could
occur in ten years without active remediation. Because the natural recovery evaluation in the FS did not predict
natural recovery for most areas of Eagle Harbor, the cleanup areas discussed are based on current.conditions.
However, additional mathematical modeling approved by EPA could be conducted where contamination is near
the cleanup level to better define areas expected to recover in ten years. If so, key assumptions and their
significance should be evaluated, additional site data obtained, and modeling methods agreed on.
8.2.4 Sampling During Remedial Design
Although extensive source, chemical, and biological information has been collected during the RIfFS and
previous studies of Eagle Harbor, some sampling may be necessary during remedial design to refine estimated
cleanup areas or volumes, and to detennine waste characteristics.
The Sediment Standards define two sets of biological criteria which correspond to the minimum cleanup level
(MCUL) and sediment quality standards (SQS) chemical criteria. The results of optional biological tests
conducted according to the Sediment Standards override the chemical information for a given location.
Although biological testing has been conducted in Eagle Harbor, the level of benthic information required to
override the chemical data was not obtained. Sampling and testing to obtain complete biological information are
considered an option for remedial design, and could affect the size of the cleanup areas. Additional sampling
during remedial design could include chemical sampling to refine areas of sediment requiring cleanup. Such
sampling is assumed for all alternatives other than No Action and Institutional Controls.
For removal alternatives, waste volumes and characteristics would be necessary, and for some treatment
alternatives, treatability tests may be required during remedial design.
8.2.5 Monitoring
Physical, chemical and biological monitoring after cleanup will continue as long as necessary. Monitoring
during implementation of remedial actions is important to assess short term environmental and human health
effects and to continn compliance with the selected remedial design.
-------
Monitoring after remediation is also critical, for several reasons:
o
to evaluate potential sources and the effectiveness of source control efforts.
o
to confinn the success of the remedy and attainment of the cleanup objectives.
o
to confinn predicted natural recovery.
o
to determine the need for continued institutional controls,
o
to evaluate improvements in the overall health of the harbor.
For FS cost estimates, monitoring was assumed to continue for thirty years and generally included chemical and
biological monitoring, tissue sampling, and monitoring of treatment areas as appropriate. Monitoring costs are
included under operation and maint.enance (0 & M), and vary according to the different alternatives and cleanup
areas.
8.3 Description or the Alternatives
The following description of the Eagle Harbor cleanup alternatives considered is an abbreviated version of the
detailed description of alternatives developed in the Eagle Harbor FS, supplemented by a description of
Alternative N.
Cost estimates for each of the West Harbor areas are summarized on Tables 12a, b, c, d, based on areas listed
in Table 10. Table 13 provides a summary of the time estimated to implement each alternative, assuming each
alternative is applied in all areas for which the alternative was carried forward for detailed evaluation.
Remedial action areas, costs an~ .timeframes for the West Harbor will be refined during remedial design.
ALTERNATIVE A. NO ACTION/NATURAL RECOVERY
The No Action Alternative must be evaluated to provide a baseline to which other alternatives can be com-
pared. No active remediation of sediment contamination would take place, although source control activities at
the Wyckoff OU would continue. Humans and aquatic organisms using contaminated areas of Eagle Harbor
would continue to be exposed to elevated levels of contaminants until natural recovery was achieved.
Natural recovery could occur gradually, in some areas over a period of fifty years or more, through deposition
of new sediments, degradation of PAH by physical, chemical, and biological processes, and movement of
contaminated fine sediments with tidal and other currents.
.....,.."
No initial costs are included, and the cost of monitoring of seafood to evaluate reductions in contaminant
concentrations over time is included as O&M.
ALTERNATIVE B. INSTITUTIONAL CONTROLS/NATURAL RECOVERY
This alternative was evaluated for all areas of the West Harbor.
As with the No Action alternative, the Institutional Controls alternative does not involve active remediation of
contaminated sediments. Natural recovery of contaminated sediments would occur gradually in some areas, and
-------
institutional controls such as access and use restrictions, health advisories, and hazard education programs for
the public would be used to limit potential human exposure to contaminants. These measures would be contin-
ued as needed until concentrations of mercury and PAR were below levels of concern for human health.
Use restrictions would include increased posting of the existing health advisories against fish and shellfish
consumption in intertidal and subtidal areas to reduce the potential for human exposure to unacceptable levels of
contaminants in seafood. Restrictions on commercial harvesting of fish and shellfish could also be
implemented. Dredging in problem areas would be restricted and best management practices (BMPs) for
maintenance of creosoted pilings and other shoreline operations would be required. Costs are considered under
O&M.
ALTERNATIVE C. CAPPING
This alternative was evaluated for all areas of the West Harbor.
Capping consists of leaving the contaminated subtidal and intertidal sediments in place and covering them with
clean material to isolate the contamination. The physical conditions that the cap would be exposed to would
vary depending on its location and would determine the detailed design requirements.
Subtidal capping would involve placement of a I-meter (3-foot) thick layer of clean medium- to coarse-grainc:.d
sand to isolate contaminants and limit their vertical migration and release into the water column. This cap
thickness would also limit the potential for marine organisms to reach the contaminated sediment. For purposes
of estimating costs it was assumed that suitable sandy material could be obtained by dredging within a
3-kilometer (1.9 mile) radius of Eagle Harbor. Identification of an actual source would be conducted during
remedial design and would affect cost.
To have better perimeter area coverage, the cap would overlap somewhat onto adjacent areas. For purposes of
estimating quantities in the FS, approximately 3 meters (10 feet) of overlap was assumed.
Physical conditions such as the slope and wave environment as well as biological and habitat issues would be
considered in the selection of material characteristics. Areas affected by currents induced by ferry propellers
would require a coarser grained material as "armoring" to hold the cap in place.
If necessary, the stream near the mercury intertidal area would be temporarily rerouted during cap placement,
and the cap would be designed to accommodate the stream.
Cap performance requirements and limitations on permeability (e.g., construction materials, cap maintenance
requirements, and testing of contained materials) would be further analyzed during remedial design.
It is estimated that design, procurement, and construction of the cap (for both subtidal and intertidal areas)
would take 3 to 4 years. This assumes 6 months for final design, 1 year for pilot testing of the cap, 3 months
for design refinement, 6 months for mobilization/demobilization, and 6 months for placement of capping
materials.
ALTERNATIVE D. REMOVAL, CONSOLIDATION, AND CONFINED AQUATIC DISPOSAL
This alternative was evaluated for all areas of the West Harbor.
-------
Confined aquatic disposal (CAD) consists of dredging or excavating contaminated sediments from the subtidal
and intertidal zones, placing them in an excavated subtidal pit in Eagle Harbor, capping the relocated sediments
with a meter (3 feet) of clean sediment from the pit, and disposing of any excess clean sediment at a Puget
Sound Dredge Disposal Analysis (PSDDA) open-water disposaI site (or applying them to beneficial uses
elsewhere). Important considerations in the design of this alternative include:
The CAD site would be in a subtidal area below -7.5 meters (25 feet) mean lower low water (MLLW), with
low current velocities. The upper surface of the CAD cap would be consistent with the original harbor bottom
contours in order to minimize cap erosion, disruption of navigation, and impacts on harbor circulation. The
west-rentralportion of the harbor could meet these conditions and has sufficient area to accommodate the
contaminated sediment.
Contaminated sediment removed from intertidal areas would be replaced with uncontaminated material of a
similar type to mitigate the loss of intertidal substrate. If necessary, some of the contaminated sediment
removed from the subtidal area would be replaced with similar uncontaminated material to assist in the
restoration of eelgrass.
It is estimated that design, procurement, and construction of the CAD for the total volume of contaminated
:>ediment would take 4 to 6 years. This estimate assumes a minimum of 1 year for design, 6 months to excavate
the CAD basin, 2 years to dredge and place the contaminated sediment, 6 months to cover, and I year to
mobilize and demobilize the operation.
ALTERNATIVE E. REMOVAL, CONSOLIDATION, AND NEARSHORE DISPOSAL
This alternative was evaluated for all areas of the West Harbor.
The alternative consists of constructing a containment area adjacent to the shore in Eagle Harbor, removing
contaminated sediments from subtidal and intertidal problem areas, placing the contaminated sediments in the
containment area in the harbor, and capping the sed.iments in the containment area with imported clean sand.
The final elevation of the upper surface of the containment area would match the existing upland surface.
This nearshore fill site would be located in an area that would minimize disruption of navigation and operations
on contiguous upland areas. The size of the disposal site would depend on the ultimate volume of sediment
removed.
. Contaminated sediment in the disposal site would be kept saturated in orde~ to limit contaminant release. The
surface of the clean sediment cap would be paved and a stormwater collection system would be installed.
It is estimated that design, procurement, and construction of the nearshore disposal facility for the total volume
of sediment would take 4 to 5 years.
ALTERNATIVE G. REMOVAL, CONSOLIDATION, AND UPLAND DISPOSAL AT AN OFF-SITE
COMMERCIAL RCRA LANDFILL'
This alternative was evaluated for all areas of the West Harbor except the intertidal HP AH area.
The alternative consists of dredging the contaminated sediments, dewatering them, and transporting them to an
off-site RCRA-permitted hazardous waste landfill. Mechanical equipment would be used for dredging, and
. trucks would be used for transport.
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~
Although sediments in the West Harbor are not listed dangerous or hazardous wastes (listed DW /HW) according
to RCRA or the State Dangerous Waste Regulations, they may be characteristic wastes (DW/HW) on the basis
of the Toxicity Characteristic Leaching Procedure (TCLP) or may be .Washington-State-only dangerous waste.
(state-only DW) on the basis of state criteria for toxicity, persistence, or carcinogenicity.
If the excavated sediments are determined to be DWIHW, they will require treatment to achieve compliance
with RCRA land disposal restrictions. Bench scale studies may be necessary to establish that the appropriate
treatment standards are achievable through stabiliZAtion/solidification. If not, a treatability variance would be
necessary .
During dredging and transport, some sediment could be stored in barges to allow for the sediment to be
transported off site at a slower rate than it is dredged. The sediment would be dewatered on site prior to ship-
ment. The dewatering process may be enhanced by placing vibrators in the dewatering basins. Waste water
would be collected and treated by carbon filtration prior to discharge to the harbor. The sediment would be
placed in lined roll-off boxes for transport by trucks to the selected hazardous waste landfill and, if necessary,
would be treated by solidification/stabiliZAtion at the landfill prior to disposal.
It is estimated that design, procurement, and remediation would take I to 2 years, with actual.on-site activities
requiring approximately 6 months. .
ALTERNATIVE H. REMOVAL, TREATMENT BY INCINERATION, AND DISPOSAL
This alternative was evaluated for areas without mercury contamination. In the West Harbor, use of this
alternative would be limited to intertidal PAH areas below the MCUL for mercury.
In this alternative, the excavated sediment would be incinerated on site after dewatering and milling to reduce
the size of large sediment particles. It has been assumed that the solids content of the sediment after dewa:ering
would be approximately 50 percent because of the sandy nature of the sediments.
The FS assumed that the incineration would be done in a rotary kiln, using natural gas or oil as supplemental
fuel. The incineration rate would be 275 m) of sediment per day. The utiliZAtion factor for the incinerator was
assumed to be 80 percent and the treatment efficiency 99.99 percent. The area needed for the incinerator would
be about 16,000 m2. The incinerator would be equipped as necessary to control the release of particulate and
gaseous emissions.
It is estimated that design, procurement, and incineration of the total volume of P AH contaminated sediment in
Eagle Harbor would take 8 to 11 years. The volume of West Harbor intertidal sediments contaminated only
with PAH is significantly smaller, and would take less time to incinerate. Incinerated sediment from the West
Harbor would not be considered RCRA listed waste. .
If tests of the treated sediment demonstrated compliance with performance standards and PSDDA criteria, the
treated sediment copld be disposed of at an open-water disposal site.
ALTERNATIVE I. REMOVAL, TREATMENT BY SOLIDIFICATION/STABILIZATI~N, AND
DISPOSAL
This alternative was evaluated for sediments with mercury contamination and moderate to low PAH
concentrations. Other treatment alternatives for mercury contaminated sediments were limited. In the West
Harbor, such sediments include intertidal and subtidal mercury areas. High concentrations of organic
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Altbougb sediments in the West Harbor are not listed dangerous or bazardous wastes (listed DW /HW) according
to RCRA or the State Dangerous Waste Regulations, they may be cbaracteristic wastes (DW /HW) on the basis
of the Toxicity Characteristic Leaching Procedure (TCLP) or may be .Washington-State-only dangerous waste"
(state-only DW) on the basis of state criteria for toxicity, persistence, or carcinogenicity.
If the excavated sediments are detennined to be DW/HW, they will require treatment to achieve compliance
with RCRA land disposal restrictions. Bench scale studies may be necessary to establish that the appropriate
treatment standards are achievable through stabilization/solidification. If not, a treatability variance would be
necessary .
During dredging and transport, some sediment could be stored in barges to allow for the sediment to be
transported off site at a slower rate than it is dredged. The sediment would be dewatered on site prior to ship-
ment. The dewatering process may be enhanced by placing vibrators in the dewatering basins. Waste water
would be collected and treated by carbon filtration prior to discharge to the harbor. The sediment would be
placed in lined roll-off boxes for transport by trucks to the selected hazardous waste landfill and, if necessary.
would be treated by solidification/stabilization at the landfill prior to disposal.
It is estimated that design, procurement, and remediation would take I to 2 years, with actual on-site activities
requiring approximately 6 months.
ALTERNATIVE H. REMOVAL, TREATMENT BY INCINERATION, AND DISPOSAL
This alternative was evaluated for areas without mercury contamination. In the West Harbor. use of this
alternative would be limited to intertidal PAH areas below the MCUL for mercury.
In this alternative, the excavated sediment would be incinerated on site after dewatering and milling to reduce
the size of large sediment particles. It has been assumed that tbe solids content of the sediment after dewa:ering
would be approximately 50 percent because of tbe sandy nature of tbe sediments.
The FS assumed that the incineration would be done in a rotary kiln, using natural gas or oil as supplemental
fuel. The incineration rate would be 275 mJ of sediment per day. The utilization factor for the incinerator was
assumed to be 80 percent and the treatment efficiency 99.99 percent. The area needed for the incinerator would
be about 16,000 m2. The incinerator would be equipped as necessary to control tbe release of particulate and
gaseous emissions.
It is estimated that design, procurement, and incineration of the total volume of PAR contaminated sediment in
Eagle Harbor would take 8 to II years. The volume of West Harbor intertidal sediments contaminated only
witb PAH is significantly smaller, and would take less time to incinerate. Incinerated sediment from the West
Harbor would not be considered RCRA listed waste. .
If tests of the treated sediment demonstrated compliance with performance standards and PSDDA criteria, the
treated sediment cO\lld be disposed of at an open-water disposal site.
ALTERNATIVE I. REMOVAL, TREATMENT BY SOLIDIFlCATION/STABn..IZATI~N, AND
DISPOSAL
This alternative was evaluated for sediments with mercury contamination and moderate to low P AH
concentrations. Otber treatment alternatives for mercury contaminated sediments were limited. In the West
Harbor, such sediments include intertidal and subtidal mercury areas. High concentrations of organic
-------
.
compounds such as PAHs can interfere with the solidification/stabilization process, and the alternative was not
evaluated for the West Harbor intertidal PAH area.
In this alternative, the dredged or excavated sediment would be mixed with solidifying and stabilizing agents in
equipment similar to that used for mixing concrete. If sediments are neither state-only DW or characteristic
DW/HW after solidification/stabilization, they may be disposed of at a municipal landfill.
Solidification combined with stabilization treatment does not destroy or remove the contaminants from the
sediment but chemically binds the contaminated sediments into a structurally fixed matrix. In this way the
leachability, and thus the mobility, of the contaminants is reduced.
The volume of the sediment is assumed to increase by about 20 percent with the addition of the stabilizing
agent. Treatment rates and the percentage increase in volume would depend upon the types and quantities of
reagents used. The treated sediments would be tested to demonstrate compliance with performance criteria
specified during remedial design, and the solidified mass would be disposed of on site, transported to a local
municipal landfill, or used for productive purposes. It is estimated that design, procurement, and remediation
would take 3 to 6 years.
ALTERNATIVE L. REMOVAL, TREATMENT BY BIOLOGICAL SLURRY, AND DISPOSAL
This alternative was evaluated for sediments with lower mercury concentrations. As with any biological treat- ,
rnent technology, the biological slurry treatment would not be effective for metals such as the mercury found in
some of the West Harbor sediments. .
In this alternative excavated sediments would be mixc::d and aerated as a slurry to enhance the biological
dt::gradation of PAH and other organic contaminants. Control over treatment conditions would help maintain
treatment effectiveness with the, relatively low organic content of the sediments at Eagle Harbor.
The sediment would be treated in mobile treatment reactors brought on site. The treatment tanks would be
covered, and the off-gas would be treated as appropriate. The area needed for the treatment tanks and
equipment would be about 30,000 m2. A portion of the Wyckoff facility could be used for the treatment
operations if they were coordinated with ongoing and future cleanup activities there.
The treated sediments would be tested to demonstrate compliance with performance criteria and disposed of at a
PSDDA open-water disposal sit~.:.... Excess wastewater from the sediment treatment would be treated on site prior
to discharge to the harbor."
It is estimated that design, procurement, and remediation would take 9 to 11 years for PAH-contaminated
sediments throughout Eagle Harbor. For the West Harbor, less time would be necessary.
ALTERNATIVE M. IN SITU TREATMENT BY SOLIDIFICATION/STABILIZATION
This alternative was evaluated only for mercury-contaminated intertidal sediments with lower PAH
concentrations, e.g., the mercury intertidal area. This technology has not been proven for contaminated
sediments in marine waters in the United States, and the stabilizing agent might be susceptible to erosion in
subtidal areas or areas with strong currents.
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~
In this in-place alternative, sheet pile or a berm would first be placed around the area to be treated. The
sediment would then be mixed with solidification agents by using either an auger-type mixing rig or equipment
such as a backhoe or a plow.
The volume of the sediment is assumed to increase by about 20 percent with addition of the stabilizing agent.
Treatment rates and the percentage increase in volume would depend upon the types and quantities of reagents
used. The treated sediments would be tested during remedial design to demonstrate compliance with specified
performance criteria. The solidified sediments would be left in place and would be capped with clean
sediments.
It is estimated that design, procurement, and remediation would take 3 to 6 years for intertidal mercury, of
which approximately I year is required for the actual remediation step.
ALTERNATIVE N.
LOW-IMPACT CAPPINGrrHIN LAYER PLACEMENT
This alternative is considered only for subtidal areas of the West Harbor, where currents are moderate to slow
and contamination is marginal. Initially identified as low-impact capping, this alternative is more accurately
termed thin-layer placement, because it does not isolate contaminated sedim~ts throughout a problem area.
Rather, clean sediments are added to the environment to allow enhancement of natural sedimentation without a
widespread or major impact on existing biological communities.
Where applied, uniform coverage would not be expectf'.d, and some areas could receive little or no clean
material in order to leave areas where existing biota would be minimally affected. Over time, vertical mixing
th.rough biological activity and lateral redistribution of the clean sediment would promote attainment of the
sediment cleanup chemical criteria.
As described in a separate feasibility evaluation completed by the U.S. Army Corps of Engineers (COE, 1992),
the clean material is assumed to be placed in longitudinal hills (windrows) parallel to the shoreline
approximately 60 meters (200 feet) apart. Along the windrow centerline, the target thickness of the clean
sediment would probably not exceed 30 cm (I foot), and the clean sediment thickness would taper between rows
to less than 3 centimeters (I inch).
The time to remediate is estimated to be 3 - 4 years, the same as for Alternative C.
8.4 Applicable or Relevant and Appropriate Requirements
Remedial actions implemented under CERCLA must meet legally applicable, or relevant and appropriate
requirements (ARARs). ARARs include promulgated environmental requirements, criteria, standards, and other
limitations. Other factors to be considered (fBCs) in remedy selection and implementation may include
nonpromulgated standards, criteria, advisories, and guidance, but are not evaluated pursuant to the fonnal
process required for ARARs.
ARARs of federal, state, and tribal governments must be complied with during CERCLA response actions.
Local ordinances with promulgated criteria or standards are not considered ARARs, but may be important
TBCs. Major ARARs and TBCs associated with the different alternatives are presented in Table 14.
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...
Table 14
Potential Action Specific ARARsIl
General Response Action Potential ARARfI'BC
Technology/Procen Option Citation Requirements Prerequisite Determination' Comments
In Situ Capping\Containment, 33 USC 403 Dredge and Fill activities must comply with Section 10 Dredge and lill in navigable Applicable Inplace capping of sediments
Thin Layer Placement 33 CFR 320-330 of Rivers and Harbors Act, Section 404 of Clean Water waters of the United States. constitutea filling.
40 CFR 230 Act, and U.S. Army Corps of Engineers regulations.
WAC 173-201 Dredge and Fill activities must comply with water Action takes place in surface Applicable
RCW 90.48 quality standards for Clan A marine waters. waters of Washington state.
WAC 220-110 Dredge and Fill activitiea must meet substantive Action may interfere with Applicable
RCW 75.20 requirements of hydraulics project approval process. natursl water flow of
Washington slate waters.
WAC 173-19-2604 Protect public interest associated with shorelines. Action occurs within 200 feel Applicable or relevant If action occurs within 200 feet of
of shorelinea of statewide and appropriate shorelines, this requirement may be
significance. applicable. If action docs not take
place on shorelines, then requirement
is not applicable, but could be
relevant and appropriate.
Excavation/Dredging of 33 USC 403 Dredge and Fill activities must comply with Section 10 Dredge and fill in navigable Applicable
Contaminated Sedimenls 33 CFR 320-330 of Rivers and Harbors Act, Section 404 of Clean Water waters of the United Slates.
40 CFR 230 Act, and U.S. Army Corps of Engineers regulations.
WAC 220.110 Operations must comply with hydraulic project approval. Action may interfere with Applicable
RCW 75.2 natural waler flow of
Washington state waters.
WAC 173.19.2604 Protect public interest associated with shorelines. Action occurs within 200 feet Applicable
of shorelines of statewide
signilicance.
RCW 90.48 Water quality antidegradation policy of the Slate of Beneficial uses shall be Applicable
WAC 173-201 Washington. maintained and protecled,
RCW 90.54 and no further degradalion of
water quality that would
interfere with or become
injurious to exisling
benelicial uses.
- 58 -
~. ~.
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Table 14
Potential Action Specific ARARS8
General Response Action Potentisl ARARITBC
Technology/Process Option Citation Requirements Prerequisite Detenninationb CommenlB '
Sediment Treatment
. Oeneral Requirements WAC 173-220 Onsite Treatment Facilities. No pollutants shall be Surface discharge of trested Applicsble These requirements would be
WAC 173-216 discharged to any surface water of the State of efffiuentto Puget Sound. applicable if sediments are treated
Washington from a point source, except in compliance onsite and effluent is discharged to
with substantive treatment and disposal requirements. Eagle Harbor.
WAC 173-220-210 Discharge must be monitored to assure complisnce. Applicable
Monitoring includes measurement of flow and mass of
each pollutant.
WAC 173-216-060 Discharge to POTW. Pollutants that pass through a Liquid waste discharge to Applicable Categorical standards have not been
POTW without treatment, interfere with POTW sewage system. promulgated for CERCLA sitcs.
operation, or contaminate POTW sludge are prohibited. Discharge standards must be
Specific prohibitions preclude the discharge to POTWs detennined on a case-by-case basis
and are dependent on the
of pollutants that: characteristics of the waste stream
and the receiving POTW.
. Create a fire or explosion hazard in the POTW.
. Are corrosive (pH <5.0 or > I I .0). These regulations would be ap-
plicable if treated effluent is
discharged to POTW.
. Obstruct flow resulling in interference.
. Are discharged at a flow rate and/or concentration
that will result in interference.
. Increase the temperature of wastewater entering the
treatment plant resulling in interference.
Discharge must comply with local POTW pretreatment
program including ,POTW-specific pollutants, spill
prevention program requiremenlB, and reporting and
monitoring requirements.
- 59 -
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Table 14
Potential Action Specific ARARSB
Oeneral Response Action Potential ARARlTBC
Technology/Process Option Citation Requirements Prerequisite Determination' Comments
Sediment 'rreatment
. Oeneral Requirements 40 CFR 261.3 Solid waste derived from treatment, storage, or disl'osal RCRA or state listed Applicable
40 CFR 260 of a listed RCRA hazardous waste or a listed slAte waste(KOOI, F034, U05I,
dangerous waste is itself a listed waste regardless of and/or F027).
concentration of HW constituents. To be exempt, the
"derived-from" HW must be delisted.
WAC 173-201 Water quality antidegradation policy of the SlAte of Beneficial uses shall be Applicable
RCW 90.48 Washington. maintained and protected,
RCW 90.54 and no further degradation of
water quality \hat would
interfere with or become
injurious to existing
beneficial uses.
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Table 14
Potential Action Specific ARARS8
Oeneral Reaponae Action Potential ARAR/TBC
Technology/Proceaa Option Citation Requirements Prerequisite Detenninalion~ Comments
Sediment Treatment
. Dewatering 40 CFR 264.600 Msnsgement of HW or DW must be done in a manner Sediments mUSt be classified Applicable or relevant EHW shall not be land disposed in
40 CFR 262 that protecta human health and the environment. as HW, DW, or EHW, and and appropriate Washington. Sedimenta would have
WAC 173.303 Prevention of releaaea that may have adverse effects on trealment may lske place depending on to be ahown to be HW, DW, or
human health or. the environment because of migrstion inside or outside of Eagle classification of EHW before requirements would be
of waate constitJents in groundwater, subsurfa~'e Haroor. waates. applicable or relevant and
environmeill, sufface water, wetlands, soils, or air. appropriate.
WAC 113-201 Emuent mUst meet the surface water quality criteria in Surface discharge of emuent Applicable or relevant If discharge is offsite to Pugel
the established mixing zone. to Puget Sound. and appropriate. Sound, both administrative and
procedural requirements would
apply.
WAC 113.201.035 Emuent muat meet the aurface water qualily crileria Surface discharge of emuent TBC If proposed regulation is
after application of AKART. to Puget Sound. promulgated. then substantive portion
of requirements would be applicable.
RCW 90.48 Water quality sntidegradalion policy of the Slste of Beneficial uses shall be Applicable
RCW 90.54 Washington. mainlained and prolected,
and no further degradstion of
waler quality that would
interfere with or become
injurious 10 existing
beneficial uses.
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Table 14
Potential Action Specific ARARS8
Oeneral Response Action Potential ARARffBC
Technology/Process Option Citation Requirements Prerequisite Detennination' Comments
Sediment Treatment
8 Dewatering WAC 173-216 Onsite Treatment Facilities. No pollutants shall be Surface discharged of treated Applicable
discharged to any aurface water of the State of emuent to Pugel Sound.
Washington from 8 point source, except in compliance
with substantive requirements.
WAC 173-220-210 Discharge must be monitored to assure compliance. Applicable
Monitoring Includes measurement of flow and mass of
each pollutant.
WAC 173-216-060 Discharge to POTW. Pollutants thai pass through a liquid waste discharged to Applicable Categorical standards have not been
POTW without treatment, interfere with POTW sewage system. promulgated for CERCLA sites.
operation, or contaminat6 POTW sludge are prohibited. Discharge standards must be
determined on a case-by-case basis
Specific prohibitions preclude the discharge to POTWs and arel dependent on the
of pollutants that: characteristics of the wasle stream
. Create a fire or explosion hazard in the POTW. and the receiving POTW.
. Arel corrosive (pH < 5.0 or > 11.0).
. Obstruct flow resulting in interference
. Are discharged 8t 8 flow rate and/or concentration
that will result in interference.
. Increase the temperature of wastewater entering the
treatment plant resulting in interference.
Liquid waste discharged to sewage system.
Discharg6 must comply with local POTW pretreatment
program, including POTW-specific pollutants, spill
prevention program requirements, and reporting and
monitoring requirements.
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Table 14
Potential Action Specific ARARs8
Oeneral Response Action Potential ARARlTBC
Technology/Process Option Citation. Requirements Prerequisite Detenninationb Comments
..
. '-Sediment Treatment' .. .
. Incineration WAC 173-303-670 Analyze the waste feed. Dispose of all HW, DW, or Sediments must be classified Applicable If wastes to be incinerated are
40 CFR 264.341 EHW waste and residues, including ash, scrubber water, as DW or EHW. classified aa DW or EHW, the re-
40 CFR 264.3S1 and scrubber aludge. quirements would be applicable. If
40 CFR 264.343 F027 wastes are incinerated, F028
40 CFR 264.342 Performance standard for incinerators includes a wastes are generated.
40 CFR 261.31 reduction of hydrogen chloride emissions to 1.8 kglhr or
I percent of the HCl in the stack gases before entering
any pollution control devices.
Monitoring of various parameters during operation of
the incinerator is required. These parameters include:
. Combustion temperature
. Waste feed rate
. An indicator of combustion gas velocity
. Catbon monoxide
WAC 173-400 Sources of fugitive dust must be controlled to avoid All air pollution sources. Applicable
40 CFR S2 nuisance conditions.
40 CFR S2 Estimation of emission rates for each pollutant expected, Source meeting the "major" Relevant and
including: criteria and/or sources appropriate
. Modeled impact analysis of source emissions proposed for nonatlainment
areas.
. Best available control technology (BACT) reviews
for source operation
WAC 173-490 Predict total emissions of volatile organic compounds Source must be in an ozone Applicable
40 CFR S2 (VOC) to demonstrate emissions do not exceed nonsttainment area.
4S0 Iblhr, 3,000 Ib/day, or 10 gal/day or allowable
emissions from similar sources BACT.
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Table 14
Potential Action Specific ARARS8
Oeneral Response Action Potential ARARfTBC
Technotogy/Proceu Option Citation Requirementa Prerequisite Determin8tio~ Comments
Sediment Treatment
8 Incineration WAC 173-460 Controls for new sources of air toxics New air emission source. Applicable
(cont.)
Regulation 10, Puget Regulates air emissions Air emissions source. Applicable
Sound Air Pollution
Control Agency
Sediment Treatment
8 Solidification/Stabilization 40 CFR 264.601 Management of HW or DW must be done in a manner Sediments must be classified Applicable or relevant EHW shall not be land disposed of in
40 CFR 262 that protects human health and the environment. as HW, DW, or EHW, and and appropriate Washington. .Placement" of wastes
WAC 173-303 Prevention of releases that may hsve adverse effects on treatment may take place OCCUr1l when restricted wastes are
human health or the environment because of migration inside or outside of Eagle placed in RCRA land-based units.
of waste constituents in groundwater, subsurface Harbor au. Placement docs not occur when
environment, surface. water, wellands, soils, or air. wastes are moved within an existing
unit.
WAC 173-303-809 Substantive requirements for research. development. and Treatment facility not Applicable
demonstration of an innovative and experimental DW permiued in WAC 173-303-
waste treatment technology at a DW facility. 500 through WAC 173-303-
670.
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.
Table 14
Potential Action Specific ARARS8
Oeneral Response Action POlential ARARlTBC
Technology/Procell Option Citation Requirements Prerequisite Dcterminationb Comments
Dispo!l8l of Sediments
8 Confined squatlc dispo!l8l PSDDA Management Guidelines for dredged sediments disposed of at Sediments meet chemical and TBC Guidelines may be TBC for actions
(includes neanhore area Plan for Unconfined approved unconfined open water sites. biological crileria specified in that involve unconfined disposal of
within Eagle Harbor OU) Open-Water Disposal document. sediments.
of Dredged Material,
Ph..e I (June 1988).
Dredged Material
Evaluation Application
Report (January 1991)
1989 Puget Sound Element S.4 of Puget Sound Management Plan. Requires Ecology to develop TBC
Waler Quality slandards for confined
Management Plan disposal of sediments'that
exceed P-2 crileria but are
nol designated as OW.
EPA Wetlands Action No net loss of remaining wetlands. Disposal of material TBC
Plan, EPA Omce of nearshore.
Water and Wetland
Protection (1/89)
WAC 113-201 Water qualily anlidegradalion policy of the Slate of Bendicial uses shall be Applicable
RCW 90.48 Washington. maintained and protected,
RCW 90.54 and no further deg:adation of
water qualily that would
interfere with or become
injurious 10 existing
beneficial uses.
WAC 220-110 Disposal activities must meet substantial requirements of Action may interfere with Applicable
hydraulics project, approval process. natural flow of Washington
state walers.
33 USC 403 Fill (disposal) activities must comply with Section 10 of Dredge and fill activities in Applicable
33 CFR 320-330 Rivera and Harbon Act, Sections 30 I and 404 of Clean navigable waters of the
40 CFR 230 Water Act, and U.S. Army Corps of Engineen United States.
regulations.
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Table 14
Potential Action Specific ARARS8
Oeneral Response Action POlenlial ARARlTBC
Technology/Process Option Citation Requiremenls Prerequisile Delenninslionb Comments
Disposal of Sedimenls
8 Confined Aqualic Disposal WAC 173-19-2604 Prolect public interesl assoclaled with shorelines. AClion occurs within 200 feel Applicable
(cont.) RCW 90.58 of shoreline of stalewide
significsllce.
40 CFR 268 Reslriclions for land disposal of hazardous waste. Prior to land disposal Applicable If lrealmenl standards cannol be met,
Subparta A, B, D hazardous wastes must be then a waiver musl be obtained.
Irealed 10 specified levels.
Upland Disposal of Sedimenls 40 CFR 264.314 Disposal of DW or EHW al pennitted hazardous wasle Elimination of free liquids if Applicable EHW shall not be land disposed in
(onsilo and/or o((site) WAC 173-303-140 facilily. dredged malerial is Washinglon.
designated as DW or EHW
and disposed of al hazardous
waste facilily.
WAC 173-304-460 Onsite landfill operation shall confonn 10 relevanl and Sediments are nol classified Relevanl and
appropriate standards and localion requirements for or designated.. HW, DW, Appropriale
landfills. or EHW. Free liquids have
been eliminated from dredge
sediments.
1989 Puge! Sound Elemenl S-4 of Puget Sound Management Plan. Requires Ecology to develop TBC If 8-4 guidelines are developed hy
Waler Quality standards for contained Ecology for confined upland
Managemenl Plan disposal of sediments that disposal, then they may become
exceed P-4 criteria and are TBCs for disposal of sediments at
not suitable for P8DDA upland area of sile.
open-water disposal bUI are
nol designated as DW.
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Table 14
Potential Action Specific ARARS8
General Response Action POlentisl ARARfI'BC
Technology/Process Option Citation Requirements Prerequisite Detennination" Comments
Dredge Water Treatment 40 CFR 26 \.3 Solid waste derived from treatment, storage, or dispo.al RCRA listed HW waste. Applicable Sediments have not been shown to be
40 CFR 260 of a listed RCRA hazardous waste is itself a listed waste listed hazardous waste. Such finding
regardless of concentration of HW constiruents. To be would be necessary for requirement
exempt, the derived from HW must be delisted. to be applicable.
WAC 173-216-060 Discharge to POTW. Pollutants that pass through a Liquid waste discharged to Applicable Categorical standards have nol been
POTW without treatment, interfere with POTW sewage syslem. promulgated for CERCLA sites.
operation, or contaminate POTW sludge are prohibited. Discharge standards must be deter-
mined on a case-by-case hasis, and
Specific prohibitions preclude the discharge to POTWs are dependent on the characteristics
of pollutants that: of the waste stream and the receiving
POTW.
. Create a fire or explosion hazard in the POTW.
. Are corrosive (pH <5.0 or > I \.0).
. Obstruct now resulling in interference.
. Are discharged at a now rate and/or concentration
that will result in interference.
. Increase the temperalure of wastewater entering the
trealment plant resulling in interference.
Discharge mUSI comply with local POTW pretreatm~:It
program including POTW-specific poIlU18nlS. "pill
prevention program requiremems, and reponing and
monitoring requirements. Liquid waste discharged to
sewage system.
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Table 14
Potential Action Specific ARARS8
General Response Action Potential ARARffBC
Technology/Process Option Citation Requirements Prerequisite Determination' Comments
Dredge Water Treatment WAC 173-220 No pollutants shall be discharged to any surface water of Surfsce discharge of Ireated Applicable Emuent must be tesled 10 determine
(fill ration) WAC 173-216 the State of Washington from a poinl source, except in emucnt. Discharge may not if it designates as a DW or EHW.
compliance with substantive treatmcnt and disposal be designated as HW, DW,
requirementa. or EHW.
Discharge must be monitored to ensure compliance.
Monitoring includes measurement of flow and mas. of
each pollutant.
WAC 173-201-047 Stilte water quality criteria for the protection of aquatic Relevant and
WAC 173-201-04S life. appropriate
40 CFR 12S.122-124 Requirements and criteria including compliance with Direct discharge to waters of Applicable
federal water quality criteria and Best Available the United Stales; applies to
Technology (BAT). sources only.
WAC 173-201-03S(3) Emuent must meet the surface water quality crileria Surface discharge of emuent. TBC If proposed regulalionis promulgaled,
afler application of AKART. to Puget Sound. substantive portion of requirements
would be applicable.
WAC 173-220-210 Discharge must be monitored to assure compliance. Applicable
Monitoring includes measurement of flow and mass of
each pollutant.
. The primary ARAR of the State of Washington Sediment Management Standards f'N AC 173-204) will be used tl\ define sile-specific cleanup areas and objectives.
b Final ARAR determination Is provided in Section 10 of this ROD.
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9. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The NCP requires that each remedial alternative be evaluated according to specific criteria. The purpose of the
evaluation is to identify the advantages and disadvantages of each alternative and thereby guide selection of the
remedy offering the most appropriate means of achieving the stated cleanup objectives. While all of the nine
criteria are important, they are weighted differently in the decision-making process. The alternatives described
in Section 8 were evaluated under CERCLA according to the following criteria:
Threshold Criteria
Overall protection of human health and the environment
Compliance with ARARs
Primary Balancing Criteria
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume through treatment
Short-term effeCtiveness
lmplementability
Cost-effectiveness
Modifying Criteria
State and tribal acceptance
Community acceptance
Following is a description of the evaluation criteria and the comparative evaluation of each candidate remedial
alternative.
9.1 Threshold Criteria
The remedial alternatives were first evaluated in relation to the threshold criteria of overall protection of human
health and the environment and compliance with ARARs. The threshold criteria must be met by the candidate
alternatives for further consideration as remedies for the ROD.
9.1.1 Overall Protection of Hwnan Health and the Environment
This criterion considers whether, as a whole, each alternative would achieve and maintain protection of human
health and the environment.
All cleanup alternatives except No Action and Institutional Controls protect both human health and the
environment. These alternatives are considered protective of the environment only in areas where natural
recovery can reduce contaminant levels to the cleanup objective within ten years. Institutional Controls can be
used to provide protection of human health but do not protect the environment in areas where natural recovery
is not predicted.
Alternatives involving on-site containment of contaminated sediments require long-term monitoring and
maintenance in order to assure continued protection.
9.1.2 Compliance with Applicable or Relevant and Appropriate Requirements
The evaluation against this criterion considers whether each alternative would comply with ARARs, or whether
a waiver of any ARAR might be necessary and justified, and whether there is any other information or guidance
"to be considered."
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All alternatives except No Action and Institutional Controls comply with the primary ARAR (the Sediment
Standards) for the West Harbor OU.
RCRA and the State of Washington Dangerous Waste Regulations would not be applicable but could be relevant
and appropriate for on-site alternatives involving consolidation and containment without treatment within an area
of contamination (AOC). This includes confined aquatic disposal, nearshore disposal, or on-site upland
disposal. For alternatives involving removal and treatment of West Harbor sediments, these laws would be
applicable for sediments determined to be characteristic DW/HW or State-only DW.
For off-site actions, such as disposal at a RCRA landfill or a municipal landfill, all regulatory requirements,
including administrative requirements, would apply. Depending on the characteristics of the excavated
sediments, state solid waste regulations could apply to off-site disposal options, and state and federal
dangerouslhaurdous waste regulations could apply for off-site transport and disposal. . Characteristic DW IHW
sediments would have to be treated to achieve treatment standards under the RCRA Land Disposal Restrictions
(LDR) prior to land disposal. If the sediments were State-only DW, the federal LDR would not apply, but
Dangerous Waste Regulations would.
No Action and Institutional Controls would meet the Sediment Standards only in areas where natunll recovery
could occur in ten years. Based on the natural recovery evaluation in the FS, EPA and Ecology believe that.
provided sources are controlled, intertidal sediments on the north shore exceeding the Sediment Standards
MCUL chemical criteria for PAHs (but not for metals) can achieve the MCUL within ten years through natural
recovery .
9.2 Primary Balancing Criteria
Once an alternative satisfies the threshold criteria, five primary balancing criteria are used to evaluate other
aspects of the potential remedies. Each alternative is evaluated by each of the balancing criteria. One
alternative will not necessarily,receive the highest evaluation for every balancing criterion. The balancing
criteria evaluation is used to refine the selection of candidate alternatives for a site. The five primary balancing
criteria are: long-term effectiveness and permanence; reduction of toxicity, mobility or volume through
treatment; short-term effectiveness; implementabiJity; and cost-effectiveness. Each criterion is further explained
in the following sections.
9.2.1 Long-Tenn Effectiveness and Pennanence
The evaluation against this criterion assesses the long-term effectiveness of each alternative in maintaining
protection of human health and the environment after the cleanup objectives have been met, with a focus on the
magnitude of risk posed by treatment residuals or untreated contaminated sediments remaining at a site after the
remedial actions have been completed.
CERCLA requires that EP A favor treatment options over institutional controls or off-site disposal of untreated
waste. Biological Treatment and Incineration permanently destroy PAH and other organic compounds, but
cannot destroy mercury or other metals. Solidification can immobilize metals, but is not as effective for organic
compounds such as PAH. In general, treatment is practical and preferable for smaIl volumes of highly
contaminated material.
Options involving containment can be effective in the long term, but do not permanently remove or destroy the
contaminants. Containment alternatives are more appropriate when large volumes of relatively low-
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concentration materials or waste are involved, as with many contaminated sediment sites. . Containment requires
monitoring and maintenance to ensure long-term effectiveness.
Off-site containment at an approved hazardous waste landfill, municipal landfill or-other upland disposal site can
provide effective long term control, provided any necessary treatment is completed and pennits or other
institutional controls are in place to ensure appropriate design, construction, maintenance and monitoring of the
disposal site.
9.2.2 Reduction of Toxicity, Mobility, or Volume through Treabnent
The evaluation against this criterion assesses the anticipated perfonnance of the treatment technologies in each
of the alternatives.
Biological treatment and incineration would reduce the toxicity and mobility of PAH contamination, but would
not address metals. Solidification (Alternatives I, M, and potentially other options involving land disposal)
would decrease the mobility of the metal contaminants, but would increase the volume.
Capping, confined aquatic or nearshore disposal, and upland disposal of untreated sediments are alternatives
which restrict the movement of contaminants by containing the sediments to which they are bound and which
limit the availability of the contaminant to marine organisms. However, these alternatives do not alter the
toxicity, mobility, or volume of the chemical contaminants themselves through treatment.
9.2.3 Short-Tenn Effectiveness
The evaluation against this criterion assesses the effectiveness of each alternative in protecting human health ami
the environment from construction and implementation of a remedy until achievement of the cleanup objectives.
It focuses on protection of the environment, the community, and workers during implementation of the remedial
action.
Capping with clean sediment provides the greatest short-term effectiveness. It can be completed most quickly
and has fewer short-term impacts on human health and the environment than other active remedial alternatives.
Any alternatives involving the dredging of subtidal contaminated sediments could have negative short-term
impacts on the environment, particularly in areas with heavy contamination. Dredging could remobilize
contamination into the water, potentially spreading contamination to nearby areas. Intertidal areas can be
excavated at low tide to minimize remobilization of contaminants.
Studies show that marine organisms soon recolonize clean sediment. This process can begin immediately after
capping or removal of contaminated sediments, but development of a mature community of sediment-dwellers
can take several years. Recolonization of larger areas may be slower.
Alternatives which involve extensive handling of contaminated sediments, such as treatment alternatives, pose
somewhat greater risks to workers and the community during implementation. The No Action and Institutional
Controls alternatives have no short term impacts, but do not protect the environment.
Among the active remedial alternatives, capping takes the least time to implement, while treatment alternatives
generally take longer (fable 13).
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9.2.4 Implementability
Three factors were evaluated to assess the implementability of the remedial alternatives: technical feasibility,
administrative feasibility, and the availability of disposal sites, services, and materials. Technical feasibility
requires an evaluation of the ability to construct and operate the technology, the reliability of the technology, the
ease of undertaking additional remedial action (if necessary) and monitoring considerations. The ability to
coordinate actions with other agencies is the only factor in evaluating administrative feasibility. The availability
of disposal sites, services and materials requires evaluation of the following factors: availability of treatment,
storage capacity, and disposal services; availability of necessary equipment and specialists; and availability of
prospective technologies.
All of the alternatives were considered technically feasible for the areas considered, although some treatability
testing would be necessary to assure the achievement of performance standards of treatment alternatives.
Although all of the alternatives are administratively feasible, some pose greater administrative challenges.
Institutional controls require coordinated action with state and local entities. Alternatives such as capping,
which involve clean sediment placement, require coordination with PSDDA agencies to obtain clean sedrments.
Coordinating ferry and tidal schedules pose additional challenges for options involving dredging and, to a lesser
extent, capping. Treatment options generally take longer and involve extensive or complex administrative
requirements. Incineration is the least administratively feasible because of the difficulties in locating an
incinerator on site in a residential community. .
Alternatives involving removal ~L'1d dewatering of sediment prior to treatment, containment, or disposal require
the management of sediment and drained water. Treatment options would necessitate storage or sequential
dredging to accommodate the materials to be treated and management of treatment residuals. On-site storage
and treatment areas are limited.
Removal of intertidal sediments=<:.an be done from land at extreme low tide, while capping in intertidal areas
may require special equipment. Standard equipment for capping or dredging in subtidal areas is readily
available, but could require air monitoring and controls, and engineering controls to limit water column
releases.
9.2.5 Cost-Effectiveness
In evaluating project cost-effecti.Y,~ess, present-worth estimates of capital costs and operation and maintenance
costs, are provided for each alternative and compared. Estimates are aimed at providing an accuracy of +50 to
-30 percent within the defined scOpe.
In general, initial costs for treatment options, such as incineration or bioremediation, and for hazardous waste
disposal options are high. On-site containment costs tend to be lower initially, but have higher monitoring
and/or maintenance costs over the long term. Institutional controls are usually low cost, and No Action is the
least costly, but these alternatives may not achieve the cleanup objectives or meet threshold evaluation criteria.
9.3 Modifying Criteria
The final two criteria reflect the apparent preferences among, or concerns about, the alternatives, as expressed
by the State, the Suquainish Tribe, and the Community. .
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9.3.1 State and Tribal Acceptance
The State Department of Ecology bad early involvement in the Wyckoff/Eagle Harbor Superfund site, in
proposing the- site for the National Priorities List, and conducting the Preliminary Investigation. After final
listing of the site on the NPL, Ecology reviewed R1 planning documents, coordinated with EPA on the
developing sediment management standards, and identified state ARARs.
The State supported the preferred alternative in the proposed plan (Appendix A) and concurs with the selected
remedy, based on the consistency of the remedy with the recently promulgated Sediment Management
Standards. A letter documenting the State's concurrence is included as Appendix B.
The Suquamish Tribe was invited to participate in aspects of the RI through the Technical Discussion Group.
The Tribe reviewed key documents such as the RI and FS, received technical memoranda issued by EPA, and
provided comments on the proposed plan. Contamination of fish and shellfish resources in Eagle Harbor is of
concern to the Tribe and may be addressed by cleanup actions described in the selected remedy.
9.3.2 Community Acceptance
EPA has carefulIy considered all comments submitted during the public comment period and has taken them into
account during the selection of the remedy for the West Harbor and East Harbor operable units.
Based on the comments received during the public comment period, members of the community are divided
between support for EPA's preferred alternative and a preference for lower cost alternatives such as the No
Action alternative (natural recovery over an indefinite time period of 10 to over 50 years) or some combination
of institutional controls, sediment source removal, and natural recovery.
EP A responses to comments received during the public comment period are included in Appendix C.
9.4 Summary
Although the individual alternatives were evaluated for each area described in Section 8, EPA anticipated the
need for combining alternatives to arrive at an overall cleanup approach suited to the West Harbor OU
conditions and presented such an approach as the preferred alternative in the proposed plan (included as
Appendix A).
The selected remedy, described in the following section (Section 10), follows the same approach. It is intended
to provide continued protection of human health from risks associated with the West Harbor OU, to address
possible changes in the definition of areas failing the Sediment Standards. and to assure and document the
attainment and continued compliance with the Sediment Standards and other environmental standards. In
addition, it considers the suitability of higher-wst disposal or treatment alternatives for small areas of high
contamination; lower~st containment alternatives suitable for large areas of relatively low contamination; and
natural recovery for marginally contaminated areas likely to achieve cleanup ohjectives without active
remediation.
Section II documents how the selected remedy meets statutory requirements and provides the most appropriate
balance of elements. Section 12 describes significant changes from the proposed plan reflected in the ROD.
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.
10. SELECTED REMEDY
Based on CERCLA, the NCP, the administrative record, and the comparative analysis of alternatives, EPA has
selected a remedy which combines the following remedial alternatives described in the proposed. plan:
Alternative B (Institutional ControlsfNatural Recovery),
Alternative C (Capping),
Alternative G or I (Removal and Appropriate Disposal), and
Alternative N (Low-Impact Cappingrrhin Layer Placement)
Specific sediment cleanup areas and the remedial actions. selected for each are shown in Table 15 and Figure 13.
EP A has determined that this combination is the most appropriate means of achieving the pr~ject objectives
described in Section 10.1, below. The State of Washington concurs with the selected remedy.
To further ensure that project objectives will be achieved, source evaluation and control of significant sources
are also included in this ROD. Monitoring will be conducted before, during, and after remediation to evaluate
changes in environmental conditions over time. Site-wide institutional controls will be implemented to limit
human exposure to chemical contaminants in seafood from Eagle Harbor.
10.1 Cleanup Objectives
The sediment cleanup objective for the West Harbor OU combines an overall site-specific cleanup objective
developed according to the State of Washington Sediment Management Standards (Sediment Standards) with
supplemental objectives developed by EPA to address specific concerns and identify areas for actions required at
the site, as described in the following sections. The combined sediment .cleanup objectives were developed to
ensure protection of public health and the environment.
10.1.1 State Sediment Management Standards
The Sediment Standards, the primary ARAR for the West Harbor, were promulgated in April 1991 and provide
a framework for developing site-specific sediment cleanup objectives at Eagle Harbor. The long-term goal of
the Sediment Standards is "to reduce and ultimately eliminate adverse effects on biologiCal resources and
significant health threats to humans from surface sediment conwnination." The process for defining sediment
cleanup sites and establishing site-specific objectives is summarized in th~ following paragraphs.
The Sediment Standards define two levels of chemical and biological criteria which correspond to the long-term
goal for sediment quality of "no adverse effects" on sediment biological resources, and to a "minor adverse
effects" level, exceedance of which triggers consideration of sediment cleanup. Tbe chemical criteria are based
on Puget Sound data which indicate sediment chemical concentrations above which specific biological effects
have always been observed in test sediments (see Section 6 for description of AETs). The biological criteria
have been developed for several types of biological tests. If the chemical criteria indicate the potential for
adverse biological effects, compliance with the Sediment Standards must be demonstrated using at least three
tests, including two for acute toxicity to marine organisms and one for chronic biological effects.
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The absence of adverse effects is predicted by attainment of the "marine sediment quality standards chemical
criteria" (SQS chemical criteria), while minor adverse effects are predicted at chemical concentrations above the
SQS but below the "minimum cleanup level chemical criteria" (MCUL chemical criteria).
Exceedance of the MCUL chemical criteria alone can be used to define cleanup areas, or "sites"; however, the
Sediment Standards recognize that the chemical data may not accurately predict biological effects for all
sediment locations. Biological testing, allowed under the Sediment Standards, can be conducted to determine
whether biological effects predicted by the chemical concentrations are actually occurring. If the biological
criteria are met for a given area, this area is not defined as part of the cleanup site.
The intent of the Sediment Standards is for sediments within a cleanup site to ultimately meet the sediment
quality standards (SQS), the level of no adverse effects. Once a cleanup site has been defined as described
above, a site-specific cleanup objective is developed based on an evaluation of the net environmental benefit,
cost, and implementability of remedial action. The site-specific objective must be between the no adverse
effects level (SQS) and the minor adverse effects level (MCUL). In all cases, if both biological and chemical
data are obtained, the biological information determines compliance with the site-specific cleanup objective
developed under the Sediment Standards. At a minimum, sediments must meet the MCUL within ten years
after active remediation is completed, unless an extension is approved.
The Sediment Standards a\1ow a period of ten years from completion of remedial action for cleanup sites to
meet the MCUL in recognition that, in certain cases, natural processes such as chemical breakdown, dispersion,
or sedimentation may reduce levels of sediment contamination over time. If mathematical modeling predicts
that certain areas of contaminated sediment wi\1 meet the site-specific objectives within ten years without resort
to active remediation, these may be defined as "natural recovery" areas. In such areas, instead of active
remediation, monitoring and compliance testing may be used to confirm the predicted recovery.
10.1.2 Site-Specific Goals and Objectives
Within the framework described above, site-specific cleanup goals and objectives were developed for the West
Harbor OU. Consistent with the intent of the State Standards, achievement of the SQS and reduction of
contaminants in fish and she\1fish to levels protective of human health and the environment are long-term goals
of sediment remedial action in the West Harbor QU. While these goals represent a conceptual target condition,
the measurable site-specific objective is the MCUL, and achievement of the MCUL is the primary focus of
remedial action in this QU. The MCUL must be achieved in the top ten centimeters of sediment throughout the
West Harbor within ten years after the completion of active sediment remediation or, in areas where natural
recovery is predicted based on accepted mathematical modeling, within ten years from control of significant
sources to such areas. Compliance with the MCUL is documented by compliance with the MCUL biological
criteria or, in the absence of biological data, with the MCUL chemical criteria.
Existing data indicate that adverse biological effects in the West Harbor are associated with heavily
contaminated areas near the former shipyard. These data also suggest that adverse biological effects predicted
in areas marginally above the MCUL chemical criteria may not be occurring. For this reason, in West Harbor
areas below the MCUL chemical criteria, adverse biological effects are not expected. In addition, because there
are no rivers or other major sources of clean sediment to Eagle Harbor, achieving the SQS would require active
cleanup in areas below the MCUL chemical criteria. The potential benefits of cleanup are not believed to
outweigh the costs and potential environmental impacts of remediation in such areas.
The MCUL represents an appropriate and achievable objective for the West Harbor QU. Achievement of the
MCUL will be an important step toward the SQS and considers the factors of net environmental benefit, cost,
and engineering feasibility as contemplated by the Sediment Standards.
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In order to defme areas requiring specific types of remedial action, the above site-specific objective developed
according to the Sediment Standards is supplemented by three EPA objectives:
I) to address sediments containing 5 mglkg (dry weight) or more of mercury ("Mercury Hotspot"), as
a means of source control;
2) to address intertidal sediments containing 1,200 Ilglkg (dry weight) or more of HPAH ("Intertidal
HPAH Areas"). Shellfish in such areas contained carcinogenic HPAH above EPA acceptable levels for
protection of human health (See Sections 6 and 7);
3) to address predicted biological impacts, minimize potential sediment resuspension, and limit
biological uptake in areas where sediment concentrations of mercury exceed 2.1 mglkg mercury dry
weight ("Mercury HAET Areas"). The sediment concentration of 2.1 mglkg (dry weight) is more than
three times the MCUL and is the High Apparent Effects Threshold (HAET) for mercury. (This is the
sediment concentration of mercury above which Puget Sound test sediments have always failed acute
toxicity tests for both amphipods and oyster larvae and have demonstrated chronic benthic effects).
Although these additional objectives do not alter the requirement of achieving the MCUL throughout the West
Harbor, areas defined by the three chemical objectives must be addressed. As described in the following
sections, regardless of biological testing options considered under the Sediment Standards, certain minimum
actions are required in. these areas to address human health and environmental concerns related to potential
contaminant resuspension and biological uptake. Also, on the basis of RIfFS information and natural recovery
modeling to date, EPA and Ecology believe that natural recovery will occur in intertidal areas described under
the second EP A objective, but is unlikely in the Mercury Hotspot and Mercury HAET areas. For this reason,
no further modeling is considered in areas defined by objectives 1 and 3, above.
10.2 Problem Areas and Actions
The following problem areas are defined by exceedance (based on RIIFS and PI data) of the goal of the
Sediment Standards SQS, the objective of the Sediment Standards MCUL chemical criteria, and the three EPA
supplemental objectives. The areas listed below are shown on Figure 13:
. )
- Mercury Hotspot
- Mercury HAET Areas
- Intertidal HPAH Areas
- MCUL Areas
- SQS Areas
The following sections describe the selected remedial action for areas which fail the sediment objectives.
Information is provided about how future biological testing or natural recovery modeling, when considered, may
result in modifications according to the selected remedy. Actions not linked to individual sediment cleanup
areas, such as institutional controls and source control are discussed in Section 10.3 and 10.4. Monitoring
objectives are discussed in Section 10.5, and implementation of the remedy is discussed in Section 10.6.
10.2.1 Mercury Hotspot
For sediments with mercury contamination greater than or equal to the 5 mglkg criterion, the selected remedy is
excavation and appropriate upland disposal (as described in Alternative G, or I, or upland on site). The volume
of sediments exceeding this criterion is estimated to range from 1,000 to 7,000 cubic meters (1300 to 9200
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cubic yards). Further sampling of intertidal and nearshore subtidal sediments will be necessary during remedial
design or early stages of remedial action to refine volume estimates prior to fmal remedial action.
The mercury hotspot is defmed by sediment mercury concentrations greater than or equal to 5 mglkg dry
weight. This value is a site-specific criterion developed by EPA to reduce potential resuspension of mercury
and other metals in this area, and their redistribution to other parts of the harbor (Fuentes, 1991). The highest
mercury concentration observed in the harbor (95 mglkg) was within this sediment hotspot located adjacent to
the former shipyards.
Optional biological testing and natural recovery modeling considered by the Sediment Standards will not be
applicablefor modification of actions required in this area. Adverse biological effects have been documented,
and mercury concentrations have been measured at close to 10 to over 150 times greater than the MCUL
chemical criterion of 0.59 mglkg.
Disposal methods will comply with ARARs and will be protective of human health and the environment. To
detenrune the appropriate disposal option, sampling during remedial design will include waste characterization
of the hotspot sediments. Options for disposal of the excavated mat~rial include disposal at an approved
commercial hazardous waste landfill, a municipal landfill, or an upland on-site disposal area, depending on the
waste designation of the excavated sediments and the availability of an appropriate disposal site.
If the sediments fail the criteria for the toxicity characteristic, they will be designated .characteristic. dangerous
waste (DW/HW) or Extremely Hazardous Waste (EHW). Solidification/stabilization of such sedimenl~ will be
required for disposal off site, and if the sediments, when solidified, cannot meet applicable treatment standards
(as specified in 40 C.F.R. ~ 268), off-site disposal at a commercial hazardous waste landfill is appropriate. In
this case, to comply with federal land disposal restrictions, a treatability variance as specified by Superfund
guidance (OSWER #9347.3-06FS) would be necessary prior to land disposal. For sediments determined to be
.Washington State-only DW. according to dangerous waste criteria other than TCLP testing, off-site disposal
must be at a commercial hazardous/dangerous waste landfill unless the sediments can be treated so they no
longer fail the criteria. '
Excavated sediments which are neither DW/HW nor DW, or which can be treated to no longer be DW/HW or
DW, will be considered .problem waste. as defined by the State of Washington Minimum Functional Standards
(MFS). In keeping with EPA's off-site disposal policy, off-site disposal of problem wastes at a municipal
landfill (provided a landfill will accept the waste) must comply with the MFS.
On-site disposal of problem w~~,~y is also acceptable, provided an on-site disposal area becomes available
during remedial design. The relevant and appropriate requirements of the MFS will be determined, and the
developing standards for confined 'disposal of contaminated sediments (under Element S-4 of the Puget Sound
Water Quality Management Plan) will be considered in evaluating disposal options. Any necessary treatment
and landfill design requirements will be determined based on protection of the environment and human health.
Selection of methods for sediment excavation or dredging will consider the need to minimize remobiJization of
mercury or other contaminants to the water column. Excavated areas will be backfilled to replicate existing
topography as closely as possible, or will meet design specifications intended to create favorable aquatic or
intertidal benthic habitat. Backfill materials will be selected which have chemical concentrations below the SQS
chemical criteria, and which provide for structural stability and suitable intertidal or subtidal habitat.
If feasible, any pit left after excavation of mercury hotspot sediments may be partially backfilled with less
contaminated sediments from surrounding areas (for which capping is identified as the selected remedy, see
Section 10.2.2 below). The top 3-foot layer of sediments applied to restore original topography or create
favorable habitat after excavation would have to meet the SQS. The purpose of this approach is to minimize
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.
Table 15
Chemical Levels, Selected Remedies, and
Potential Modifications
If no biological Passes all Fails 1 of 3 Fails 2 or
Sediment Chemistry testing conducted 3 tests' tests more tests
Greater than or equal to Removal and no no no
5 mg/kg mercury Appropriate change change change
Disposal
Less than 5 but greater I-meter thick 15-cm Evaluate need I-meter
than 2.1 mg/kg mercury cap sediment cap for I-meter cap cap
Less than or equal to 2.1 Thin Layer No Action Thin Layer Evaluate need
mg/kg mercury but Placement Placement for I-meter cap
above MCUV (TLP)
1 Tests must be conducted in accordance with the State of Washington Sediment Management
Standards and must meet the MCUL biological criteria.
1 Areas in this category which are predicted to recover to the MCUL or below in ten years (using
approved modeling) do not require remedial action. Current EPA modeling indicates that intertidal
areas above MCUL for PAils but not mercury are predicted to recover naturally due to exposure to
air and light. All natural recovery areas will be monitored to evaluate progress toward achieving
MCUL.
.
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SEA69'O..PS.ROIECM..O.02IDISK EH 2'
"'-J
\D
CITY OF
BAINBRIDGE ISLAND
o
East Harbor problem areas are
not addressed in this ROD.
o
150
300
-~ST HARBOR OU
-----~' WYCKOFF
f- lEGEND FACILITY
o Only one PAH exceeds Sediment Cleanup levels
Chemical Criterion
~ Exceeds Sediment Quality Standards Chemical Criteria
~ Exceeds Sediment Cleanup Levels Chemical Criteria
lZ2J Intertidal HPAH area
Iim Exceeds 2.1 mg/kg mercury
ti",=,,'1 IntMidal mercury hot spot (>5 mg/kg mercury)
I
600
~
Scale in Meters
Figure 13
CLEANUP AREAS IDENTIFIED IN
WEST HARBOR SELECTED REMEDY
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.
potential habitat loss due to elevation changes from intertidal capping near the hotspot excavation. Restoration
of habitat would consider the PSEP Habitat Assessment Protocols (EPA, September 1991), and any necessary
mitigation of lost habitat will be required.
Sampling will be necessary to confirm the removal of sediments to the 5 mglkg mercury cleanup objective. If
solidification is required, treatability tests will be conducted during the remedial design phase. If on-site
containment is determined to be appropriate, requirements for locating, constructing, and monitoring disposal
areas will be identified during remedial design.
10.2.2 Mercury HAET Areas
Near the mercury hotspot are areas of the harbor where sediment concentrations are greater than 2.1 mglkg
mercury (shown on Figure 13). The value of 2.1 mglkg, the High Apparent Effects Threshold (HAET) for
mercury, is the concentration of mercury in sediments above which amphipod and oyster larvae acute toxicity
and benthic effects have always been observed in Puget Sound studies. The selected remedy for addressing
predicted or documented adverse impacts to aquatic life in such ar~ is an ill SilU sediment cap no less than I
meter thick (Alternative C).
Further mathematical modeling of the potential for natural recovery, in accordance with the Sediment Standards,
will not be considered for this area, becau~ concentrations of mercury are not expected to decline sufficiently
over ten years to meet the MCUL. However, biological testing may be conducted in accordance with the
Sediment Standards. If these tests show that thf\ sediments meet the MCUL biological criteria, the contingent
remedy will be precision placement of 15 to 30 centimeters of clean sediment (to provide coverage of at least 15
cm) to minimize any remobilization and/or bioaccumulation.
In biologically affected sediments under structures such as piers, or in shallow areas 3 meters or less below
mean lower-low water (MLLW), the selection of a I-meter thick cap or a 15 - 30 cm cap will be initially made
as described above. However, cap thickness, placement methods, and the potential need for excavation and
disposal of contaminated sediment prior to placement will be evaluated to allow consideration of engineering
feasibility, impacts on habitat or fisheries resources, stream flow from the adjacent ravine, and habitat
mitigation.
During remedial design, baseline sampling will be necessary to further define the areas requiring the I-meter
thick cap, and optional biological testing may be conducted at this time.
Both the I-meter and minimum 15-cm caps must achieve the MCUL within ten years froin completion of
remedial action. Performance standards for the selected (and/or contingent) remedy will be refined during
remedial design. They will include the following: clean sediment used for capping shall, at a minimum, meet
the SQS chemical criteria, effectively isolate contaminated sediments from the marine environment, and provide
suitable habitat for recolonization by benthic organisms. .
10.2.3 Intertidal HPAH
The selected remedy for intertidal sediments with HPAH concentrations of 1,200 #Lglkg or more (dry weight) is
natural recovery combined with institutional controls (Alternative B). In areas such as the former shipyard,
where contaminant concentrations exceed both this HPAH criterion and one or more of the chemical objectives
for mercury, sediments will be. addressed by remedial actions d~ribed for the appropriate mercury criterion (as
described in Sections 10.2.1, 10.2.2, and 10.2.4).
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.
The FS recommended 1,200 ",glkg HPAH in sediments (corresponding to the 90th percentile of Puget Sound
subtidal background concentrations for HPAH (PTI, 1989» as an objective for protection of human health.
HPAH most closely approximates the carcinogenic PAHs evaluated in the risk assessment, and clam tissue
concentrations from the RI showed a moderate correlation with intertidal sediment concentrations. Carcinogenic
P AH concentrations in clams from intertidal sediments containing HP AH above this criterion (See Figure 13)
resulted in cancer risk estimates above EPA levels of concern. In the West Harbor, intertidal sediments in
pubIic1y accessible areas near the ferry terminal and the former shipyard exceed this criterion.
In beach sediments adjacent to the ferry terminal, this HPAH criterion is exceeded, but metals are below the
MCUL chemical criteria. Because HPAH are rapidly degraded by exposure to ultraviolet or visible light (Payne
and Phillips, 1985), natural recovery is considered appropriate in these intertidal areas. Once significant source
control is achieved, PAH concentrations are expected to decrease to the MCUL within ten years.
Intertidal areas of Eagle Harbor exceeding the HPAH criterion correspond closely with areas where intertidal
sediments exceed two or more MCUL chemical criteria for PAHs. Some West Harbor locations along the north
shore are below the MCUL for metals and the HPAH criterion but may marginally exceed the MCUL chemical
criteria for PAHs. These areas will be monitored to ensure that natural recovery will achieve the MCUL
chemical criteria in these locations also.
The 1,200 ILglkg (dry weight) criterion is intended to protect human health. For this reason, biological testing
according to the Sediment Standards cannot be used to eliminate or reduce cleanup requirements contaminated
above this level. Optional biological testing is acceptable in intertidal areas which exceed the MCUL for PAH
but are less than or equal to 1,200 ILglkg HP AH (see Section 10.2.4 below). If the MCUL biological criteria
are met, these areas are eliminated from further consideration.
Sampling will be necessary to refine the problem areas and establish baseline information for monitoring natural
recovery. Contaminant concentrations in the above areas must meet the MCUL within ten years from control of
3ignificant sources of contamination to these areas. A contingency plan for enhancement of natural recovery,
for example by nutrient enhancement or tilling of the sediments, will be developed during remedial design. It
may be implemented within the ten year period if sediment monitoring does not indicate sufficient progress
towards the M CUL.
10.2.4 MCUL Areas
Areas of intertidal and subtidal sediment in the West Harbor not included under the foregoing sections exceed
the MCUL chemical criteria for mercury or PAH, based on existing data. These areas are shown in Figure 13.
Mercury concentrations are below 2.1 mglkg, thus less than 3.5 times the MCUL chemical criterion for.
mercury (0.59 mglkg dry weight), and in many locations are less than twice the MCUL chemical criterion for
mercury. Intertidal and certain subtidal sediments in the West Harbor are predicted to meet the MCUL
chemical criteria for PAH within ten years through natural processes (FS Appendix DI). However, significant
decreases in mercury concentrations are not expected in ten years due to the low sedimentation rate and the fact
that mercury does not break down. Existing biological information suggests that the impacts of the
contamination in.areas marginally above the MCUL chemical criteria are not severe and may not warrant a
meter-thick cap. Thus, the selected remedy for areas above the MCUL chemical criteria but meeting all other
site objectives is enhancement of natural recovery by means of low-impact capping\thin layer placement
(Alternative N).
Low-impact cappinglthin layer placement is defined as placement of shallow layers, mounds, or "windrows'
(longitudinal hills) of clean sediment intended to reduce concentrations in the biologically active zone without
causing widespread physical impacts on existing sediment biological communities. Low-impact capping/thin
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.
layer placement is technically feasible and is expected to enhance the low sedimentation rate in Eagle Harbor
sufficiently to achieve the MCUL objectives for PAH and mercury in areas addressed in this section within ten
years of completion of remedial action (COE, March 1992).
Natural recovery is a contingent remedy for this area or for portions of this area. Mathematical modeling
during remedial design to evaluate the potential for natural recovery is optional and must meet EPA
requirements. If such modeling predicts that certain areas will achieve the project objectives within ten years of
active remediation in the harbor through natural processes, the contingent remedy in these areas will be
monitoring and natural recovery without enhancement. However, if monitoring during the ten year period does
not confirm predicted progress toward the MCUL through natural recovery, low-impact capping/thin layer
placement may be required at a later date to ensure achievement of these objectives.
Optional biological testing in accordance with the Sediment Standards may also be conducted to define areas of
adverse biological effects. Areas which meet the MCUL biological criteria do not require cleanup. Thin-layer
placement is required in areas failing only one of the MCUL biological criteria, and a sediment cap may be
required in areas failing MCUL criteria for two or more biological criteria. Such failure indicates more adverse
biological effects than anticipated based on available data.
Performance standards will be further defined during remedial design. At a minimum, material used for thin-
layer placement and sediment caps will meet the SQS chemical criteria and will provide suitable habitat for
recoloniution by benthic organisms. Methods and costs for thin-layer placement have been evaluated by EPA
(COE, May 1992). A specific placement method will be selected during remedial design. It will provide for the
minimiution of impacts on existing biota and habitat while providing sufficient clean sediment to achieve the
MCUL in the top ten centimeters of sediment within ten years of placement.
Modeling may be required to develop design criteria which will ensure that areas of thin layer placement will
achieve the MCUL. If other contaminants exceeding the MCUL chemical criteria are identified during remedial
design, the selected remedy will apply as for PAHs and mercury (provided approved modeling predicts that the
actions will achieve the MCULs for these contaminants within ten years). If modeling does not predicet this
result, a thicker or more uniform cap will be required.
In the event that significant improvements in sediment quality are not indicated for PAH, mercury, or any other
contaminants exceeding the MCUL chemical criteria, EPA may require that additional clean sediment be applied
during the ten year period to achieve the MCUL.
10.2.5 SQS Areas
Although the site-specific objective is achievement of the MCUL, contiguous areas may exceed the long-term
goal of the Sediment Standards SQS chemical criteria. Limited monitoring will be required in these areas to
evaluate the effectiveness of source control and the effect of remedial actions in other areas. In addition,
engineering feasibility in implementing the capping alternatives may dictate placement of clean sediment in these
areas (Figure 13).
For example, to allow full coverage of areas currently above the MCUL chemical criteria, the trailing edges of
a cap or thin-layer placement may extend into the SQS area. Extending remediation into the SQS areas in this
manner is consistent with the intent of the Sediment Standards and could hasten the achievement of the SQS
throughout the West Harbor.
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.
10.3 Source Control
Source control actions described below as part of the West Harbor selected remedy include only actions to be
taken to identify and control significant upland sources of contamination to the West Harbor.
The following sources will be evaluated and controlled to the extent that sediment cleanup objectives defined in
Section 10 can be achieved and maintained, and that discharges will not cause violations of water quality
standards, the State Sediment Management Standards, or any other appropriate environmental standards:
o Stormwater discharges from urban runoff (e.g., storm drains)
o Marine operations (boatyards, marinas)
o Releases from contaminated uplands (e.g., shipyard area)
Contaminant releases from the former shipyard facility and from other upland sources, including stormwater
discharges and marine operations, are to be evaluated during remedial design. Remedial design and remedial
action will be coordinated with efforts to control significant sources of contamination. Cleanup of a given area
will occur after controls have been implemented for significant sources to the this area, to minimize potential
recontamination of harbor sediments. Since the mercury hotspot itself is believed to be a source of .
contamination, excavation of hotspot sediments may precede control of sources to other areas of the harbor.
Control of significant contaminant sources to sediment areas which are predicted to recover naturally, such as
near the ferry terminal, will signal the beginning of the ten year period of natural recovery in these areas.
10.3.1 Stonnwater
The following will be evaluated for potential stormwater discharge of chemical contaminants to the West
Harbor, and controls will be implemented as necessary:
o urban runoff
o runoff from parking and ferry maintenance areas
Source control efforts will be designed to minimize or eliminate discharge to the harbor of urban runoff in
exceedances of water quality standards, or at levels which may cause exceedance of the Sediment Standards.
Controls will consider recommendations in the Department of Ecology Stormwater Program manual.
Inspections of facilities and monitoring of sources and sediments will be conducted as necessary to document
control of sources.
10.3.2 Marine Operations
At Eagle Harbor, marine operations currently active include the Washington State Ferries maintenance yard,
several smaller boat yards, and a number of marinas and yacht clubs. At these facilities, inspection and
evaluation of potential sources and implementation of specific best management practices (BMPs) necessary to
assure source control will be conducted. These BMPs will be made enforceable through the issuance of orders,
or as requirements of National Pollution Discharge Elimination System (NPDES) permits.
The BMPs generally include a requirement that underground storage tanks (USTs) comply with federal and state
requirements. Several USTs are located on land adjacent to Eagle Harbor.' An inventory of such tanks, an
evaluation of their significance to harbor sediments, and their status of their compliance, will be completed as
part of the source control efforts in Eagle Harbor. A schedule for addressing noncompliant USTs will be
developed as appropriate.
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.
10.3.3 Contaminated Upland Areas
Although the shipyard practices that initially introduced significant amounts of contamination to the harbor have
ceased, contamination of upland surface soils at the former shipyard may be sufficient to cause further releases
of contaminants to the harbor.
Evaluation of the shipyard area as a continuing source of contamination to the harbor through surface water
runoff, point source discharges, or leaching and infiltration will be conducted. Washington State Department of
Transportation (WSDOT) samples of the former shipyard area indicate that, in some areas, PAHs and metals
exceed the state Model Toxies Control Act (MTCA) cleanup levels. Implementation of any necessary actions
(e.g., providing run-on/run-off control) to prevent contamination from upland areas of the former shipyard from
causing exceedances of water quality and sediment cleanup objectives will be required prior to sediment
remediation.
10.4 Institutional Controls
Consumption of clams, crabs, fish and other marine organisms from Eagle Harbor is considered a pathway of
potentially significant health concern.
Sinc,;: 1985, the Bremerton-Kitsap County Health District has alerted citizens to chemical and bacterial concerns,
advising against the harvest of fish or shellfish from the harbor, through signs posted in publicly accessible
areas, a hotline, and correspondence to potentially affected residents. EPA supports the continuation of this
advisory until chemical contaminants in seafood are below EPA levels of concern identified below. Although
not part of this ROD, it is expected that advisories for other reasons, such as bacterial contamination, will also
continue as necessary.
Using the reasonable maximum exposure assumptions of the risk assessment (see Section 7), EPA has identified
concentrations of methyl-mercury in fish and shellfish tissue which would produce a hazard index of I. Similar
values were calculated for carcinogenic P AHs which would produce a lifetime excess cancer risk of I~. These
indicator concentrations will be used during long-term monitoring to evaluate potential continuing human health
risks, and to generally assess the success of remedial action.
Concentrations of methyl-mercury corresponding to a hazard index of I are 0.22 mg/kg and 0.98 mglkg (wet.
weight) in fish and shellfish tissue, respectively. Since the benzo(a)pyrene slope factor is assumed to be the
same for all other carcinogenic PAHs, 15 JLgikg and 60 JLglkg total carcinogenic PAH concentrations in fish and
shellfish, respectively, correspond to an estimated excess lifetime cancer risk of 10"', using current PAH toxicity
information. (CH2M Hill, 1992). While these are the primary considerations for continuance of the health
advisory for chemical contamination, EPA and the health agencies may establish additional thresholds for other
contaminants to protect human health.
To supplement the Health District's efforts, additional warning signs (using the same visual symbols and the
warning in multiple languages) will be posted on publicly accessible beach areas and piers to make the warning
visible to recreational boaters and to people on the affected beaches. An informational display will be placed in
a high traffic area, such as the ferry terminal building. Periodic inspections and necessary maintenance of the
signs and the display will be conducted for the duration of the advisory.
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.
10.5
Monitoring
Monitoring is necessary to document progress toward and attainment of the cleanup goals and objectives
described in Section 10.1. Detailed plans for monitoring of chemical, physical, and biological conditions
before, during, and after remediation will be developed during remedial design. EP A will review and approve
the plans in consultation with Ecology, the Suquamish Tribe, and the appropriate public health and natural
resource agencies (Natural resource agencies include natural resource trustees, whose role in the Superfund
process is briefly described in the Responsiveness Summary, attached as Appendix C).
In addition to sediment chemistry and biological tests to document attainment of the cleanup objectives, the
plans may include sampling for other environmental conditions, such as physical conditions, concentrations of
contaminants in marine organisms of importance to human health or the environment, evaluations of the
diversity and abundance of marine organisms, and integrative measures of exposure to, or effects from,
sediment contamination, as discussed below.
Where possible, sampling and other activities will be conducted according to existing protocols (e.g., PSEP);
will complement other Puget Sound monitoring efforts (such as the Puget Sound Ambient Monitoring Program,
PSAMP); and will provide information for evaluating as many objectives as possible. If additional information
arises regarding sources, contaminants, or biological effects, sampling requirements may be modified by EPA.
Under federal requirements, monitoring may continue for as long as thirty years. New or modified monitoring
methods may be developed over this period. EPA will continue to evaluate these developments and, in
consultation with Ecology, the Suquamish Tribe, natural resource agencies, and other technical resources, will
adopt them as appropriate.
10.5.1 Monitoring for Environmental Conditions
The objectives of monitoring the harbor physical, chemical, and biological conditions in the West Harbor au
are briefly listed below:
.
to evaluate sources of contaminants and the need for source controls;
to determine areas, volumes, and other characteristics necessary for designing specific remedial actions;
to establish baseline conditions necessary for assessing the success of the remedial actions;
to evaluate short term environmental effects during implementation of the remedial actions;
to confirm predicted natural recovery of sediments within ten years from completion of West Harbor
remedial actions;
to evaluate the success of source control, natural recovery, sediment removal, capping, and thin-layer
placement in meeting and maintaining the cleanup objectives; and
to evaluate changes in the marine environment through measures which integrate overall conditions.
.
.
.
.
.
.
Monitoring plans to address these objectives will be developed during remedial design. Monitoring efforts will
be focused primarily on the first ten years after completion of remedial action. Final cleanup areas must be
determined, and baseline conditions must be established prior to remedial action. Any sampling necessary to
further characterize source control. needs wi II also be conducted during remedial design.
During excavation, dredging, or placement of clean materials, monitoring will be conducted to evaluate short-
term effects on the environment and to assure accurate and adequate materials placement.
If monitoring after remedial action documents compliance with the MCUL by or before the tenth year, the type
and frequency of monitoring may be adjusted, or monitoring may be phased out, provided continued compliance
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..
with the objectiveS is assured. If monitoring indicates that the MCUL may not be attained within ten years,
EPA wi\1 evaluate the need for additional remedial action during the CERCLA five-year review (Section 10.7,
below) or as appropriate.
10.5.2 Monitoring Hwnan Health Risks
Periodic monitoring for chemical contaminants in fish, crabs, and clams from Eagle Harbor wi\1 be used to
assess public health risks and evaluate the success of remediation in reducing contaminant concentrations in
edible seafood. A detailed monitoring plan wi\1 be completed during remedial design.
During remedial design, additional contaminants of potential concern, including PCBs, dioxins and furans, will
be monitored in seafood at least once to determine if further monitoring for these contaminants is needed.
At the CERCLA five-year review and ten years after completion of remedial action in the West Harbor, EPA
will evaluate the need for continued monitoring of fish and shellfish tissues. If tissue monitoring does not
indicate a trend toward decreasing concentrations of site contaminants ten years after completion of all final
remedial actions in Eagle Harbor, EPA will evaluate the need for additional action.
10.6 Implementation
Implementation of the selected remedy requires coordination among EPA, Ecology, and other involved
agencies, including the Washington State Ferries, the City of Bainbridge Island, the COE, natural resource
agencies, the Suquamish Tribe, and state and local health agencies. Coordination with the affected community
and potentia\1y responsible parties will also be important during remedial design and remedial action. Individual
actions within the West Harbor OU will be coordinated, and West Harbor cleanup activities will be coordinated
with actions in the East Harbor OU and Wyckoff OUs as appropriate. Although no critical habitats have been
identified in the West Harbor, EPA will continue to coordinate with the U.S. Fish and Wildlife Service to
assure that remedial activities do not adversely affect endangered species.
In order to expedite achievement of the cleanup objectives, mathematical modeling to evaluate natural recovery,
where considered by the selected remedy, should be completed as soon as possible. Biological testing to modify
cleanup areas or requirements may be conducted concurrently with baseline sampling. New information on
previously unidentified contaminants will also be evaluated during the remedial design phase and integrated into
the remedial design sampling and analysis strategy. For example, the presence of dioxin and PCBs in some
seafood warrants further development of sediment data and source information.
"
..,:,
Figure 14 provides a general framework for the timing of remedial activities. EPA anticipates that negotiations
with potentially responsible parties, remedial design (including sampling to refine problem areas and options),
and implementation may take two to three years to complete. A detailed schedule for activities such as source
evaluation and control, key aspects of the remedial design and remedial action phases, and development of
monitoring plans wi\1 be prepared as an initial step in implementation of the ROD.
10.7 CERCLA Five Year Review
The FS dIscussed the 5-Year Review mandated by CERCLA for remedial actions that leave contaminants at the
site. The review is required at least once every five years to ensure that human health and the environment are
being protected. The five-year review was considered necessary for all of the individual alternatives. The
review is required for the selected remedy, a combination of several alternatives.
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Framework for the Timing of Remedial Activities
SOURCE
ACTIONS
Source
Identification,
Control, and
Monitoring
Source Control
and Monitoring
Source
Monitoring
NO
--------------------------------------
YES
--------------------
I
00
....
Natural
Recovery
Recovery
Monitoring
I
SEDIMENT
ACTIONS
Remedial
Design
. Confirm source control
. Refine problem areas
Chemical sampling to refine cleanup areas
Optional biological testing
Optional modeling of natural recovery
. Select hotspot disposal option
Characterize waste sediments
Identify viable disposal s"es
Treatabil"y testing if necessary
YES
Remedial
Action
Disposal Site
and Cleanup
Area Monitoring
. Implement confinement
options
. Begin 10 year recovery
period
. Design remedial actions
---------~--~------------------------~-------------------
Key Decision Point Key Decision Point Figure 14.
TIME .. Framework for the Timing of
Remedial Action
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10.8 Costs
Estimated costs associated with the selected remedy are summarized in Table 16. Sediment cleanup volume
estimates will be refined during the remedial design phase, and costs are anticipated to change accordingly.
Costs may also be affected if optional biological testing and natural recovery evaluations result in modifications
according to the selected remedy.
The present worth cost estimates provided are intended to be within +50% and -30% of the actual costs of
remediation, and are based on volume estimates established during the FS using the following key assumptions:
.
Adverse biological effects will not occur in areas which meet the three EPA objectives and
which passed MCUL criteria for two acute toxicity tests during the RI. (Costs may increase if
areas defined by the MCUL chemical criteria are remediated without the use of biological
testing options.)
Natural recovery will not be predicted to occur in areas currently exceeding the MCUL for
mercury. (Costs may decrease if optional modeling of natural recovery identifies natural
recovery areas).
Mercury hotspot sediments will not exceed 7,000 cubic meters and will be disposed of at a
hazardous waste landfill. (Disposal at a municipal landfill or on site could decrease costs, but
costs could increase if volumes to be disposed of increase.)
Clean sediment for capping will be available at costs outlined in the FS. (These costs may be
lower if sediments scheduled for routine dredging by the U.S. Army Corps of Engineers are
available.)
Costs for West Harbor intertidal areas with 1,200 Jlglkg or more HPAH will be one third of
CQsts estimated in the FS for such areas in the combined East Harbor and West Harbor OUs.
.
.
.
.
Based on these assumptions, total costs for the selected remedy are e~pected to range from $6.2 to 16 million.
Costs associated with source control activities are not included in this ROD, because source controls are
expected to be implemented largely according to non-CERCLA environmental authorities and programs.
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I
00
\0
Table 16 - Estimated Costs for West Harbor Selected Remedy
PRESENT WORTH
CLEANUP AREA VOLUME/AREA ESTIMATE INITIAL COSTS. OF 0&1\1" TOTAL COSTS PRESENT WORTH"
Mercury Hotspot 1,000 - 7,000 m) 2.5 - 11.7 0.3 2.8 - 12b
Mercury HAET 4,600 m2 1.2 .3 1.5
Areas
MCUL Areas 283,300 m2 1.4 - 2.0 0.3 1.7 - 2.3
Intertidal HPAH 20,000 m2 0 0.2 0.2
TOTALS: 314.900 m2 5.1-14.9 1.1 6.2 - 16
. Cost estimates are in millions of dollars.
b Assuming disposal in a RCRA permitted hazardous waste landfill. For disposal in a municipal landfill, initial costs are expected to be no mOre than
$ 4.4 million, for a total costs of approximately $ 4.7 million.
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11. STATUfORY DETERMINATIONS
Under CERCLA, EPA's primary responsibility is to undertake remedial actions that assure adequate protection
of human health, welfare, and the environment. In addition, Section 121 of CERCLA establishes cleanup
standards which require that the selected remedial action comply with all applicable or relevant and appropriate
requirements (ARARs) established under federal and state environmental law, unless any such requirements are
waived by EPA in accordance with established criteria. The selected remedy must also be cost-effective and
must utilize permanent solutions, alternative treatment technologies, or resource recovery technologies to the
maximum extent practicable. Finally, CERCLA regulations include a preference for remedies that employ
treatment that permanently and significantly reduces the volume, toxicity, or mobility of hazardous waste as a
principal element. The following sections discuss how the selected remedy meets these CERCLA requirements.
11.1 Protection of Hwnan Health and the Environment
The selected remedy combines alternatives which were evaluated separately in the FS. It combines upland
source control, removal of hotspot sediments, capping of moderately contaminated sediments, low-impact
capping/thin layer placement of marginally contaminated sediments, and institutional controls.
Upland source control is intended to reduce or eliminate future contaminant discharges which could
recontaminate sediments. Removal of hotspot sediments, i.e., those with the highest mercury concentrations,
will eliminate a significant source of mercury contamination to the marine environment. Capping large areas of
subtidal sediments with clean materials is an effective means of quickly protecting the environment with minimal
short-term effects. Within areas to be capped, use of a meter thick cap will limit potential redistribution of
mercury and address more significant environmental risks. Low-impact capping/thin layer placement in
marginally contaminated areas will reduce surface sediment chemical concentrations to levels protective of
human health and the environment without unnecessary cost.
Restrictions on the harvest and consumption of contaminated seafood 'will further ensure protection of public
heal th.
11.2 Compliance with Applicable or Relevant and Appropriate Requirements
The selec~ed remedy will be designed and implemented to attain all ARARs identified in this section.
Applicable requirements are those clean-up standards and other substantive environmental requirements,
criteria, or limitations promulgated under federal or state law which specifically address a hazardous substance,
pOllutant, or contaminant, remedial action, location, or other circumstance at a CERCLA site. Relevant and
Appropriate requirements are those cleanup standards and other substantive environmental requirements,
criteria, or limitations promulgated under federal or state law which are not applicable, but nevertheless address
matters sufficiently similar to those encountered at a CERCLA site (relevant), and their use is well suited to a
particular site (appropriate).
ARAR compliance for on'-site remedial action is strictly limited to the substantive portions of ARARs.
Administrative or procedural requirements in ARARs, such as approval or consultation with administrative
bodies, permitting requirements, reporting, record keeping, and enforcement provisions need not be met. Off-
site actions, however, comply with both administrative and substantive aspects of federal and state law.
- 90-
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..
No waiver of any ARAR is sought or invoked in this ROD. The ARARs for the site are as follows:
By taking remedial action for sediments which do not meet the minimum cleanup level (MCUL), EPA
will comply with the substantive requirements of the primary ARAR, the State of Washington
Sediment Management Standards (Washington Administrative Code [WAC] Chapter 173-204).
Sediments are required to meet the MCUL ten years after the completion of remedial action, unless
otherwise indicated in the selected remedy.
Fill activities (e.g., capping in subtidal or intertidal areas) and dredging or excavation of contaminated
sediments (e.g., the mercury hotspot) will comply with the substantive requirements of federal
regulations promulgated pursuant to Section 404(b)(l) of the Clean Water Act (40 C.F.R. j 230) and
Section 10 of the Rivers and Harbors Act (33 C.F.R. j 320-330). These regulations are intended to
protect marine environments, and to prevent unacceptable adverse' effects on municipal water supplies,
shellfish beds, fisheries (including spawning and breeding areas), wildlife, and recreational areas during
dredging activities.
Fill, dredging, and other remedial activities conducted within 200 feet of the shoreline (e.g., at the
mercury hotspot) will also comply with the substantive requirements of the Kitsap County Shoreline
Master Plan (WAC 173-19-2604), as developed pursuant to the State Shoreline Management Act
(RCW 90.58), and adopted by the former City of Winslow.
If fill or dredging activities will change the natural flow or bed of state waters, EPA will meet the
substantive requirements of the Washington State Hydraulic Code Rules (WAC 220-110). These
substantive requirements are intended to protect fish by, e.g., placing limitations on the timing and
duration of dredge/fill activities. If it becomes necessary to re-route the stream entering Eagle Harbor
near Waterfront Park, relevant and appropriate requirements of these regulations pertaining to channel
changes will be met.
Liquids and other wastewaters from sediment dewatering or solidificationlstabilization processes will be
managed (treated and discharged) in compliance with substantive requirements of the following:
.
State of Washington Water Pollution Control Act (RCW 90.48) and Water Quality
Standards (WAC 173-201);
NPDES Permit Program (WAC 173-220) for effluent limitations, water quality standards,
and other substantive requirements; and
State Waste Discharge Permit Program (WAC 173-216) restrictions on certain discharges to
POTWs (if wastewater is discharged to a POTW).
.
.
Most RCRA hazardous waste is regulated under a program delegated to the Washington Department of
Ecology. State Dangerous Waste Regulations (WAC 173-303) promulgated pursuant to this authority
will be met. These regulations control most RCRA listed hazardous/dangerous waste (listed DW IHW)
and TCLP characteristic waste (characteristic DWIHW), and include criteria for .Washington-State-
only. dangerous waste (DW) and "extremely hazardous waste" (EHW).
Excavated sediments will be characterized pursuant to the Toxicity Characteristic Leaching Procedure
(TCLP) found in Appendix II of 40 C.F.R ~ 261. Failure of TCLP criteria generally causes waste
materials to be designated as characteristic DW IHW. Determinations of whether the waste is DW
according to other state criteria will also be necessary.
If the wastes are DW or DWIHW, the handling, storage, and disposal requirements of RCRA and lor
the State Dangerous Waste Regulations will be triggered for off-site actions. Prior to land disposal,
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DW IHW must be treated to meet the RCRA treatment standards for land disposal as set forth in 40
C.F .R. ~ 268. If waste cannot be treated to meet the RCRA treatment standards, a treatability variance
will be necessary prior to treatment and disposal at a landfill in compliance with federal and state
requirements (40 C.F.R. U 262, 268, and WAC 173-303-200 and 173-265-141).
For sediments which are state-only DW, off-site disposal must be at an approved hazardous waste
landfill. For sediments which are neither DW IHW nor state-only DW, disposal at an off-site municipal
landfill must comply with Washington State Minimwn Functional Standards (WAC 173-304). If a
suitable on-site disposal area is available, the relevant and appropriate requirements of the Minimum
Functional Standards will be met for disposal of "problem waste". Anyon-site disposal will be
protective of groundwater and human health.
Source Control Actions, including activities to control stormwater, marine operations, and contaminated upland
areas, will meet the substantive requirements of the following:
.
Washington Water Pollution Control Ad (RCW 90.48) and Water Quality Standards (WAC 173-
201); .
State Waste Discharge Permit Program (W AC 173-216~60) restrictions on certain discharges to
POTWs;
Effluent limitations, water quality standards, and other substantive requirements for treatment and
discharge re3trictions under the NPDES Program (WAC 173-220-120, 130);
Kitsap County Shoreline Master Plan (WAC 173-19-260).
.
..
.
Additional policies, guidance, and other laws and regulations to be considered for source control and remedial
actions include: .
.
Executive Orders 11990 and 11988 (40 C.F .R. 6, Appendix A) which are intended to avoid adverse
effects, minimize potential harm, and restore and preserve natural and beneficial uses of wetlands and
floodplains;
Requirements and guidelines for evaluating dredged material, disposal site management, disposal site
monitoring, and data management established by Puget Sound Dredge Disposal Analysis (PSDDA)
(1988, 1989);
Critical toxicity values (acceptable daily intake levels, carcinogenic potency factor) and U.S. Food and
Drug Administration action levels for concentrations of mercury and PCBs in edible seafood tissue;
EPA Wetlands Action Plan (U.S. EPA 1989) describing the National Wetland Policy and primary
goal of wno net loss";
Element 5-4 of Puget Sound Water Quality Management Plan (relating to confined disposal of
contaminated sediments) «1988, 1989, 1991»;
Puget Sound Stormwater Management Program (pursuant to 40 C.F.R. Parts 122-24, and RCW
90.48);
AKART (All Known, Available, and Reasonable Technologies) guidelines and 1989 PSWQA plan.
Elements P-6 and P-? for the development of AKART guidelines and effluent limits for toxicants and
particulates.
Federal Ambient Water Quality Criteria (40 C.F.R. 131)
Puget Sound Estuary Program Protocols, (1987) as amended, for sample collection, laboratory
analysis, and QA/QC procedures.
.
.
.
.
.
.
.
.
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11.3 Cost EtTectiveness
EP A believes that the combination of remedial actions identified as the selected remedy for the West Harbor OU
. will reduce or eliminate the risks to human health and the environment at an eJtpected cost between 6.2 and 16
million dollars. The remedy is cost-effective. It provides an overall protectiveness proportional to its costs.
By tailoring the remedy so that removal and any necessary treatment are applied to small-volume, high-
concentration sediments, and using lower-cost containment alternatives for the large areas of moderate to
marginal contamination, the selected remedy cost-effectively provides an appropriate level of protection for each
area. Allowing natural recovery in areas where cleanup objectives will be achieved in ten years, and allowing
biological testing to modify the selected remedy and perhaps eliminate cleanup areas, avoids costly and
unnecessary remedial actions. .
11.4 Utilization of Pennanent Solutions and Alternative Treatment Technologies
The selected remedy utilizes permanent solutions and alternative treatment technologies to the maximum extent
practicable. Among the alternatives which are protective of human health and comply with ARARs, the
selected remedy provides the best balance of long-term effectiveness and permanence;. reduction of toxicity,
mobility, volume, and persistenc~; short-term effectiveness; implementability; and cost. The selected remedy
considers the statutory preference for treatment as a principal element and considers state and community
acceptance.
A number of alternative technologies were explored in the FS, particularly for PAH-contaminated sediments.
However, alternative technologies for treatment of mercury-contaminated sediments are limited. Only one
treatment alternative, stabilization/solidification, was carried forward for detailed evaluation for mercury-
contaminated sediments, because of technical uncertainties associated with other treatment alternatives.
Excavation and solidification/st.!lhilization was evaluated for mercury-contaminated sediments.
Solidification/stabilization in place was also considered, but only for intertidal sediments. Although it was
advantageous in some respects, including cost, implementability, reduction of contaminant mobility, and short-
term effectiveness, in situ solidification has not been tested extensively in a marine environment. This
uncertainty led to a lower rating for long-term effectiveness and permanence.
While it was considered for all mercury contaminated sediments, treatment was found not practicable for large
volumes of sediments containing low contaminant concentrations. The mercury hotspot is a low-volume, high
concentration area, however, an~...if treatment is necessary to control leaching, it will be practicable and
appropriate.
Upland disposal of the mercury hotspot sediments is appropriate for reasons of long-term effectiveness and
permanence, because it permanently removes the most concentrated mercury contamination from the marine
environment. This important criterion outweighed the advantages of in situ solidification/stabilization and other
alternatives.
Treatment by solidification/stabilization may be required prior to land disposal of excavated mercury hotspot
sediments. These sediments may be hazardous or dangerous waste or may pose a threat to groundwater through
leaching. Solidification/stabilization will not be required if the excavated sediments do not pose a risk of
leaching.
-------
11.5 Preference for Treatment as a Principal Element
If solidification/stabilization is necessary prior to land disposal of excavated mercury hotspot sediments, the
selected remedy will satisfy the CERCLA preference for treatment of principal threats. If treatment is not
necessary for these sediments, disposal actions will be conducted in accordance with ARARs, but the preference
for treatment will not be satisfied. Remaining West Harbor sediments have lower concentrations of
contaminants and are not a principle threat. For these sediments, the selected remedy calls for engineering
controls such as capping and thin-layer placement.
-------
12. DOCUMENT A TION OF SIGNIFICANT CHANGES
Subsequent to issuing the Proposed Plan, EPA reviewed public comments. In response. EPA clarified the
cleanup objectives and areas with respect to the Sediment Standards, provided more detail for source control and
remedial actions for the West Harbor OU, and re-evaluated more cost-effective approaches to achieving the
cleanup objectives.
Based on these considerations, the following changes were made to the Proposed Plan and have been
incorporated into the selected remedy:
1.
2.
3.
4.
5.
6.
7.
Clarification of Low-Impact Capping/Thin Layer Placement methods and costs,
Clarification of the basis for defining capping subareas,
Further definition of future source control efforts,
Clarification of appropriate disposal for excavated sediments,
Elimination of the requirement for additional biological testing to determine cleanup areas.
Further consideration of Natural Recovery, and
Reevaluation of areas exceeding the Sediment Standards.
These changes are discussed below:
12.1. Low-Impact Cappingffhin Layer Placement Methods and Costs
The Proposed Plan described Low-Impact Capping (Supplemental Alternative N) broadly as a means to
minimize the impact of a thick cap in areas where contamination and biological effects were not severe. The
method would involve placement of clean sediment for dispersal, either by mechanical placement or natural
processes. Preliminary costs provided in the description of alternatives and in the Preferred Alternative
summary were based on placement of mounds of clean sediment on a grid pattern.
Under a cooperative agreement with EPA, the COE identified several feasible Low-Impact Capping methods.
Using computer modeling, existing information on harbor currents and biological data, current knowledge of
methods of sediment application, and information on sources of clean dredged material, the COE developed a
type of low-impact capping defined as Thin Layer Placement in a report issued in March 1992 (COE, 1992).
Thin-Layer Placement is the basis for the cost estimates provided for the Low-Impact Capping alternative in
Section 8 of this ROD.
In their 1992 report, the COE provided an initial cost estimate based on obtaining capping materials at low cost
from river dredging projects (excluding design, construction development, mitigation costs, eelgrass surveys,
operations and maintenance, and other items). These cost estimates were revised to be consistent with the
costing assumptions and methods used in the FS. The final cost estimate was comparable to the Proposed Plan
cost estimate for Low-Impact Capping, although actual costs may be reduced if lower cost dredging materials
can be used (Table 17).
1
-------
,
Table 17 - Comparison of Cost Estimates For Low-Impact CappinglTbin Layer Placement
Proposed Plan COE Report Revised Cost
Initial Costs' 1.8 - 3.3 0.28 1.9
Present Worth of O&M 0.3 none 0.3
Total Present Worth 2.1 - 3.6 0.28 2.2
I .
I . Cost Estimates are in Millions of Dollars I
12.2. Basis for Defining Capping Subareas
The Proposed Plan included Low-Impact CappingrThin Layer Placement as a component of the preferred
alternative, in combination with the removal of the mercury hotspot, natural recovery of the HPAH area, and
capping. Locations appropriate for Low-Impact Cappingrfhin Layer Placement should be determined hased on
harbor currents, existing chemical data, and the biological data gathered to delineate cleanup areas. The basis
for defining subareas for Low-Impact Cappingrfhin Layer Placement, or for a meter thick cap (or 15 -30 cm
thick cap if sediments meet Sediment Standards biological criteria) has been further defined in this ROD (See
Section 10, selected remedy).
West Harbor areas with concentrations of mercury below the HAET are considered appropriate for use of Low-
Impact CappingrThin Layer Placement. Harbor currents are sufficiently slow in the West Harbor that placed
materials would not be expected to erode. In West Harbor areas below the HAET for mercury, PAH
concentrations are also generally lower, and could be expected to recover naturally in ten years. Existing
biological data indicate that acute biological effects are generally not occurring in the West Harbor except where
PAHs exceed MCUL chemical criteria. Mercury concentrations below the HAET exceed the MCUL by a
factor of less than four, and enhancement of natural sedimentation may be sufficient to achieve the mercury
MCUL in ten years.
At concentrations four times the MCUL or more, mixing of surface sediments above the HAET is unlikely to
reduce contaminant levels sufficiently to achieve the MCUL chemi~l criteria within ten years. Such sediments
pose potential redistribution and biological uptake concerns and are predicted to have biological impacts greater
than those associated with the MCUL. As described in Section 10, areas above the mercury HAET merit a
sediment cap of one meter thickness to address predicted biological effects. However, if an absence of
biological effects can be demonstrated, a cap of 15 - 30 centimeters thickness is warranted and should be
sufficient to minimize redistribution and biological uptake.
12.3. Further Definition of Future Source Control Efforts
The Proposed Plan for the West Harbor Slated that "as a safeguard, the most actively used part of the old
shipyard would be tested before cleanup to ensure that rainwater runoff does not recontaminate the sediment.
Operations involving haurdous materials, such as boatyard work and ferry maintenance, would be monitored."
In the selected remedy, EPA has further defined the source control requirements for the West Harbor, and the
means of achieving source contro\. Because the harbor may be affected by a number of minor sources, EPA
-------
.
intends to address them by two means. Where probable upland sources are related to potentially responsible
parties for the Harbor OU, EPA will require an evaluation of these sources and impleme~tation of any
necessary source control for the West Harbor. For potential sources unrelated to potentially responsible parties,
separate arrangements will be made for the evaluation of these sources and implementation of necessary source
controls.
Costs for source control are not included in this ROD (See Section 10.8).
12.4. Clarification of Appropriate Disposal for Excavated Sediments
Appropriate Disposal, as described in the Proposed Plan, included only two disposal options for excavated
mercury hotspot sediments: disposal at a municipal landfill or at an approved hazardous waste landfill. The
ROD broadens the definition of appropriate disposal to include disposal at an upland location within the site. As
detailed in Section 10, on-site upland disposal may be appropriate for sediments which are not hazardous or
dangerous waste. The disposal area must be protective of.human health and groundwater, and must not cause
recontamination of the sediments after remediation.
12.5. Elimination of Requirement for Additional Biological Testing
The Proposed Plan stated that biological testing in areas exceeding the MCUL would be required in order to
define areas for cleanup. In order to be consistent with the Sediment Standards, however, this ROD
incorporates biological testing as an option, rather than a requirement. The Sediment Standards allow cleanup
areas to be defined solely on the basis of chemical data, but biological information, if obtained, outweighs
chemical information in determining these areas. The selected remedy also allows optional biological testing in
certain West Harbor areas to refine cleanup areas or modify the remedial action to be implemented for these
areas.
12.6. Consideration of Natural Recovery
The Sediment Standards allow natural recovery as an alternative to active remediation in areas where the
cleanup objectives will be met within 10 years. The Proposed Plan indicated that natural recovery was unlikely
in most areas of Eagle Harbor based on FS evaluations. Public comment indicated a preference for greater
consideration of natural recovery. In the selected remedy, Low-Impact CappinglThin Layer Placement is
. required for subtidal areas of the West Harbor exceeding the MCUL by a small margin. However, the remedy
allows for additional, more detailed evaluation of natural recovery rates as an option to further reduce areas
requiring active remediation. The evaluation must be approved by EPA and can be used to define areas for
natural recovery. Monitoring in these areas will be necessary to determine whether the predicted recovery is
occumng.
12.7. Reevaluation of Areas Exceeding the M CUI.. Biological Criteria
Comments received during the public comment period prompted a reevaluation of the basis for defining areas
failing the criteria of the Sediment Standards. The FS had identified areas which failed one or more of the
acute bioassays conducted during the RI and areas where one acute bioassay passed and the other acute bioassay
was either unknown or incomplete. The reevaluation of biological data revealed that the statistical interpretation
of oyster larvae bioassays completed during the RI was not correct. Figure 15 indicates changes as a result of
the recalculation. An. increased number of stations fail acute biological tests in the East and West Harbor OUs,
-------
.
including several stations adjacent to the fonner shipyard. Some locations with incomplete results for a second
acute bioassay are now shown to pass two acute toxicity tests, offsetting the additional failures in the West
Harbor. Overall, the changes support the link between areas with high contamination and acute biological
effects. However, they do not indicate areas meeting the Sediment Standards biological criteria, since
attainment of the chronic biological criterion cannot be demonstrated. Nevertheless, since cleanup areas will be
defmed on the basis of chemical data (unless additional biological testing or natural recovery modeling is
conducted) the revised results do not affect the selection of the remedy.
12.8 Summary
The above changes are logical outgrowths from infonnation in the Proposed Plan and RIfFS. The selected
remedy, which incorporates these changes, provides a framework for major West Harbor OU decisions.
Additional refinement of the selected remedy is anticipated during remedial design, based on biological and
chemical data, natural recovery modeling, waste characterization, treatability testing, and other potentially new
infonnation. Minor, significant, and fundamental changes to the remedy after issuance of the ROD will be
evaluated and made in accordance with the NCP.
-------
SEA60l0..PS.RDiECR/9-:\-OWISK EH
21IGFA
CITY OF
BAINBRIDGE ISLAND
. 660
684.
8 EH06
8659
8658
8837
717
8
.:Uj~
8634
.....
8657 8 EH03 8633
8668
. EH02
8
825
8843 8836
8 8
824 812
...
8 EH04
8667
8656 EAST HARBOR OU
8
631
..
\0
\0
EH16
8842 835 #811. ~ 8
8 8 EH23 7878 EH218.775
8841 823
8834 ~~
8622 8810 8798 .766 7;4 ~~ 8
EST HARBOR OUEH208 '\?i2' 750
. ..
EH138
Note: Samples taken during the Preliminary
Investigation (June 1985) and the Remedial
Investigation (March 1988, June 1988)
~
--I
.628 Sampling station (June 1985, March 1988,
June 1988)
~~ Previously shown as passing MCUL acute bioassay,
now falls
LEGEND
o
150
300
600
5:1<~ Previously shown as failing and still failing MCUL acute
bioassay
!<""><) Previously shown as failing MCUL
-""-"". bioassay, now passes
Scale in Meiers
.
643
8EH01
.630
11.":"'. :~.:?:.. ~",
r.629~6171
'li~
Figure 15 .
CHANGES IN AREAS ABOVE MCUl
-------
.
References"
CH2M Hill. Data Reoort. Remedial Investi2ation. Eal!le Harbor Site. KitsaD County. Washin2ton. Prepared
for U.S. Environmental Protection Agency. 1989. .
CH2M Hill. Ea21e Harbor Remedial Investi2ation Reoort for Ea21e Harbor Site. Kitsap County. Washinl!ton.
Prepared for U.S. Environmental Protection Agency. November 1989.
CH2M Hill. Technical Memoranda. Numbers 1 - 13. (Complete listing on Table I of ROD). Prepared for
U.S. Environmental Protection Agency. 1989 - 1991.
CH2M HilI. Revised Risk Assessment. Ea21e Harbor Ooerable Unit. Wvckoff/Ea2le Harbor Site. KitsaD
County. Washin2ton. Prepared for U.S. Environmental Protection Agency. May 1991.
CH2M Hill. Public Comment Feasibilitv Study. Eal!le Harbor ODerable Unit. Wyckoff/Eagle Harbor Site.
KitsaD County. Washington. Prepared for U.S. Environmental Protection Agency. November 199\.
CH2M HilI. Memorandum to ElIen Hale (EPA) Rel!arding PAH Indicator Concentration Update. May 18,
1992.
Fuentes, R. Memorandum to ElIen Hale (EPA) Regarding Eagle Harbor Mercury Hot Spot. Novem~r I,
199\.
Malins, D.C., et a\. Summary Reoort on Chemical and Biolol!ical Data from Ea21e Harbor. National Marine
Fisheries Service, Seattle, Washington. 1984bb.
Payne, J.R., and C.R. PhilIips, Photochemistry of netroleum in water. Environmental Science and Technology
19:569-579, 1985. .
Puget Sound Water Quality Authority. 1989 PU2et Sound Water Oualitv Mana2ement Plan (and updates).
Seattle, Washington. October 1988.
PTI Environmental Services. Performance Standards for Pu2et Sound Reference Areas. Draft Report.
Prepared for Washington Department of Ecology. Olympia, Washington. 1989.
PTI Environmental Services. Briefin2 Reoort to the EPA Science Advisorv Board: The AT1Parent Effects
Threshold Approach. Prepared for U.S. Environmental Protection Agency, Region 10. 1988c.
PTI Environmental Services. Confined Disoosal of Contaminated Sediments: Development Documentation.
Final. January 1990.
Simenstad et aI. Estuarine Habitat Assessment Protocol. Prepared for U.S. Environmental Protection Agency,
Region 10, Office of Puget Sound. September 1991.
-------
State of Washington Department of Fisheries. Salmon. Marine Fish. and Shellfish Resources and Associated
Fisheries in Washin$!ton's Coastal and Inland Marine Waters, Technical Report Number 79, Revised. April
1992.
Tetra Tech. Preliminary Investil!ation. Eal!le Harbor. Bainbrid2e Island. Washin2ton. Prepared for Black and
Veatch, Engineers-Architects under contract with the Washington State Department of Ecology. Bellevue,
Washington. 1986.
Tetra Tech. Health Risk Assessment of Chemical Contaminants in Pul!et Sound Seafood. Prepared for the
U.S. Environmental Protection Agency Region 10, Office of Puget Sound, Seattle, W A. Tetra Tech, Inc.
Bellevue, Washington. 1988.
Tetra Tech. PUl!et Sound Estuarv Prol!ram: Recommended Protocols for SamDlinl! and Analvzin!! Subtidal
Benthic Macroinvertebrate Assemblal!es in Pu!!et Sound (and other PSEP protocols and updates). Prepared for
U.S. Environmental Protection Agency, Region 10. Seattle, Washington. 1986.
U.S. Army Corps of Engineers, Seattle District. Thin Layer Placement of Dred!.!w Material. Ea!.!le Harbor,
Washin!!ton. Feasibilitv Analvsis. March 1992.
U.S. Environmental Protection Agency. An EXpOsure and Risk Assessment for Benzo(a)pyreneand other
Polvcvclic Aromatic Hvdrocarbons. Office of Water Regulations amI Standards, Washington D.C. 1982.
U.S. Environmental Protection Agency. Health Effects Assessment for Polvcyclic Aromatic Hvdrocarbons
(PAHs). Office of Research and Development; Office of Health and Environmental Assessment; Environmental
Criteria and Assessment Office. Cincinnati, Ohio. 1984.
U.S. Environmental Protection Agency. Risk Assessment Guidance for Superfund: Human Health Evaluation
Manual. Part A. Interim Final. OSWER Directive #9285-701A. July 1989c.
U.S. Environmental Protection Agency. Statement of Work. Remedial Investil!ation/Feasibility Study Risk
Assessment. Region 10. January 1990.
U.S. Environmental Protection Agency. Obtaininl! a Soil and Debris Treatabilitv Variance for Remedial
Actions (OSWER Directive # 9347.3-06FS). Office of Emergency and Remedial Response. September 1990.
"This is a partial list of documents used in preparing the Record of Decision. The decision is based on the
administrative record for the site.
b References from RIfFS documents retain the suffix letter used in the original citation for consistency.
-------
APPENDIX A
-------
.oEPA
Region 10
1200 Sixth Avenue
seattle WA 98101
December 16, 1991
Superfund Fact Sheet
Alaska
Idaho
Oregon
Washington
The Proposed Plan for Cleanup of Eagle Harbor
Wyckoff/Eagle Harbor Superfund Site
Bainbridge Island, Washington
Public Comment Period:
December 18,1991 - February 15, 1992
Public Meeting Schedule:
Informational Meeting to Discuss Cleanup Alternatives
January 15, 1992, 7:00 PM
Meeting for Public Comment
January 30, 1992, 7:00 PM
at
Commodore Middle School
9530 NE High School Road
Winslow, WA
Introduction
This proposed plandescri>eSthe U.S. Environmental Pro-
tection Agency's (EPA's) preferred cleanup plan for the
Eagle Harbor portion ofthe Wyckoff/Eagle Harbor Super-
fundSiteonBainbridge Island, Washington (FIgUre 1). EPA
is the lead agency forthe site and works closely with the
Washington Department of Eoology (Eoology). Thisdocu-
ment summarizes the cleanup altematives considered by
EPAandpresenls EPA'srecommerdedapproachforphased
cleanup of oontaminated sediments in the Eagle Harbor
portion of the site. Eoology supports this approach. .
This proposed plan describes cleanup altematives for
Eagle Harbor only. The Wyckoff/Eagle Harbor site is
currently divided into two units, the harbor and the Wyckoff
facility. Interim cleanup measures are underway at the
Wyckoff facility; final cleanup of the facility will be ad-
dressed in a future proposal. Contaminated beaches
adjacent to Wyckoff will be addressed in the Mure propos-
al for cleanup of the facility.
We invite you to comment on EPA's preferred plan and on
individual cleanup altematives. Your comments will
help EPA make a decision on the cleanup approach
for Eagle Harbor that is technically sound and ad-
dresses the concerns of the community.
An opportunity for questions and verbal comment will be
provided at two public meetings. Written comments on
the Proposed Plan and other alternatives should be
postmarked by February 15 and addressed to:
Ellen Hale
. EPA Site Manager, Eagle Harbor
1200 6th Avenue, HW-113
Seattle, WA 98101
This proposed plan summarizes information explained in
greater detail in the Eagle Harbor Remedial Investigation
and Feasibility Study. as well as in several Technical
Memoranda. These documents are available for public
review as part of the administrative record for the site at:
Region 10 EPA
1200 Sixth Avenue
Seattle, Washington
Tel: 553-1215
or
Bainbridge Public Ubrary
1270 Madison Avenue North
Winslow, WA
-------
2
the turn of the century. Past activities have been
identified as the primary source of the mercury and other
metals found in the harbor. PAH is also found near the
shipyard and ferrYtEmninat. .
Background
The Wyckoff/Eagle Harbor site was listed as a Superfund
site for investigation and cleanup of uncontrolled hazardous
substances in 1987. The site includes Eagle Harborandthe
former Wyckoff wood treating facility. Sediments in rruch
of Eagle Harbor contain hazardous substances such as
mercury and polynuclear aromatic hydrocarbons (PAH).
(FlQUres 2 and 3 indicate their distribution in the harbor.)
PAH represents a group of chemical compounds found in
creosote. used oil. and other sources. Mercury and other
metals in sediment are often associated with practices su.ch
as sandblasting and refurbishing boatbottoms. Whileother
substances have been detected , PAH andmerc:ury are the
primary contaminants of concem.
On the south shore, a succession of owners operated a
wood-treating facility from 1905 to 1988. Soils, beaCh
sediments, and ground water in this area contain corn-
pounds associated with wood treatjng, particularly PAH.
. The wood tr~ating facility has been identified as thepri~~ .
cy.source:ofPAHcontamination in the harbor. ...
.'n 1987. EPAseparatedthe WyckofflEagle Harborsiteinto
two units. . This allowed EPA to rOOveforward with the
investigation of the harbor while taking enforcement adion .
to reduce P AH contamination atthewood-treating facility.
Pacific Sound Resources, formerly Wyckoff Company,
began source control work under a 1988 administrative.
On the north shore of the harbor. ship building. mainte-
nance. and repair activities have been conducted since
D
Uountlake
Terrace
Kenmore
Bangor
Issaquah
o 5 Miles
~~......._-
~
N
Renton
to Kilom8ll1fS
-------
3
order, which has since been revised in a 1991 order.
Specifically, the company is pumping and treating P AH-
contaminated ground water and subsurface oil at the
facility. under EP A oversight.
EPA plans a detailed study of soil and groundwater con-
tamination at the Wyckoff facility and adjacent beaches in
order to develop a comprehensive cleanup plan forthis
area. This is a necessary step in the final cleanup of Eagle
Harbor. When proposed. the Wyckoff facility cleanup plan
will be subject to public comment.
Site Risk Assessment
EPAbelieves that existing human health and environmen-
tal risks warrant cleanup 01 the site. EPA evaluated
potential human cancer and non-cancer health risks from
eating fish and shellfish and from skin contact and inges-
tion of contaminated sediments.
The primary pathway for human health risk at Eagle
Harbor is long term, frequent consumption of P AH-con-
taminated shellfish. such as crabs and clams. Dataonfish
contaminants suggest that a steady diet of Eagle Harbor
fish should also be avoided until more is known.
In 1985. the Bremerton-Kitsap County Health District
issued a public health advisory cautioning against con-
sumption offish and shellfish from Eagle Harbor. Waming
signs are posted around the harbor and a hotline recording
confirms the advisory. EP A supports the health advisory
and will require continued monitoring 01 contaminants in
Eagle Harborfish and shellfish until the co ncentrations are
below EPAlevelsof concern. Monitoring 01 environmental
effects will also continue after cleanup.
Environmental damage is indicated by liver tumors in
English sole and toxic effects on some sediment-dwelling
organisms. Overthelastseveralyears, EPAand Ecology
have collected and analyzed sediment samples. shellfish
and fish tissues, and marine organisms in Eagle Harbor.
In addition to showing mercury. P AH, and other contami-
nants in seafood, the studies indicate that contaminated
sediments in parts of the harbor are damaging to marine
animals that live in or on sediment, such as bottom fish and
organisms such as bunowing worms and small crusta.
ceans. These organisms serve an important function in
the ecosystem of the harbor. EPA's Remediallnvestiga-
tion (11/89) and several supplemental reports describe the
results of EPA'swork.
Genera I Cleanup Goals
EPA's go~1 is to protect human health and the environ-
ment. EPA believes that existing human health and
environmental risks will be reduced by controlling sources
of contaminantstothe harbor and by addr.essing cOntam~.,
inated harbor sediments. Clean sediment provicles a'
betterhabitat for marine organisms and reduces qantam;
inants in the food chain. " '. .
The proposed plan describes cleanup altematives for two
general categories of sediment: .
. Intertidal: beach sediments exposed at tow tide,
and;
. subtidal: bottom sediments below the low tide line.
The objective of the plan is to address contaminated sedi-
ments and to ensure that they meet state and federal criterla
fortheprotectlOnofhumanhealthandtheeriVlrOnment. '." "
Cleanup Objectives -
Washington's Sediment ManaQement Standards
Inconducting Superfund cleanups, EPAisrequiredto meet .
or waive certain state and federal regl1tationS:nteseare "
referred to as "applicable or'relevant arid apprOpriate re-
quirements" (ARARs). For Eagle Harbor. the 1991 Sedi-
ment Management Stanc!ardsdevetoped bytheWashirgton
Department of EcologyareasignjficantARAR~ ~PA W111be
using the state sediment standiJrds astt1e'primarY
cleanup obj~ive for Eagle'HarDor~TtiegO~)of th~
standards is to "reduce and ultimately eliminate adye.rs,e
effects on biological resources and signifJCaf1t hea~i1threats
to humans from surface sediment contaminatiOrt. "." ."
The standards include a puget Sound-wide approach for
defining problem sediments tor cleanup. If sediment can
be cleaned up by natural processes in ten years, active
cleanup is not required. A combination of chemical and
biological tests is used -to define arE!as Yfhich may neec;i
cleanup. Chemical tests meaSureconcentrationsofco~
taminants in the sediment; biological tests assure th;rt the
combined effects of any contaminants present are Consid.-
ered in determining cleanup areas.
Adverse biological effects do not appear to be occurring in
all areas of Eagle Harbor . Tests showed definite biological
effects in the darkly shaded areasot Rgure4. Inthe tightly
shaded areas, where concentrations of mercury and/or
PAH indicate the potential for a biological impact, limited .
-------
4
ther biological testing in accordance with the state stan-
dards is necessary in these lightly"shaded areas to fully
evaluate potential biological effects from the chemicals
found in the sediment and to define cleanup needs.
EPA has identified two cleanup objectives in addition to
meeting the state sediment management standards--
specifically,
(1) to remove and dispose of sediment containing
high levels of mercury (more than 5 parts per
million mercury) because it may act as a source of
contamination to other areas of the harbor, and
(2) to address intertidal sediments with high-
molecular-weight PAH (HPAH) above 1200 parts
per billion. Tissues of clams taken from some
PAH-contaminated beaches contained HPAH at
levels of concem for public health.
Source Control
A major factor in any cleanup decision is whether sources
of contamination have been controned enough to avoid"
future contamination of cleaned-up areas. At Eagle Har-
bor, contamination from the shipyard activities on the.
northwest shore appear to be controlled. EPA will confirm
source control in this area prior to cleanup. "
Ground water contamination atthe Wyckoff wood treating
facility is a source of continuingPAH contamination 10
parts of eastemEagleHarbor. Wood-treating operations
were conducted at the facility for over eighty years under
various owners. Over the years, leaks. dripPage, and
spills of creosote and other wood preservatives resulted in
severe contamination of soil and groundwater at the
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5
es, and apparent movement of PAH into sediments some
distance from shore. To supplement ongoing oil and
groundwater extraction and treatment, EPA issued Wyck-
off an order for additional source control work at the site in
June 1991.
The potential for recontamination of the harbor requires
further evaluation. EPA does not expect to propose a
final cleanup plan for the eastem portion of Eagle Harbor
until sufficient information about the volume and move-
ment of contaminants from the Wyckoff facility and the
need for controlling this source is obtained. In contrast,
shipyard sources in the westem part of the harbor are
more easily controlled. Therefore, EPA is proposing a
final cleanup in this area.
. ::~~~~::. ~:". ,~,:::~,:,:,.::,:~~::)~;, i:~,:.:~~~~~:\:::«~i~~~~~h~i~\~i\~~*-,*~i~:@~\~ltb~~+~~~~~~k~R~r
Sediment Cleanup Alternatives
In the November 19%1 Eagle Ha.rbor Feasibility Study
(FS), EP A evaluated' several techQologieS' for, cleaning
up the harbor. The study defines preliminary' cleanup
areas and describes a range of technologies for cleanup
in these different areas, comparing effectiveness, cost,
feasibility. and other factors. Overall, the Cleanup alter-
natives fall into. three categories: . .
. no action,
- institutional controls, and
- active cleanup. . .
EPA always considers "no action" to compare risks. and
benefits of othercleanup approaches. Institutional controls
reduce exposure to contaminants. but don't clean up the
contamination. Active cleanup options range from oovering
Scale in Metem
~
Areas are approximate
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6
contaminated areas with clean sediment ("capping1 to
treating or disposing of contaminated sediment. Because
some cleanup alternatives do not apply to all contaminant
typeS or physical settings, EPA anticipated combining
alternatives ina site-wide plan. The FS provided examples
of several combinations and is available forpublic review at
EPA in Seattle and at the Bainbridge Public Ubrary. .
Common Elements ofthe Cleanup Alternatives
EPA has developed an integrated plan to address the
different sources. contaminants. and cleanup areas of the
harbor. The individual cleanup alternatives and EPA's
proposed plan are presented below. EPA encourages
comment on each altemative and on the integrated plan,
EP A's "preferred alternative".
Some elements are common to more than one alternative.
For example. EPA requires periodic monitoring for all
alternatives; including "no action, "to evaluate changes in
environmental conditions .with active cleanup or natural
processes. In all cases. EPAsupportscontinuationofthe .
current health advisory as long as necessary. Many ofthe
alternatives rely on some form of sediment containment.
-either in place, or in containment areas underwater, near
the shore, on adjacent uplands, or off site. Altematives D
throughJ require dredging of contaminated sediment, and
Alternatives H and L employ treatment to destroy organic
contaminants.
All alternatives other than No Action and Institutional
Controls include two additional steps before active clean-
up can occur:
(1) additional chemical and biological testing
according to the state sediment standards to further
delineate cleanup areas in the westem part of the
harbor,and
(2) an investigation of potential P AH movement from
the Wyckoff facility into the eastern portion of the
harborthroughdeep soils and sediment.
Plans for these two activities are summarized in supple-
ments tethe FS and would be implemented before cleanup
in each respective portion of the site.
EPA used available chemical and biological data to esti-
mate approximate cleanup areas and costs inthe FS. The
FS grouped areas by major contaminant (i.e. mercury or
PAH) and physical type (i.e., intertidal or subtidal) and
provided low-end and high-end area estimates. These
areas, shown below, formed the basis forthe costs provid-
edwith each alternative. .
Intertidal
Mercury (near city par1<) .............. 14,000 m2 (3.5 acres)
Intertidal
PAH (at ferry terminal) ................... 20.000 m2 (5 acres)
Subtidal -
Mercury ..,.............50.000-125.000 m2(12.5-31 acres)
Subtidal.
PAH ...................... 60,000 - 235,000 m2 (15- 59 acres)
Estimated
Sum of Areas: 144,OOO-394,OOOm2 (36-98.5acres)
Areas, and therefore costs, may increase or decrease
signifICantly, depending on the results of the additiOnal
biological testing and the PAH investigatiOn. The aCtual
cleanup area could decrease to 62,000 m2 (15.5 acres) or .
increase to as much as 650,000 m2 (160 acres)~(The ..
combined shaded areas shown in Figure 4 indicate this'
upper bound area.)
Costs forthe biologicaltesting in the westemportion and the .
PAH investigation inthe eastem J)<)rtion areineluded in the.
costs shown with each alternative, except for NoMion ar)d
Institutional. Controls. Timefram~ prQvided areforcomPIEt ..
tion ofthe cleanup aCtion mt~area.sconslcteied. Ch~1
and biological monitoring aftercleariw>wDlcOntinue.as~
as necessary. For costingpurpoSefj. monitoring~.aS~
sumedto continueforthirtyyears. These coSts. ar:e included
under operations and maintenance (0 &M). ' .
Discussion of the Cleanup Alternatives
Alternative A: No Action
Under "no action.~ the harbor would be left in its present
condition to recover overtime through natural processes
such as sedimentation (Le. gradual burial of contaminated
sediments), chemical and biological breakdown of PAH,
and dispersaUdilution of contaminated sediments.
Eagle Harbor has little new sedimentation, and mercury
does not break down over time. Burial. dispersal, or
dilution of mercury could take a very long time. EPA
estimates that even with complete source control, PAH
could take from 30 to 180 years to decrease to the state's
sediment chemical standards in heavily contaminated
areas. PAH exposed to light and air breakdown taster, and
some beach areas are expected to meet the state stan-
dards in ten years without active cleanup.
Costs forthirty years of monitoring fish and shellfishtissue,
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mated areas are shown below. The Wyckoff facility
cleanup woo Id continue, but no additional source investi-
gation or control work is included for the harbor.
Viable for: Mercury, PAH
Primary Area: Harbor-wide
Estimated Area: 144,OOO-394,OOOr02 (31.5-98.5acres)
O&M: O.8-1.2milliondollars
Total Estimate: 0.8-1.2 million dollars
Timeframe: not applicable
Altemative B: Institutional Controls/Natural Recovery
Institutional controls could include fencing of contaminat-
ed beach areas. restricting commercial fish and/or shell-
fish harvests, and posting advisory signs in order to limit
exposure of humans to contaminated seafood and sedi-
ments. Marine organisms would continue to be exposed
to contamination until the sediments recovered naturally
as described in Alternative A. Forthe purpose of estimat-
ing costs, periodic monitoring of fish and shellfish tissue,
sediment chemistry, and biological effects were assumed
to continue tor thirty years. "'.
Viable for: Mercury, PAH
Primary Area: Harbor-wide
Area Estimate: 144,OOO-394,Ooor02(31.5-98.5acres)
Initial Costs: 24,000 dollars for fence
0& M: 1 -1.2 million dollars
Total Estimate: 1-1.2 million dollars
Timeframe: Less than a year. ..,....,..
Altemative C: Capping
Capping with clean sediment limits movement of contam-
inated sediment, isolates contaminants from the marine
environment, and provides clean habitat for sediment-
dwelling organisms. In heavily contaminated subtidal
areas of Eagle Harbor, a three-foot thick sand cap would
beeffective. Where the current is strong, for example from
ferryprcpellerwash,coarSermaterialSwouldbepiacedon
top of the sand to keep it in place. Sediments saturated with
oily contamination would probably require a base layer
containing finer, clay-like materials to block contaminant
movement up through the cap. The need for additional
engineering controls would be evaluated during the de-
tailed cap design.
Viable for: Mercury,PAH
Primary Area: Harbor-wide
Area Estimate: 144,000 -394,000 m2 (31.5-98.5acres)
Initial Costs: 14.1 - 23.8 million dollars
o & M: 1.1 - 1.3 million dollars
Total Estimate: 15.2 - 25.1 million dollars
Timeframe: 2 - 4 years
Alternative D: Removal, Consolidation. Confined Aquatic
Disposal .
Confined aquatic disposal (CAD) would involve dredging
contaminated sediments from the subtidal and intertidal
zones, placing it in a pit dredged at the bottom of Eagle
Harbor. and covering the relocated sediments with clean
sediment originally dredged from the pit. The FS consid-
ered an area in the central channel ofthe east harbor for a
CAD location. Contaminated sediments removed fr:orn..
intertidal areas would be replaced with clean material to .
replace disturbed intertidal habitat. The top ofthe CAD
area would be level with the harbor bottom, and excess.
clean sedimentwoold be disposed of at ari'approvooopen
water site. ,'. ..' .
Viable for: Mercury, PAH
Primary Area: Harbor-wide
Area Estimates: 144,000 -394.000 ro2 (31.5-98.5 acres)
I nitial Costs: 21.3 - 46.9 million dollars
0& M: 1.4 -1.7 million dollars
Total Estimate: 22.7 -48.6 million dollars
Timeframe: 4 - 6 years
Alternative E: Removal, Consolidation, and Nearshore
Disposal
This alternative calls for constructing a sediment contain-
mentarea in the harbor adjacent to the shore. Contaminated
sediments would be dredged from subtidal and intertidal
areas, placed in the containment area, and capped with
clean sand. The containment area surface would be an
extension of theexisting land surface. Areas considered for
such containment include the log-rafting area near Wyckoff
and a smaller area east of the Winslow waterfront park.
Leaching controls and monitoring would be necessary.
Viable for: Mercury, PAH
Primary Area: Harbor-wide
. Area Estimate: 144,OOO-394,Ooom2(31.5-98.5acres)
Initial Costs: 71 -108 million dollars
0& M: 2.6 - 2.7 million dollars
Total Estimate: 73.6 -110.7 million dollars
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8
Alternative G: Removal, Consolidation, and Upland
Disposal at a Commercial Hazardous Waste Landfill
This altemative would involve dredging the contamina1ed
sediment, dewatering it. and transporting it to a permitted
off-site hazardous waste landfill. Barges and trucks would
be used fortransport ofthedredged sediment. Wastewater
would be treated on site. Mercury-containing sediments
would have to be treated (i.e. solidified) to meet standards'
for land disposal. Sediments with PAH contamination are
not considered for this altema1ive as most cannot be land
disposed without excessively costly treatment.
Viable for: Mercury
Primary Area: West Harbor subtidal and intertidal
Area Estimate: 64,000 -139,000 m2 (16-34.5 acres)
Initial Costs: 49.5 - 103.5 million dollars
0& M: 0.4 - 0.5 million dollars
Total Estimate: 50 -1 04 million dollars
Tmeframe: 1 - 2 years
Alternative H: Removal, Treatment by Incineration, and
Disposal
For this alternative, contaminated sediments would be
dredged, dewa1ered. ground to break up larger particles.
and incinerated. The incinera1orwould be a mobile rotary
kiln equipped with air pollution control equipment. The
incinerator could be located at Wyckoff facility or else-
where within the site boundaries. Incinerator residue
would be disposed of in accordance with state and federal
regulations. After burning, the sediment would be dis-
posed of either in an open water disposal site or at an
approved landfill. depending on the nature of remaining
ma1erials. Disposal restrictions on incinerated sectiments
containing wood-treating waste may make this altemative
difficult to implement.
Viable for: PAH .
Primary Area: East HartJorsutticlal. West HartJorinterticlal
Area Estimate: 80.000 - 255,000 m2 (20 - 64 acres)
Initial Costs: 173.9 - 273.6 million dollars
0& M: 0.5 million dollars
Total Estimate: 174.5-274.1 million dollars
Timeframe: 8 - 11 years
Alternative I: Removal. Treatment by Solidification-
Stabilization, and Disposal
Contaminated sediments would be dredged and mixed
with solidifying and stabilizing agents in equipment similar
tothat used for mixing concrete. The solidified seQiment -'
would increase in volume and \Vould be .d!sposed-of at a --. -
municipal landfill. Sediments with high concentrations of - - - .
P AH or other organics are not readily solidified. Only areas
with mercury contamination are included in the coSts .
below.
. .
Viable for: Mercury
Primary Area: West Harbor subtidal and intertidal
Area Estimate: 64.000 -139,000 m2 (16 - 34.5 acres)
Initial Costs: 17 - 34 million dollars
. 0 & M: 0.37 - 0.5 million dollars
Total Estimate: 17.4 - 34.5 million dollars
Timeframe: 3 - 6 years
Alternative L: Removal. Treatment by Biological Slurry.
and Disposal
Afterdredging and dewatering, contaminated sediments
would be mixed in a slurry. aerated, and gradually run
through a biological treatment system to breakdown'PAH
. and other organic contaminants. Biological trea1ment
tanks. which could be located on the Wyckoff property.
would be equipped with pollution controls. The treated .
sediment would have to demonstrate compliance with
standards foropen-waterdisposal. and wastewa1erfrom
the process would be biologicallytrea1ed on site. As with-
other biological treatment technologies, this altemative
would not be effective for sediments with high mercury or
other metals contamination. Costs are only for PAH-
contaminated areas.
Viable for: P AH
Primary Area: East Harbor subtidal
Area Estimate: 80,000 - 255.000 m2 (20 - 64 acres)
Initial Costs: 100.3 - 204.9 million dollars
0& M: 0.5 - 0.7 million dollars
Total Estimate: 100.8 - 205.6 million dollars
Timeframe: 9 - 11 years
Alternative M: In Situ Treatment by Solidification
This alternative is considered only forthe intertidal mercu-
ry area. Like Alternative I it involves solidification of
sediment, but nodredging would be needed. Thesediment
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9
mixed into the sediment by an auger-type mixer, backhoe,
or plow. A layer of clean sediment would be added after
solidification to provide habitat for marine organisms.
Viable for: Intertidal areas with mercury
Primary Area: West Harbor intertidal
Area Estimate: 14,000 m2 (3.5 acres)
Initial Costs: 4.3 million dollars
o & M: 0.2 million dollars
Total Estimate: 4.5 million dollars
Timeframe: 1 year
Supplemental Alternative N: Low-Impact Capping
This alternative is presented in a supplement to the Fea-
sibility Study. It provides a means to minimize the impact
of a thick cap where contamination and biological effects
are not severe. Clean sediment brought to the harbor
would be dispersed in a thin layer, either with natural
processes over a period of years or with mechaniCal'
placement. This approach would not apply in high-current
areas or heavily contaminated areas. Locations appropri-
ate for use 01 the low-impact cap would be determined
based on harbor currents, existing chemical data, andthe
biological datagatheredtodelineate cleanup areas in the
western areas. Preliminary costs and a comparisoliofthis .
approach to other alternatives will be provided in a supple-
ment to the Feasibility Study.
Viable for: Mercury, PAH
Primary Area: West Harbor subtidal
Area Estimate: 125,000 m2 (31 acres)
Initial Costs: 1.8 - 3.3 million dollars
0& M: 0.3 million dollars
Total Estimate: 2.1 - 3.6 million dollars
Timeframe: 2 - 10 years .
Table 1:
Evaluation Criteria .
EP A uses nine criteria to identify its preferred alternative for a given site or contaminant With the e)itception of the nq action
alternative, all altematives must meet the firsttwo -'hreshold" criteria. EP A uses the ne)Ct five criteria, 11S."balanci~g- criteria
for comparing alternatives and selecting a preferred alternative. After public comment; EP A may alter its p'reference on
the basis of the last two "modifying- criteria.
Threshold Criteria:
1. OVerall protection of human health and the environment - How well does the alternative protect human health and
the environment, both during and after construction?
2. CompUancewlth federal and state environmental standards - Does the alternative meet all applicable or relevant
and appropriate state and federal laws?
Balancing Criteria:
3. Long-term effectiveness and permanence - How well does the alternative protect human health and the environment
aftercornpletion of cleanup? What, if any, risks will remain at the site? .
4. Reduction oftoxlclty, mob1\1ty, or volume - Does the alternative effectively treat the contamination to significantly
reduce the toxicity, mobility, and volume of the hazardous substance?
5. Short-term effectiveness - Are there potential adverse effects to either human health or the environment during
construction or implementation of the altemative? Howfast does the alternative reach the cleanup goals?
6.lmplementablllty -Is the alternative both technically and administratively feasible? Has the technology been used
successfully on othersimilar sites?
7. Cost - What are the estimated costs of the alternative?
Modifying Criteria:
8. State acceptance - What are the state's comments or concerns about the alternatives considered and about EP A's
preferred alternative? Does the state support or oppose the preferred alternative?
. 9. Community acceptance - What are the community's comments or concerns about the preferred alternative? Does
the community generally support or oppose the preferred alternative?
i.
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EP A'5 Preferred Alternative
Portions of the harbor can and should be cleaned up now.
EPA is proposing to divide Eagle Harbor into two additiOnal
"operable units. with a separate cleanup plan for each. Thf3
division (Figure 4) is based on the types of contamination
present and the potential for recontamination. The Pre-
ferred Alternative would divide the harbor as follows:
1)The West Harbor Operable Unit would have a final
cleanup plan to remove the mercury hotspot and address
remaining contaminated sediments through in-place cap-
ping and institutional controls. Sampling before cleanup
would define biologically affected areas and the bound-
aries ofthe hotspot.
2)The East Harbor Operable Unit would have aniIJ1wim
cleanup plan, providing a permanent in-place cap forthe
severe PAH contamination in the central harborchannet.
Before placement of the cap, testing would be conducted
to evaluate the potential for recontamination by PAH
movingfrornWyckoff. Remaining contaminated areas in
the East H~rbor would be addressed in a future cleanup
plan, after a comprehensive study of the Wyckoff facility
provides abetterunderstanding 01 reco"tC!mination potell-
tiat for sediment closer to the facility.
As components of a dynamic natural system, all areas 01
thesite--East and West Harbor areas and the Wyckoff
Facility itself~~are interrelated. Prompt actioriisjustified in
areas where recontami!1ation is unlike.ly (i.e..t~e West
Harbor) and where the impacts of contamination are
particularly severe (i.e. the PAH hotspot inthe East Har-
bor). EP A believes that dividing the harbor and proceeding
with cleanup will ,accelerate the recovery 01 the Eagle'
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For most areas of Eagle Harbor, EP A prefers capping in
place to other ahemativesdeveloped. Treatment of large
volumes of waste containing relatively low levels of con-
tamination is expensive and slow. Capping is a cost-
effective remedy which can isolate any contaminants
present, both organic and inorganic. Capping is less likely
than dredging todisturb contaminants and releasethemto
the water and air. Cappingcanalso be implemented fairly
readily, allowing the harbor to start recovering sooner.
west Harbor
Proposed Final Remedy
Mercury Hotspot:
The principal contaminant in the West Harboris mercury.
The highest mercury concentrations are in the intertidal
area west of the ferry maintenance facility, where ships
were built and repaired from the tum ofthe century to the
late fifties. Other metals are also found here, as well as
PAH.
The "mercury hotspot" (Figure 2) merits cleanup as soon
as possible. Biological effects on marine life have been ,
observed, and the contaminated area is accessible to the
public. Mercury concentrations generally decrease with
distance from this area, indicating that it is a potential
source of mercury to the rest ofthe harbor. Removal and
properdisposalofthe mostcontaminated sediments should
prevent further spreading of mercury into the harbor.
EP A believes the risk of recontamination after cleanup of
the West Harboris low. As a safeguard, however, the most
actively used part of the olel shipyard would be tested
before cleanup to ensure that rainwater runoff does not
recontaminate the sediment. Operations involving haz-
ardous materials, such as boatyard work and ferry main-
tenance, would be monitored. '
IntertidalPAH:
Unlike mercury, PAH can break down naturally overtime
unclercertain conditions, particularly when exposed to air
and light. Beach areas nearthe ferrY landing contain PAH
above the state sediment standards and EPA's HPAH
deanupobjective. Bevated mercury concentrations were
notdetected.lnthisarea, EPAexpectsthatsediments will
meet the standardswithinthe accepted ten year period for
"natural recovery"- Monitoring of sediments and shellfish
would be conducted to ensure that PAH concentrations
were decreasing. The advisory against consumption of
seafoodwoulel be maintained.
Other Areas:
Other subtidal and intertidal areas in the West Harbor
contain PAH and mercury at lower levels (Figure 4).
Biologicaltesting in these areas would determine whether
additional cleanup is required to, meet the state sediment
criteria. If so, a layer of clean sediment woulO be IJsed to "
isolate the contaminated sedimer1tsand provide new hat>- '
itat. Periodic monitoring anCi the advisory against cOn-
sumption of fish and shellfish would continue until
concentrations fell below levels of concern.
Existing biological data have not indicated adverse biok>g-
ical effects in these areas. If more complete biological'
testing shows limited adverse effects-for example, failure
of biological tests by a narrow margin, failure of only one
of the three test types, or scattered failures--a thick cap
may be inappropriate. EPA has. evaluated thelowei'-
impact Alternative N for feasibility inth.e West Harbor. Tt1is ,
method could bring sedime.ntconcentrations below levels "
of concemwithin a tEm year period and maybe preferable
to the thicker cap in less contaminated areas. Further
evaluation of the low-impact cap, either alone orin combi-
nation with the thick cap, may be appropriate during
detailed design of the West Harbor cleanup; , .
East Harbor
Proposed Interim RemedY
East Harbor Hotspot:
The principal contaminant of concem in the E,ast Haft>9r is
P AH. Adverse biological effects have been demonstrated '
in the most heavily PAH-contaminated areas. Because
PAH continues to enter the harbor near Wyckoff, EPA is
proposing initial cleanup of only part of the East Harbor,
with final cleanup to be proposed in the luture.
The interim proposal focuses on the most severely P AH-
contaminated area, known asthe"central harbor hotspor
(Rgure 3). Tidal currents and propellerturbulence during
low tides keeps the PAH contamination in this area ex-
posed and may spread contaminants to adjacent areas. A
cap of clean sediment would be placed overthe hotspot to,
provide a better habitat for marine organisms. 'Special
capping techniques would be needed to keep the clean
material in place and to successfully contain the PAH.
EP Adata suggestthatthis area is far enough from Wyckoff
10 nolongerbesignificantly affected by PAH seepage from
thefacility. As part of the plan, the additional investigation
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12
to cleanup to confirm this hypothesis. This investigation
would include deep wells on the Wyckoff facility and deep
borings between the facility and the hotspot. If the tests
indicate thatthe risk of recontamination is high. additional
. work to control the sources would be required before
cIearwp. .
The investigation may show that the risk of recontamina-
tion is low enough to warrant prompt cleanup of additional
areas between the hotspot and Wyckoff where acute
biological effects were shown (the darker shaded area of
the East Harbor). EPA is considering the central area
"hotspot" as a minimum area for this partial East Harbor
cleanup, and the total area of known biological effects as
a maximum.
Other East Harbor Areas: .
Although the East Harbor contamination (Figure 4) con-
sists mOstly of PAH, some mercury contamination is also
present nearthe Wyckoff facility. Removal ofthe mercury
hotspot in the West Harbor should limit increases in
mercury contamination in the East Harbor.
A final proposed plan for cleanup of contaminated areas
not addressed in the East Harbor interim cleanup will be
presented for public comment after confirmation of suffi-
cent source control. The plan will be developed after a
comprehensive study of the Wyckoff facility and. if neces-
sary, after cleanup of soil and ground water at Wyckoff. At
that time. likely to be several years from now. sediment
cleanup alternatives will be further evaluated. Public
comment on the cleanup proposal for these areas will be
solicited before a final decision is made.
Preferred Alternative Summary
WEST HARBOR
Mercury Hotspot-Removal and Disposal of Sediments
Sediments containing mercury concentrationsgreaterthan
5 parts per million (ppm) would be removed and disposed
of at a landfill-either a hazardous waste or municipal
landfill, depending on the leaching characteristics of the
waste. Clean fill material would be used to restore the
original bottom contours where necessary.
Volume Range: 1000 - 7000 m3 (m3 is cubic meters)
Cost Range: $ 3.1 -12.4 million (hazardous waste
landfill)
(rrorq,allandfilloostsareaboutSOOlobNer)
Timeframe: 2 - 3 years
PAH Intertidal (ferry terminal)--Institutional Controls!
Natural Recovery
The area would be monitored and allowed to recover
naturally inten years. The existing advisory and additional
signs would be used to alert the public to risks from
consuming contaminated shellfish. Costs assume moni-
toring for thirty years.
Area Estimate: 20.000 rW
Cost Estimate: $137.000
Timeframe: not applicable
West HarborlntertidallSubtidal- ThickCapandiorLow-
Impact Cap
After cleanup areas are further defined by biological tests,
contaminated intertidal and subtidal sediments on the
West Harbor will be addressed by a clean sediment cap
(either the thick cap described in Memative C.a low-
impact cap such as described in Supplemental Alternative
N. or a combination).
Area Estimate: 50.000 -125,000 m2 (12.5- 31 acres)
Cost Range: $ 5.5 - 7.9 million (thick cap)
$ 2.1 - 3.6 million (thin cap)
Timeframe: 2 - 4 years
EAST HARBOR
East Harbor Subtidal Hotspot- Thick Cap
This area. under 35 to 50 feet of water in the central
channel. would be covered with a thick cap and armored
to prevent loss of capping material. The capped area could
be increased to include other biologically affected areas if
the PAH investigation indicates that recontamination is
unlikely.
Area Estimate: 60,000 - 235,000 m2 (15 - 59 acres)
Cost Range: $ 7.5 - 15.1 million
Timeframe: 3 - 4 years
Preferred Alternative Summary
Total Area: 144.000 - 394,000 rW (31.5-98.5acres)
T etal Costs: Approximately 1 i .2 - 32.8 million dollars
Total Timeframe: up to 4 years
~."7)~~~'R-~ '
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Analysis of Alternatives:
The ahernatives in the FS were evaluated based on the
nine evaluation criteria described in Table 1. The following
is a discussion of that evaluation.
protectiveness of Human Health
and the Environment:
All cleanup alternatives except No Action and Institutional
Controls protect human health and the environment. No
Action can be protective of the environment in areas where
natural recovery can occur in ten years. In these and other
areas,lnstitutional Controls can be used to provide protec-
tion of human health. Altematives involving on-site con-
tainment of contaminated sediments require long-term
monitoring and maintenance in orderto assure continued
protection.
EPA's preferred altemative is protective of both public
health and the environment. It removes source metals,
addresses human health risks from consumption of con-
taminated seafood bycontinuingthe existing advisory until
contaminants are below levels of concem, and isolates
sediment from adversely affected marine organisms.
Compliance with ARARs:
All altematives except No Action and Institutional Controls
comply with the state sediment standards throughoutthe
harbor. Altemative F, involving anonsite landfill at Wyck-
off. may not meet state criteria forthe disposal of hazard-
ous waste. Altemative G, involving transport of the
contaminated sediment to an offsite landfill, would be
subject to state and federal dangerous and hazardous
waste regulations, as well as treatment standards for Land
Disposal Restrictions.
No Action and Institutional Controls would meet the state
sediment management standards ONLY in areas where
natural recovery could occur in ten years. EPA and
Ecology believe that intertidal sediments on the north
shore exceeding the state standards for PAH but not for
metals may meet the ten-year requirement with natural
reccNery.
EPA's preferred altemative can meet all ARARs.
Long-Term Effectiveness and Permanence:
Biological Treatment and Incineration permanently de-
stroy P AH and other organic compounds. Mercury,. an
element, cannot be destroyed. Solidification can keep
metals from moving, but is not as effective for organic
compounds such as PAH. Options involving containment
do not permanently remove or destroy the contaminants.
Superfund policy generally favors on-site treatment op-
tions over institutional controls or off-site disposal of
untreated waste.
Containment is most appropriate for areas with mixed
organic and metal contaminatiOn. espeCially when very
large volumes of relatively Iow-concentrationwaste are
involved, as with many contaminated. sedim~.n~ site!? . ..
Containment requires maintenance to be effective long .,
term. Offsite containment at an approved hazardous: ,
waste landfill can also provide effective long term Control.' .
The preferred altemative combines removal of the m~rcu-
ry source sediments with capping where bioloQiCal effects
are shown. Solidification and appropriate landfill selection'
will be relatively permanent. Longterm monitoring aOOlor
maintenance will be needed in the caPped areas: . ,
Reduction of Toxicity, Mobility. and Volume:
Biological treatment and incineration would reduce the
toxicity and mobility of PAH contamination, but would not
eliminate metals. Solidification (Alternatives I, M, and
potentially other options involving land disposal) 'would
decrease the rnobilityofthe metal contaminants, but would
increase the volume.
Under the preferred altemative, mercury source sedi-
ments would be solidified before landfill disposal. Cap-
ping, a major component of the preferred alternative, does
not aher the chemical nature of the contamination, but
restricts the movement of sediment particles to which
organic contaminants are bound.
Short-Term Effectiveness:
Capping with clean sediment provides the greatest short-
term effectiveness because it can be implemented most
quickly. Any altemative involving the dredging of subtidal
contaminated sediments could have negative short-term
impacts on the environment, particularty in areas with
heavy PAH contamination. Dredging could remobilize
contamination into the water, particularly for oily, PAH-
contaminated sediments, causing contamination to spread
to nearby areas. Intertidal areas can be excavated at low
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Studies show that marine organisms soon repopulate
clean sediment. This process can begin immediately after
capping or removal of contaminated sediments, butdevel-
opment of a mature community of sediment-dwellerscan
take several years. Recolonization of larger areas may be
slower.
Implementabllity:
All ofthe altematives can be implemented, although with
varying degrees of diffICUlty. Options involving removal
and dewatering of sediment prior to treatment, contain-
ment. or disposal require the management of sediment
and drained water. Treatment options would necessitate
storage or sequential dredging to accommodate the mate-
rials to be treated.
Air monitoring and controls, engineering controls to limit
water column releases, and coordinating ferry and tidal
schedules pose additional challenges for options involving
dredging and. to a lesser extent, capping. Institutional
controls would require coordinated action with state and
. local entities.
The capping component of the preferred altemative in-
volves no dredging , storage, dewatering, or processing of
contaminated sediment. Careful design, scheduling, and
environmental monitoring are essential. Removal of the
mercury source sediments can be done from land at
extreme low tide. These options are more readily imple-
mentedthan most ofthe other active cleanup alternatives.
Cost:
The estimated cost range provided with each altemative
assumes the alternative is applied wherever feasible and
appropriate, given the contaminants and physical location.
Ingeneral, initial costs for treatment options and dispoSal
options are high. Containment costs tend to be lower
initially, with higher monitoring and/or maintenance costs.
Institutional controls are usually the least costly. The
preferred alternative combines offsite disposal, contain-
ment in place. and institutional controls.
What Next?
Two public meetings about this plan will be held in Winslow
in January. The first, on January 15, is an opportunity to
discuss the proposed plan and to ask questions. The
second, on January 30, is for additional Questions and
formal public comment.
EPA will respond to written and verbal comment on the
proposed plan in a document called a "responsiveness
summary." After considering all public comments, EPA
will make its cleanup decisions forthe East Harbor and the
West Harbor operable units. The decisions will be docu-
mented in two "Records of Decision" (RODs), with the
responsiveness summary attached.. Both RODs will be
available for review at EPA and the public library in
Winslow.
Once the ROD is signed. EP A will enter into negotiations
with the potentially responsible parties to implement the
cleanup outlined in the RODs. .Implemerrtation inCludes
necessary testing and detailed engineering design before.
actual cleanup action begins. To ensure the continued
protectiveness of Superfund cleanups where contami-
nants remain on site, EPA requires a review every five
years after cleanup activities begin.
For Furthur Information
I Contact:
Ellen Hale
EPAProject Manager
(206) 553-1215
or
Dan Phalen
EPA Community Relations Coordinator
(206) 553-6709
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APPENDIX B
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STATE OF WASHINGTON
DEP ARTMENT OF ECOLOGY
Mail S/oP P\.'- /1 .
()/)'mpia. \'\/a,l1;ngron
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