EPA/ROD/R10-94/082
November 1994
EPA Superfund
Record of Decision:
Wyckoff Groundwater Operable Unit,
Wyckoff/Eagle Harbor, WA,
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u.s. Environmental Protection Agency
Region 10
Seattle, washington
Wyckoff Groundwater Operable Unit
Wyckoff/Eagle Harbor Superfund Site
INTERIM RECORD OF DECISION
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.1.
CONTENTS
LIST OF FIGURES
LIST OF TABLES
DECLARATION
.
Site Name and Location
.
Statement of Basis and Purpose
.
Assessment of the Site
.
Description of the Selected Remedy
.
Statutory Determination
DECISION SUMMARY
A.
Site Name, Location, and Description
B.
Site History and Enforcement Activities
C.
Highlights of Community Participation
D.
Scope and Role of Operable Unit Within the Site Strategy
E.
Summary of Site Characteristics
(
.
Conceptual Model
.
Nature and Extent of Contamination
F.
Summary of Site Risks
G.
Remedial Action Objectives
H.
Description of Alternatives
.
The Groundwater Treatment Plant
.
The Groundwater Extraction System/Hydraulic Barrier
.
Installation of Physical Barriers to NAPL Movement Off Site
.
Seal and Abandon Drinking Water and Other Water Supply Wells
Summary of Comparative Analysis of Alternatives
Threshold Criteria
.
Protectiveness of Human Health and the Environment
.
Compliance with ARARs
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Primary Balancing Criteria
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Long-Term Effectiveness and Permanence
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Reduction of Toxicity, Mobility, and Volume Through Treatment
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Short-term Effectiveness
.
Implementability
.
Cost Effectiveness
Modifying Criteria
.
State Acceptance
.
Community Acceptance
J.
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L.
Selected Remedy.
.
Replace Existing Treatment Plant
.
Evaluate, Maintain, and Upgrade Existing Extraction
System/Hydraulic Barrier Operations
.
Evaluate Performance of Current Extraction System/
Install Barriers
.
Seal,and Abandon Onsite Water Supply Wells
.
Costs of Selected Remedies
Statutory Determinations
(.
.
Protection of Human Health and the Environment
.
compliance with ARARs
.
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Practicable
.
Preference for Treatment as a Principal Element
RESPONSIVENESS SUMMARY
Documentation of Significant Changes
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~igure 1:
Figure 2:
Figure 3:
Figure 4:
Figure 5:
LIST OF FIGURES
Site Location
Wyckoff/Eagle Harbor Superfund Site Operable Units (OU)
Wyckoff Facility, Location of Water Supply Wells
Wyckoff Groundwater OU Contamination
Concentrations of TPAH at Stations Sampled During
RI "(June 1988) and PI (1986)
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Table 1:
Table 2:
Table 3:
Table 4:
Table 5:
Table 6:
LIST OF TABLES
Well Drilling, Construction, and Hydraulic Data Summary
for Water Supply Wells at the Wyckoff Facility
Summary of Current Effluent Limitations and Monitoring
Requirements
Summary of Detected Analytical Results and Comparison to
MCLs for Groundwater in the Water Table Aquifer
Evaluation Criteria
Comparison of Costs for Interim Remedial Alternatives
Costs of EPA's Selected Interim Remedial Alternative
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DECLARATION
FOR THE
INTERIM RECORD OF DECISION
site Name and Location
wyckoff/Eagle Harbor superfund site
Groundwater Operable Unit
City of Bainbridge Island, Washington
statement of Basis and purpose
This decision document presents the interim remedial action
selected by the U.s. Environmental Protection Agency (EPA) for
the Wyckoff Groundwater Operable Unit, one of four.operable units
at the Wyckoff/Eagle Harbor Superfund site, iocated at Bainbridge
Island, Kitsap County, Washington.
The remedy was chosen in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of
(CERCLA), as amended, and, to the extent practicable, the
National oil and Hazardous Substances Pollution contingency
(NCP). This decision is based on the Administrative Record
this site.
1980
Plan
for
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Concurrence by the State of washington, Department of Ecology is
under consideration.
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 Selected Remedy
The remedy selected in this interim Record of Decision addresses
the need to contain contaminated groundwater and non-aqueous
phase liquids (NAPL) to the immediate area of the wood treatment
operations of the former Wyckoff facility and not allow it to
migrate into Eagle Harbor or into deeper drinking water aquifers.
The selected remedy for the Wyckoff Groundwater Operable Unit
includes: .
.
Replace existing groundwater treatment plant,
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."
.
Evaluate, maintain, and upgrade existing extraction
system/hydraulic barrier,
.
Evaluate performance of current extraction system/
install physical barrier, "
.
Seal and abandon onsite water supply wells.
statutory Determination
This interim action is protective of human health and the
environment, complies with Federal and State applicable or
relevant and appropriate requirements for this limited-scope
action, and is cost effective. Although this interim action is
not intended to address fully the statutory mandate for
permanence and treatment to the maximum extent practicable, this
interim action does utilize treatment and thus is in furtherance
of that statutory mandate. Because this action does not
.constitute the final remedy for the Groundwater Operable unit,
the statutory preference for remedies that employ treatment to
reduce toxicity, mobility, or volume as a principal element will
be addressed fully by the final response action.
Subsequent actions are planned to fully address the threats posed
by the conditions at this operable unit. Because this remedy
will result in hazardous substances remaining on site above
health-based levels, a review will be conducted to ensure that
the remedy continues to provide adequate protection of human
health and the environment within five years after commencement
of the remedial action. Because this is an interim action ROD,
review of this site and this remedy will be ongoing as EPA
continues to develop final remedial alternatives for the
Groundwater Operable Unit.
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Date Chuck Clarke
Regional Administrator
U.S. Environmental Protection Agency
Region 10
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DECISION SUMMARY
Wyckoff/Eagle Harbor Superfund site
Groundwater Operable unit.
City of Bainbridge Island, Washington
A.
site Name, Location, and Description
The Wyckoff/Eagle 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 (Wyckoff facility), the adjacent Eagle Harbor, and other
upland sources of contamination to the harbor, including a former
shipyard. The Wyckoff facility has been divided into two
operable units (OUs): the Wyckoff Facility OU, including surface
soil, subsurface soil, and surface water, and the Wyckoff
Groundwater OU, including groundwater at or beneath the facility.
The Wyckoff OUs, together with the East and West Harbor OUs,
constitute the Wyckoff/Eagle Harbor Superfund site as shown in
Figure 2. This interim ROD addresses only the Wyckoff
Groundwater OU.
Land use on Bainbridge Island, recently incorporated as a city,
is principally residential, with some commercial and industrial
use. The Wyckoff facility is located on the south shore at the
mouth of the harbor. The former City of Winslow lies on the
north side of Eagle Harbor. Residences, commercial centers, a
04ty park, several marinas, and a ferry terminal characterize th~
northern shoreline. The western and southern shores ate
primarily lined with residences, farms, marinas, and a boatyard.
The primary land use to the south of the facility is residential.
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.
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 wildlife. 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.
The shoreline to the Wyckoff property has been extended and
filled at least twice. ~he average ground surface elevation at
the Wyckoff Facility OU is approximately ten feet above mean sea
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~
Kenmore
~ Scale in Mile~ @
Norlh
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Figure 2
WYCKOF~EAGLEHARBOR
SUPERFUND SITE OPERABLE UNITS (OU)
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WEST HARBOR OU
\
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/
/
/
/
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\
\
\
EAST HARBOR OU
~
- - - - Approximate Location
of Property Line
L---------
Property Line - - - - - --
Note: OU Boundaries are approximate
WYCKOFF
FACILITY OU
BOUNDARY
~,~
'- WYCKOFF
GROUNDWATER
OU BOUNDARY*
o
300
600
. The Wyckoff Groundwater OU boundary extends toward
Eagle Harbor to include subsurface marine sediments
contaminated by fluids migrating from the facitity. It may also
be found to extend further upgradient to the south.
I
150
Scale in Meters
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level. A tree-covered bluff, about 200 feet above sea level,
defines the southern boundary of the Wyckoff Facility OU.
A drainage ditch (known as the perimeter ditch) is located at the
base of the bluff, south of the oil/Creosote Unloading Dock and
the Wyckoff facility. The perimeter ditch collects runoff from
the bluff and discharges it to Eagle Harbor via three underground
culverts.
Numerous structures including buildings, tanks, and sumps, still
exist at the Wyckoff facility. The buildings are not in use and
contain potentially hazardous materials. Some areas of the
facility (e.g., northeast of the shop building and in the
vicinity of the log peeler) have piles of debris that include
metal, wood, .rebar, and concrete. Most of the surface of the
site is soil and gravel.
There are two deep drinking water supply wells, Wells Band C,
located on-site in the facility process area. In addition there
is evidence of four additional water supply wells located on-site
which are no longer in use. Table 1 summarizes the information
known about these wells. Their locations. are shown in Figure 3.
Wells Band C have provided drinking water to the facility and
the Rockaway Beach Community. A replacement source of drinking
water is being developed for the community by the City of .
Bainbridge Island. . The new well for this community, the South
Eagle Harbor Well, has recently been sited and installxd in an
area west of the facility. This new well is expected to be
available for use in late 1994.
I
The wastes resulting from the operations at the facility are
Resource Conservation and Recovery Act (RCRA) listed wastes~ The
use of pentachlorophenol when the facility was in operations
results in an F032 listing. The use of creosote results in an
F034 listing. . Inorganic wood treating preservatives were not
used at this site, so the F035 listing does not apply.
B.
site History and Enforcement Activities
Wood-preserving operations began at the facility in the early
1900s and continued until 1988. Operations over the years
included the use and storage of aromatic oil, creosote, and other.
chemicals; wastewater treatment and discharge; wood preserving;
and storage of treated wood and poles. The Wyckoff facility is
no longer operational; however, some. treated wood still remains
onsite.
The wood-preserving process at the Wyckoff facility primarily
used the organic preservatives, creosote and pentachlorophenol
(PCP). Creosote is a blend of various coal tar distillates that
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Table 1
Well Drilling, Construction, and Hydraull~ Data Summary for Water Supply Wells
At the Wyckoff Facility
Well A WellD WellC WellD Navy Well Unldentlned Well
Welll)escription
Waler Righls No. 061267 (35 gpm) 061270 (10 gpm) 061269 (50 gpm) 061271 (II gpm) 061268 (50 gpm) Unknown
Ecology Regislratlon No. 048846 048843 048844 048842 048845 Unknown
Map Reference Bremerton East Bremerton East Bremerton East Bremerton East Bremerton East Bremerton Easl
Localion SEI/4, NEII4, SEI/4, NEII4, SEII4, NEI/4, SEI/4, NEI/4, SEI/4, NEI/4, SEI/4, NEI/4,
Sec!. 35, T25N, R2E Sec!. 35, T25N, R2E Sec!. 35, T25N, R2E Sec!. 35, T25N, R2E Sec!. 35, T25N, R2E Sec!. 35. T25N. R2E
Easling 1588927.14 1589067.02 1589150.99 1587580 (4) 1588205 (4) 1587103 (4)
Northing 229182.71 229638.21 229676.92 229211 (4) 229026 (4) 229273 (4)
General Description Shallow Well at the RR Artesian well near sump. Artesian well near AKA Well No.2 AKA Well No.5 S. side of Log Dump
Tracks, AKA Well No. I AKA Well No.3 shoreline, Road, W of Log Dump
AKA Well No.4 "A" Frame
Drilling Information
Driller Unknown Unknown N. C. Jannsen Unknown Unknown Unknown
Drilling Melhod Unknown Unknown Unknown Unknown Unknown Unknown
Drill Dale Prior to June 1924 1914 1942 1943 1945 Unknown
Inslallation Dale Prior to June 1924 1914 1942 1943 1945 . Unknown
Ground Surface Elevation (feel) 12.8 Approximately 9.4 (1) Approximately 9.4 (1) Approximately 11.3(2) Approximately 11.3(2) Approximately 11.3(2)
Drill Depth (feel below ground surface[bgs]) 30 500 (7) 813 Unknown Unknown Unknown
Depth 10 Water (feel bgs) Approxlmalely 8 (5) Flowing Flowing Approximalely 6 (5) Unknown Unknown
Well Construction
Tolal Well Deplh (reel bgs) 30 (6) 500 (per R& N. July 12. 813 (per drilling log) 23 (5) Unknown Unknown
1979)
Sump lenglh (feet) Unknown Unknown 13 Unknown Unknown Unknown
Casing Diameler (inches) Unknown Unknown 10 to 8 Unknown Unknown Unknown
CasinglScreen Type Unknown Unknown Welded steel Unknown Unknown Unknown
Siol size (inches) Unknown Unknown ,.. Unknown Unknown Unknown Unknown
Top of Screen (reel bgs) Unknown Unknown 600 Unknown Unknown Unknown
Bottom or Screen (feel hgs) Unknown Unknown 800 Unknown Unknown Unknown
Sand Pack Unknown Unknown Unknown Unknown Unknown Unknown
Top of Sand Pack (feel hgs) Unknown Unknown Unknown Unknown Unknown Unknown
Bottom of Sand Pack (feel bgs) Unknown Unknown Unknown Unknown Unknown Unknown
Bentonite Seal? Unknown Unknown Unknown Unknown Unknown Unknown
Surface Seal Unknown Unknown ... Unknown Unknown Unknown Unknown
Well Use Cooling Water Drinking Waler Drinking Waler Cooling Water Unknown Unknown
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Table 1
Well Drilling, Construction, and Hydraul'c Data Summary for Water Supply Wells
At the Wyckoff Facility
Geolugie Log Available?
No
No
Uydruullc Dutu (3)
Fluw ROle (gallons per minute)
Approximate Specinc Capacity
lIydraulic I'lead (feet)
15
3.78
Unknown
No
Yes
No
Not measured
Not measured
Not measured
No
Noi measured
Not measured
Not measured'
Not measured
Not measured
Not measured
Comments
There is very little
available information
regarding this well.
Water from this well was
used for cooling water in
Ihe wood-treating plant.
6.8
1.5
+ 1.25
53.2
14.3
Flowing (not measured)
There Is very little
available Information
regarding this well.
(I) Based on ground surface elevation measured at POI (CH2M HILL, April 16, 19~2).
(2) Based on ground surface elevation measured at MW22 (CH2M HILL, April 16, 1992).
(3) From a letter to M. WalkerlWyckoff from R & N dated 7/12179 (measurements made on 8/3n3).
(4) Coordinates are estimated based on field bearings and distances recorded by Don Johnson, August 30,1973: approximate error is +1. 50 to 100 feet.
(5) Apparent depth measured by CH2M HILL on 8/23/94. .
(6) Total well dcplh (30) from bottom of current wellhead vault (7 feet below ground surface): tolal well depth Is 37 feet below current ground surface.
NOte: R & N: Robinson and Noble. .
RlJON4
There Is very little
available Information
regarding this well.
This well was re-
developed in October
1979 by R&N and
approx. 100 feet of sand
was removed. R&N
(l0/8n9letter to M.
WalkerlWyckoff) noted
that Ihe well Is also
perforated from 90 10 105
feel bgs, although IIllIe or
no waler comes from this
area.
,...
....
Page 2 of 2
There Is very little
available information
regarding this well.
There Is very little
available Information
regarding this well.
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L- /-- - / <,'> '\ .._~....:.. ...;;.~~.~' WELL A. '
...., ,... \ ROW / .
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ii' ' /j/' WELL 4 '. .. .. . , ".
! i""""'''''''''''''::i ~;.--::~...!/ . WEL~ 2 W~LL 3 . \\ \<-' !
! i .. ,.,1 ":./" "7! WELL 1 \ , \ i
! ! - f':WCUN ,f \ " 1:-:1 \. {
a Wyckoff Water Supply Well
o Bill Point Water Supply Well
... South Eagle Harbor Water Supply Well
Eagle Harbor
"*'-'
f
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NPE69131.0B,02' EPA2RI . 8/27/94' CJS
NOTES: 1. Monitoring and groundwater'extractlon well locations and selected structures based on land survey conducled
by CH2M HILL March 1992, property line and horizontal control monuments based on Farenthold and Assoc, map
(no date), and selected structures and roads based on EPA6.10.63 and 7.30.92 aerial photographs,'
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may contain up to 90 percent polynuclear aromatic hydrocarbons
(PARs) mixed with other hydrocarbons. Technical grade PCP
contains 85 to 95 percent PCP; the remainder is a mix of other
chlorinated phenols and about 0.1 percent dioxins and furans.
The Wyckoff/Eagle Harbor site was proposed to the National
Priorities List (NPL) in September 1985. Under the washington
State Hazardous Waste Cleanup Program, washington Department of
Ecology (Ecology) completed a Preliminary Investigation of
sediment contamination in Eagle Harbor (November 1986). In 1985,
the National Oceanic and Atmospheric Administration (NOAA)
completed a study relating the presence of PARs in sediment to
the'high rate of liver lesions in English Sole from Eagle Harbor.
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. At that time the site
was divided into two OUs, the Wyckoff facility and Eagle Harbor.
A potentially responsible party (PRP) search initiated in 1987
identified the Wyckoff Company as the party potentially liable
for cleanup costs for the facility and the underlying
groundwater.
EPA initiated the RI/FS for Eagle Harbor and used enforcement
authorities to address ongoing releases of contaminatiqn from the
wood-treating facility. EPA enforcement actions at the wood-
treating facility after the site listing on the NPL include the
following:
.
A July 1988 Administrative Order on Consent, 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 syst~m and other
source control measures.
.
A June 1991 Unilateral Administrative Order (UAO) requiring
the Wyckoff Company (renamed and currently known as Pacific
Sound Resources, Inc.) to continue the ERA with
enhancements. The UAO called for increased groundwater
extraction and treatment rates, improved system monitoring,
and removal of sludge stored or buried at the Wyckoff'
Facility OU.
Since 1988, several environmental cleanup activities have been
initiated at the Wyckoff facility as expedited response actions
(ERA) to reduce threats to human health or the environment from
releases or possible releases, of hazardous substances. These
activities have been conducted by both EPA and the Wyckoff
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Company and have included asbestos abatement, removal of all
liquids and sludges from tanks, removal of buried sludges, and
the installation of a groundwater extraction system and a
groundwater treatment plant.
The groundwater treatment system processes groundwater
contaminated with elevated levels of PCP and PAR. The
groundwater is obtained from seven extraction wells located
'within the Wyckoff Groundwater OU that are screened in the water
table aquifer. In addition to recovering groundwater, the'
extraction system recovers both floating and sinking oily
contaminants also known as light and dense non-aqueous phase
liquids (LNAPL and DNAPL). As of June 1994, an estimated 138
million gallons of groundwater had been extracted and treated;
and an estimated 44,000 gallons of NAPL had been recovered.
Treated effluent from the groundwater treatment plant is
discharged via a single outfall in Eagle Harbor.
The treatment plant is designed for a maximum capacity of 150
gallons per minute (gpm). Under normal operations, the plant
operates at approximately 35 gpm. The current limitations are
summarized in Table 2.
EPA assumed responsibility for operation and maintenance of the
groundwater extraction and treatment systems on November 12,
1993, because the company was financially unable to do so.
operations were continued under EPA's remedial program. At that
time, the groundwater extraction and treatment systems(were I
evaluated and found to be in an extremely deteriorated condition.
The poor condition of the extraction' system was primarily due to
severe corrosion on the pipes and valves. The treatment system
was in poor operating condition for numerous reasons, including
sludge and product accumulation in the roughing tank and
oil/water separators. EPA's efforts to correct these problems to
date have included: evaluating options for replacement piping,
beginning to clean the product and debris from the process units
of the treatment system, and establishing a regular inspection
and maintenance program.
Pacific Sound Resources, Inc., and their principals have settled
their CERCLA liability with EPA and the federal and tribal
natural resource trustees in a consent decree entered in Federal
District Court in Seattle on August 29, 1994. Under the
settlement, after payment of debts, all of PSR's liquidated
assets will be held in an environmental trust, which will pay for
a portion of the environmental clean up activities.
The ongoing RI/FS for the Wyckoff Facility OU was initiated in
September 1992 and should be completed in December 1995. A
focused RI/FS on the Wyckoff Groundwater OU, the basis for this
Interim ROD, was initiated in May 1994 and completed in July
1994. The RIfFS for the Wyckoff Facility OU will also serve as
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Table 2
Summary of Current Effluent Limitations and Monitoring Requirements (a)
CHEMICAL MONITORING
Discha e Limitation Monitorin Re uirements
Daily Monthly
Maximum Average Measurement
Effiuent Cbamcteristic (u (u ) Re rtee! Value(s)
Total of 16 Polynuclear Aromatic
Hydrocarbons (PAHs) 20 Once per week 24-hour composite (c) Maximum daily
Individual PAHs (b)
Naphthalene 4 Once per week 24-hour composite Maximum daily
Acenaphthylene 4 Once per week 24-bour composite Maximum daily
Acenaphthene 4 Once per week 24-hour composite Maximum daily
fluorene 2 Once per week 24-hour composite Maximum daily
Phenanthrene 2 Once per week 24-hour composite Maximum dailY
. Anthracene 2 Once per week 24-hour composite Maximum daily
fluoranthene 2 Once per week 24-hour composite Maximum daily
Pyrene 2 Once per week 24-hour composite Maximum daily
Benzo( a)anthracene 2 Once per week 24-hour composite Maximum daily
Chrysene 2 Once per week 24-hour composite Maximum daily
Benzo(b)fluoranthene 2 Once per week 24-hour composite Maximum daily
Benzo(Ic.)fluoranthene 2 Once per week 24-hour compOsite Maximum daily
Benzo(a)pyrene 2 Once per week 24-hour composite Maximum daily
Dibenzo(a,h)anthracene 2 Once per week 24-hour composite Maximum daily
Benzo(g,h.i)perylene 2 Once per week 24-hour composite Maximum daily
Indeno(l.2.3
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I.
D.
Current Biomonitoring Requirements
Acute Toxicity Test Requirements:
1.
For each lest period (see also Paragraph 1.8 below), aane survival toxicity tests are required for ln1and Silversides (Mmidi4
beryUina).
2.
The lest prococ:ol is adapted from C.!. Weber, et ai, Methodsfor Measuring the Acute Toxicity of E/JWents to Freshwater
and Marine Organisms. EPA/600/4-90/027,1991.
3.
All quality assurance criteria used are in accordance with Methodr for Measuring the Acute Toxicity of Effluents to
Freshwater and Marine Organisms. EPA/600/4-901027. Test results which are not valid (e.g., control mortality exceeds
acceptable level) will not be accepted and must be repeated.
4.
The lest is performed with a series of dilutions (100. 50, 25, 12.5, and 6.25 percent effluent) plus a control (0 percent
effluent) to determioe (1) the LC,o. and (2) any statistically significant differences between the results for the control and
each effluent concentration tested.
5.
If the lest demoDStra1eS the presence of acute toxicity, EPA will undertake the fol1owmg actions as needed to determine the
source of toxicity:
(a)
Chemial aoa1yses.
(b)
Evaluation of treatment processes and chemials used.
(c)
Physial iospection of facility for proper opetaIioo of trea1meot uoits, spills, etc.
(d)
&..min3QOn of records.
(e)
Ioterviews with plant persoooel to determine if toxicant releases occum:d through spills, unusual operating
cooditions, etc.
If any toxicity remains after conducting the above steps, additiooal monitoring or treatment may I6c required.
I
6.
A written report of the toxicity lest results and any reWed source investigation are prepared for EPA withio 60 days after
the initial sampling. The report of the toxicity lest resuhs and chemial aoa1yses shall be prepared in accordance with the
Reportiog Sedions in the documents specified above in Sec:tioo 1-3.
7.
Chemial testiog for the parameters for which effiueot limitatioos exist sha11 be performed on a split of each sample
collected for bioassay testing. To the extent that the timing of sample co1kction coincides with that of the sampling
required for the effiuent limitations, aoa1ysis of the split sample will fu1fi11 the requirements of that monitoring as well.
8.
Testing shall be conducted every three'months (41imcs per year), uotil EPA modifies this requirement in writing.
Additiooal toxicity testing is also required at any time that spills or other unusual events resuh in different or substantially
increased discharge of pollutants.
Chronic Toxicity Test Requirements:
1.
For each lest period (see also Paragraph D.ll below), chronic toxicity tests are required for the following organisms:
(a)
SrronglyocenlrotUS putpurarus (purple sea urdtio), or Dordraster excenlricus (saud dollar).
(b)
Mytibu edulis (mussel) or Crassostrea gigas (pacific oyster) larvae.
The purple sea urchin aDd saDd dol1ar, aDd the mussel and Pacific oyster may be used interchaogeably if necessary.
2.
In each year, the bioassay tests shall be conducted four limes with each organism during the organism's nattJral spawning
period. To the extent that these seasons overlap, testing shall be conducted on splits of the same effluent samples. Any
tests which fail the criteria for control mortality as specified in the respective protocols shall be repeated on a freshly
collected sample.
3.
Testing is conducted on 24-hour composite samples of effluent. Each composite sample col1ected shal1 be large enough to
-------
4.
The chronic toxicity tests are performed as follows:
(a) For the purple sea urchinlsand dollar, tests are performed on a series of dilutions, plus a control (0 percent effluent).
The IC25 value. (the incipient concentration of effluent causing a 2S percent reduction in biological measurement, e.g.,
fertilization, is calculated. EPA has indicated that the I~ is the approximate analogue to the no observable effect
concentration (NOEC) of the effluent in the control water. The NOEC is that concentration of effluent for which survival,
reproduction, or growth of the teSt organisms is not significantly different (at the 95% confidence level) from that of the
control organisms (see Technical Support Documentfor Waler Quality-based Toxics Control. EPAl50512-9~I, March
1991). .
(b) For the mussel or Pacific oyster larvae, tests are performed on a series of dilutions, plus a control (0 percent effluent).
The NOEC, LOEC Oowest observable effect concentration), and the EC50ILC50 (effective concentration [Ee) at which 50
percent of the population shows sublethal effects such as reduction in growth and lethal concentration [LC] at which 50
percent of the population dies, respectively), are calculated.
s.
The chronic bioassays are conducted in accordance with the following protocols:
(a)
For purple sea urchinlsand dollar: Short-tenn Methodsfor Estimating the Chronic Toxicily of EjJlIlents and
Receiving Walen to Marine and EstUarine Organisms, EP AI600I4-871028 and The Environmental Monitoring
and Suppon Laboratory, Cincinnati, OH, 1988.
(b)
For mussel1Pacific oyster larvae: Standard GuUk for Conducting Slatic Acute Toxicily Tests Storting wUh
Embryos of Saltwater Bivalve Molluscs. ASTM E 724-89.
6.
All quality assurance criteria used shall be in accordance with Methods for Measuring the Acute Toxicity of Effluents to
Freshwater and Mari1Je Organisms, EPAl600I4-85-013, Quality Assurance Guidelines for Biological Testing, EPAl600I4-
78-043, and for oysterlmussel larvae test, Standard Guide for Conducting Slatic Acute To:dcily Tests Storting wUh Embryos
of Saltwater Bivalve Molluscs. ASTM E 724-89. The control water shall be high q~ty natural seaWater. No exceptions
will be made for artificial sea salts or concentrated brine unless Wyckoff submits data to EPA which demonstra1es that the
lab has reliably conducted the specified test with one of these media.
7.
The results of the bioassay tests are provided to EP A within 45 days after completion of each test in accordance with the
Reponing Section in Short Tenn Methods for Estimating Chronic Toxicily EjJlMents and Receiving Waler to Marine aruj
EstUarine Organisms, EPAl600I4-871028, May 1988, and include any other information required't,y the protocols.
8.
EP A and Ecology will evaluate the results to determine whether they indicate the occum:nce of chronic toxicity outside the
mixing zone. If it appears that this may be oc:curring, a toxicity evaluation and reduction plan will be prepared within 90
days. The evaluation portion of the plan may include additional toxicity testing if needed to follow up on initial results or
gather information for a possible toxicity limit in the future.
9.
If the sea urchinIsand dollar or musseVoyster larvae tests prove inadequate for evaluating Wyckoff's effluent, EPA may.
substitute alternative tests which will provide the required toxicity information.
10.
Chemical testing for the parameters for which effluent limiWions exist shall be performed on a split of each sample
collected for bioassay testing . To the extent that the timing of sample collection coincides with that of the sampling
required for the effluent limitations, analysis of split sample will fulfill the requirements of that monitoring as well.
11.
After one year, EPA may reduce the monitoring requirements to once per year, using the more sensitive species. All
-------
the final RI/FS for the Wyckoff Groundwater OU. This
consolidated ROD for the Wyckoff Facility and Wyckoff Groundwater
OUts should be completed by July 1996.
c.
Highlights of community Participation
section 113(k) (2) (B) and Section 117 of CERCLA set forth the
minimum requirements for public participation at sites listed on
the NPL. The EPA has met these requirements and maintained an
active community relations program at the site.
A community relations plan for the wyckoff/Eagle 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 clip out portion of the notice. CUrrently, the mailing
list comprises over 670 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 local Eagle Harbor Task.
Force, which included local community groups and was active from
1985 to 1987. In 1988, public notice of the availability of
funds for a technical assistance grant (TAG) was published, and
the Association of Bainbridge Communities (ABC) applied for and
received the grant. The group's volunteer technical advisory I
committee and a consultant hired with the grant monies'have been
active in EPA'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 quarterly. The community relations plan was
revised in late 1990 to reflect the existence of the TAG.
Throughout the Focused RI/FS for the Wyckoff Groundwater OU, key
documents were kept at the Bainbridge Island branch of the Kitsap
County Regional Library for public review. The West Harbor.
Operable Unit Administrative Record. file was placed in the
library in July, 1991. The Groundwater Operable Unit
Administrative Record file was placed in the library in August
1994. The Wyckoff Facility Operable unit Administrative Record
file was placed in the library in September 1994. All of the
Administrative Record files are updated regularly. .
The Focused RI/FS report for the Groundwater Operable unit was
released to the public for review in July, 1994. In July, 1994
the Proposed Plan for the Groundwater Operable unit was added to
the information repository, and copies of the Proposed Plan were
sent to citizens on the site mailing list. A thirty-day public
comment period began on July 27, 1991. EPA held a public meeting
-------
on August 10, 1994, to provide information and answer community
questions. Approximately 15 people were present.
Three letters commenting on the proposed plan were submitted to
. EPA, and six citizens provided comments at the August meeting.
The Responsiveness Summary (page 47) outlines and responds to the
concerns voiced by the community in these forums.
The interim remedy selected in this
accordance with CERCLA, as amended,
decision is based on information in
the site.
ROD was selected in
and with the NCP. The
the Administrative Record for
D.
scope and Role of Operable unit Within the site strategy
Different environmental media,. sources of contamination, public
accessibility, enforcement strategies, and environmental risks in
different areas of the Wyckoff/Eagle Harbor sit~ led to the
division of the Wyckoff/Eagle Harbor site into operable units.
As stated above, the current division of the site is as follows:
.
OU 1: East Harbor OU (subtidal/intertidal sediments)
.
OU 2: Wyckoff OU (surface structures, soils)
+
OU 3: West Harbor OU (subtidal/intertidal sediments,
and upland sources)
au 4: Wyckoff Groundwater au (the saturated'area
located under the Wyckoff facility and extending
towards Eagle Harbo~)
I
.
This interim ROD for the Wyckoff Groundwater OU is limited in
scope and addresses only the actions necessary to contain
contaminated groundwater to the site and reduce the movement of
contaminants offsite into Eagle Harbor and puget Sound. . These
actions will be reviewed and incorporated into the final operable
unit ROD. .
Efforts to control contaminant movement, through the use of a
groundwater extraction system and treatment plant, are a primary
focus of this interim ROD. Other activities associated with the
Groundwater OU have also been incorporated at this time,
including, (1) consideration of source control barriers in
addition to the existing extraction wells and, (2) abandonment of
water supply wells that are at risk of failure and could act as
conduits for migration of contaminants to deeper aquifers.
These interim actions will be consistent with any future actions,
to the extent practicable.
-------
E.
summary of site Characteristics
Conceptual Model
A conceptual model of the groundwater aquifers beneath the
Wyckoff facility are shown in Figure 4, including:
.
.
.
.
Unsaturated zone,
Unconfined Water Table Aquifer,
Hard Clay Semiconfining Unit,
Semiconfined Aquifer.
The unsaturated zone immediately below the surface of the site is
part of the Wyckoff Facility OU. This unsaturated unit is five
to ten feet thick and consists of fill and native materials
composed of discontinuous silt and fine sand layers.
The unconfined water table aquifer, underlying the unsaturated
zone, is composed of fill and native materials from 10 to 20 feet
in depth, overlying coarse-grained alluvium composed of
interbedded sand, gravel, and clay of various thicknesses. This
alluvial layer extends down another 5 to 50 feet below ground
surface. The depth to water is strongly influenced by the tides.
The maximum elevation of the liquid surface within this aquifer
defines the upper boundary to the Wyckoff Groundwater Operable
Unit.
Separating the water table aquifer from a lower semi-confined
aquifer is a relatively impermeable hard clay layer, wftich is
interpreted to underlie much of the Wyckoff facility. The top of
the hard clay layer extends from less than 10 feet below ground
surface in the south central part of the site to approximately
50, feet deep along the northern portion of the site. This hard
clay layer ranges from 10 to 35 feet thick at the four soil
borings that have penetrated the clay. '
Underlying the hard clay layer is a semiconfined aquifer which
consists of gravelly silty sand, clayey sand, gravelly sand~ and
sandy gravel. The lower boundary of this aquifer has not been
determined. Limited data from deeper well logs at the site
indicate that there are at least two additional clay layers that
may act as confining units between this semiconfined aquifer and
even deeper aquifers.
I
The drinking water wells located on-site (wells B and C) are
screened at approximately -500' mean sea level (msl) and -800'
msl in the deeper water bearing units. Both wells Band Care
under artesian pressure and generate flow to the surface at
10 gpm and 50 gpm, respectively. Four off-site drinking water
wells serving Bill Point, a local residential community, and are
located approximately 1500' to the south of well C and are
approximately -20' msl. There is some question as to which of
-------
Figure 4
WYCKOFF GROUNDWATER
OU CONTAMINATION
Elevation
(lee I-mean 0
sea level)
N~69IJ 100.011 P602/ ~-1...4/ el'
(South)
(North)
... ....~
Worker Residential Area
Former Process Area
Offshore Area
Adjacent to Wyckoff
Facility OU Boundary
'"
AWfOJIUr.l.
Low Tido
20
EAGLE HARBOR
-- ....
--It;.
-"
-"
. -"
Q --
roon~B'e, Fb ..... ~
~"dlon
AWfOXiffMte
High T/do
211
WYCKOFF GROUNDWATER OU
LEGEND
'"
-~--
ApproJ:ilN18 unc:onfiNd
groundwater .I..,.tion
r:a
Hard (.I.y t8Y8'
.0
- - - -.. --- ApproxirN'e c:onl.et location
::::::::::::::::::::::::~;;::::m::~
.:.:.:.:.:.:.:.:.:.:.:.:.:.:.:.:.:.:.:.:.:.
Oiuolved Ph... Cont.minant
,...
on
l!IilliIIl!I i II!
~
tigh1 Non A_ouo Pho.. UcrJd IlNAPl)
0.... Non A_QUO Pho.. UcrJd 10NAPlI
S~
~N
HORIZONTAL SCALE (FEET)
Lower AquKer
1111
~
Note: Scale is approximate.
"
50
o 25 50
Waler supply wells lor Rockaway
Beach completed 500 10 800 leet
-------
- the aquifers the Bill Point wells are screened in.
Groundwater flow beneath the Wyckoff site is affected by both
tidal fluctuations in puget Sound and the groundwater extraction
system which operates 24 hours a day at the site. Prior to
groundwater extraction system pumping, groundwater in the
unconfined water-bearing unit was observed to flow to the north
where it discharged along most of the northern and eastern
portions of the -site. Groundwater discharge was especially
evident at low tide in the form of intertidal seeps. During
extraction system pumping, water level measurements indicate that
groundwater converges inward, toward the extraction wells, and
that the capture zone is maintained over much of the site during
bo~h high and low tides. - --
.~
Nature & Extent of Contamination- -
Groundwater
Figure 4 graphically illustrates the conceptual site model for
the movement of contaminants- at the Wyckoff Facility and
Groundwater Operable units. It illustrates how contaminants
introduced at the surface are thought to be moving into the lower
aquifers and Eagle Harbor. Further information on the nature and
extent of contamination will be developed as part of the Facility
RIfFS and this interim remedial action.
TBe groundwater in the water table aquifer underlying ~he Wyckoff
facility is known to be contaminated from former wood treating
operations. The contaminants are dissolved in the groundwater
and are present as free~phase oily liquids known as non-aqueous
phase liquids (NAPL). Light non-aqueous phase liquid (LNAPL) is
found floating on the unconfined groundwater table surface.
Dense non-aqueous phase liquid (DNAPL) appears to be pooling on
the semiconfining clay layer.
The NAPL is essentially pure product, containing
pentachlorophenol and the constituents of creosote, which are
primarily polynuclear aromatic hydrocarbons (PARs). The primary
contaminants in the groundwater are PARs and substituted phenols.
Acenaphthene and naphthalene were detected in over 85 percent of
the groundwater samples collected at the site. Pentachlorophenol
was detected in 33 percent of the samples. Table 3 summarizes
the groundwater analytical data.
Offshore Area Adjacent to Wyckoff Facility OU Boundary
There continue to be observable seeps of pure product, in the
form of DNAPL and LNAPL, in the intertidal zone to the north and
east of the-facility. The seeps have contributed to
contamination of the sediment and shellfish in the East Harbor
OU. Figure 5 shows the distribution of total PAR (TPAH)
-------
. Tobie 3
Sum'mory of Detected Annlytlcol Results and Comparlslbn to MCLs for Groundwater In the Water Table Aquifer
-------
Table 3
Summary of Detected Analytical Results and Comparlsldn to MCLs for Groundwater In the Water Table Aquifer
Nondcteel.. Deted.. Federal Prima Federal Seconda MCL a
Number Number Frequeney Count of Count of
of of of Detects > Nondetects >
Parameter Deteets Sam les Detection Minimum Maximum Minimum Maximum Value Value Value Value
VOilltUe Or .
Acelone 4 23 17% 10 72 30 430
Benzene 5 23 22% 5 250 2 53 5 3 18
Carbon DisuUide I 23 4% 5 250 1 1
Chlorobenzene I 23 4% 5 100 250 250 100 2
Ethyl benzene 13 23 57% 5 5 2 560 700
Methylene Chloride 3 23 13% 5 100 3 180 5 2 20
Slyrene 7 23 30% 5 250 13 310
Toluene II 23 48% 5 5 1 800 1000
Xylene (Tolal) II 23 48% 5 5 17 2300 10000
Aluminum I 21 5% 70 70 7610 7610
Arsenic 9 21 43% 10 10 11.1 82 50 2
Barium II 21 52% 16 16 11 96 2000
Cadmium 5 21 24% 3 3 3 41 5 2
Chromium 4 21 19% 7 7 II 26
Copper 3 21 14% 15 15 18 44 1300 1000
Iron 15 21 71% 65 65 51.25 14400
lead II 21 52% 5 5 7.05 63 15 8
Magnesium 21 21 100% 4430 6222000
Manganese 21 21 100% 4 1780
Mercury I 21 5% 0.2 0.2 0.8 0.8 2
Nickel 3 21 14% 25 25 26 430 100
POiasslum 21 21 100% 1410 259000
Sliver 4 21 19% 8 9 13 100
Sodium 21 21 100% 14300 8650000
Vanadium 4 21 19% 14 14 21.5 56
Zinc 20 21 95% 12 12 18 82 5000
,..
.Polynuclear Aromatic Compounds (PAHs)
(a) Federal Maximum Conlamlnanllevel (MCL) [40 CFR 141), Federal Secondary Maximum Conlamlnanllevel (SMCL) [40 CFR 143); blank values Indicate thai there are no slandards (or these chemicals.
Nole Ihal field duplicale resulls were averaged such thai a single estimator was Intergrated Inl.o the database (or each location sampled al a specific time. The estlmalor was Identlfed as a nondelecllf both resu\(s were nagged
wilh any combination of qualifiers Including "U". All other combinations were fiagged as delecls.
"
8/30/94
Page 20r2
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NPE69131.08.02' EPAIRO' 8/27/94' CJS
WINSLOW
o
o
150
300
600 Meters
LEGEND
. >1 ,000,000 ~g/kg
. > 1 00,000 ~gIkg
. >10,000 ~glkg
" > 1 ,000 ~g/kg
o >100 ~gIkg
'; <100 ~gIkg
'-- 6---.. Approximate depth In meters MLLW
\.
~
Scale in Meters
NOTE: For clarity, subtidal station numbers have been shortened
by eliminating the hyphen (e.g., EHOB rather than EH-OB). The
three-digit subtidal station numbers are shown without the EH-
(e.g., 714 Instead 01 EH-714). EH stations (e.g., EH.OB) were
sampled In the PI. Numerical stations (e.g., 714) were sampled
in the AI.
SOUACE: EPA, November 19B9.
"
Figure 5
CONCENTRATIONS OF TPAH
AT STATIONS SAMPLED DURING
-------
concentrations found in the harbor. Visual monitoring of the
seeps indicates that the partial containment that has been in
effect since startup of the groundwater extraction system and
groundwater treatment plant, combined with the removal of buried
sludges, tank bottoms, and other source material has
significantly reduced the amount of oily seepage.
F.
summary of site Risks
EPA has determined that existing human health and environmental
risks warrant control of contamination sources and cleanup of
.harbor sediments (Record of Decision, West Harbor Operable Unit,
Wyckoff/Eagle Harbor Site, September, 1992, and Record of
Decision, East Harbor Operable unit, Wyckoff/Eagle Harbor site,
September, 1994). The risk assessments for Eagle Harbor and the
Groundwater Operable Units are briefly summarized here. Although
this interim ROD identifies interim actions for the Groundwater
Operable bnit only, it is important to include a discussion of
the Eagle Harbor risks, as groundwater and NAPL from the facility
provides a significant source of contamination to the harbor. .
This discussion of the Eagle Harbor risks will focus on the risks
resulting from ~AHs.
-
Eaqle Harbor Risk Characterization
To assess potential human cancer and non-cancer health risks, EPA
used measurements of Eagle Harbor sediments and ~eafood and I
assumed exposure to contaminants from eating contaminated fish,
shellfish, and sediments, and from skin contact with contaminated
beach sediments. The primary human health risk was posed by
long-term, regular consumption of PAH-contaminated crabs, clams,
or other shellfish from Eagle Harbor. The data indicates that
consumption of shellfish from areas of the East Harbor, near
Wyckoff results in cancer risks in the 10-3 range.
Biological risks due to contamination in the East Harbor are
evidenced by documented acute toxicity of sediments near the
former wood treating facility, by the predicted toxicity of other
sediments above apparent effects thresholds, and by the presence
of PAHs, which can accumulate in the tissues of food chain
organisms.
'Since 1985, the Bremerton-Kitsap County Health District has
maintained a public health advisory cautioning against
consumption of fish and shellfish from Eagle Harbor due to both
chemical and bacterial contamination. Warning signs are posted
a~ound the harbor, and the Healt~ District provides a telephone
hotline recording confirming. the advisory.
-------
Although a clean sediment cap has already been' placed over the
most heavily-contaminated areas of the East Harbor, the
contamination in remaining areas of the East Harbor is at a level
anticipated to pose a continued risk to marine organisms and to
people who may eat shellfish from beaches adjacent to the Wyckoff
Facility.
Wyckoff Groundwater
EPA also evaluated the potential human health risks from drinking
contaminated groundwater present at the Wyckoff facility. The
results of these assessments indicated that regular consumption
of contaminated groundwater from the shallow water table aquifer
beneath the Wyckoff facility over a long period of time poses
cancer risks to those exposed. Assuming residential use of the
shallow water t~ble aquifer for 30 years, the cancer risk as a
result of groundwater ingestion is estimated to be in the 10~
range, primarily from ingestion of PARs. At this time, no one is
currently drinking this water.'
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the responseactiori
selected in this ROD, may present an imminent and substantial'
endangerment to public health, welfare, or the environment.
G.
. Remedial Action objectives
,
The purpose of this interim action is to ensure contai~ment of
contaminated groundwater and to protect human health and the
environment. One objective of the interim action shall be to
prevent contaminated groundwater and NAPL from moving offsite
into the harbor. The second objective shall be to prevent
contaminants from reaching deeper aquifers via onsite drinking
water wells and other onsite water supply wells. Because this is
an interim action, groundwater cleanup standards will not apply
at this time. The cleanup standards will be determined in the
final Groundwater Operable unit ROD.
The primary role of the groundwater extraction system and
treatment plant has been to create a hydraulic barrier, reducing
the offsite flow of contaminated groundwater and LNAPL. Pumping
the groundwater via the extraction wells creates a cone of
depression which causes the LNAPL to flow towards the well,
rather than out to the harbor. During the process, groundwater
is removed from the aquifer and is treated to meet effluent
limitations prior to being discharged into the harbor. EPA
anticipates that a treatment plant in conjunction with a
groundwater extraction system will be necessary for at least 20
years. The existing treatment plant has reduced the flow of
contaminants in groundwater and NAPL offsite. However,
-------
significant NAPL seepage and groundwater flow offsite still
exists.
All alternatives are interim measures, designed to be consistent
with the final cleanup action addressed by the overall Remedial
Investigation, Feasibility study, and final Record of Decision
for the Wyckoff Groundwater OU. "Applicable or relevant and
appropriate requirements" (ARARs) relating to the discharge of
treated water or other wastes generated from the operation of the
groundwater extraction and treatment systems shall still apply as
the interim action is implemented. Final ARAR-compliant actions
will be addressed in the final ROD. .
The effluent discharge from the site as a result of operations
from the groundwater extraction system and treatment plant shall
comply with substantive requirements of an NPDES permit. Air
emissions as a result of operations from the groundwater
treatment plant shall comply with substantive requirements of a
puget Sound Air Pollution Control Agency permit. Abandonment of
the water supply wells on site shall comply with the substantive
requirements of the Washington Water Well Construction Act.
H.
Description of Alternatives
Four categories of interim actions were studied:
1)
2)
Groundwater treatment plant,
I
,
Groundwater extraction system/hydraulic barrier,
. 3)
Installation of physical barriers to inhibit movement
of NAPL off site, and
4)
Abandonment of drinking water and other water supply
wells.
For each of these categories, several alternatives were
identified. Overall, the alternatives fall into two categories:
1) No Action or minimal action to maintain the status quo; and 2)
Major Action for the purpose of containing contaminated. .
groundwater on the site. The schedule of actions associated with
each alternative is identified in Table 5.
1) The Groundwater Treatment Plant
The current groundwater treatment plant utilizes the following
processes:
.
Primary treatment of extracted groundwater using physi~al
processes to remove solids and ?il and grease,
-------
.
Secondary treatment using biological processes to reduce the
concentration of organic compounds,. and
.
Tertiary treatment using physical and chemical processes to
remove residual solids and organic compounds before effluent
discharge to puget Sound. .
The effluent of the plant currently meets the discharge
requirements established in 1990 (see Table 2). However, the
plant is in a very deteriorated condition and requires extensive
maintenance to address chronic equipment failure. ..There is
. extensive corrosion of the carbon steel piping and tanks.
Reliable plant operation is also confounded by poor design and
installation. There is no bypass piping around individual units.
Much of the piping is undersized. Some of the process equipment
is improperly installed. -
Alternative la:
No Action
Alternatives 1a and 2a are linked. Under "no action," both the
treatment plant and the groundwater extraction system would be
abandoned, and treatment of contaminated groundwater would cease.
This action has zero capital or operations and maintenance costs.
However, this alternative is not protective of the- human health
or the environment. Abandonment of the treatment plant would.
lead to increased flows of LNAPL and contaminated groundwater
into Eagle Harbor.
,
,
Alternative lb: Maintain Existing Treatment Plant operations,
Including Minor Repairs.
Under this alternative,EPA would attempt to keep the existing
groundwater treatment plant operational retaining existing unit
processes and repairing/replacing components and devices as -
necessary. However, within the next one to two years, it is
expected that the plant condition will have disintegrated to such
a degree that safe and successful operation of the plant will no
longer be possible. While the treatment plant continues to
operate, treatment of contaminated groundwater would continue.
This alternative has zero capital costs. The operations and
maintenance costs would be approximately $1.2 million per year.
When th~ current plant does break down to the point where it is
~o longer operable (estimated to be within the next two years),
EPA would be faced with alternatives 1a or 1c and their
associated costs.
Alternative No. lc:
Repair or Replace Existing Treatment Plant.
Under this alternative EPA would operate the existing treatment
plant and conduct repairs as necessary for the short term.
During the short term EPA would evaluate the effectiveness of a
-------
new treatment plant and whether repair or replacement of the
existing plant would be appropriate over the long term.
Replacement of the existing plant would involve design,
construction, and operation of a new plant and subsequent
demolition of the old plant. Groundwater extraction would
continued throughout this transition, using the existing plant.
EPA has completed this analysis subsequent to the proposed plan
release and has determined for Alternative 1c, that construction
of a new treatment plant would be more effective than repair of
the existing plant. Most of the physical problems of the
existing plant can be repaired but long term reliability will
still be questionable. The lifespan of a repaired plant would be
uncertain,. with 20 years as a probable maximum. The current
plant has a maximum flow capacity which cannot be expanded.
Even with a decision to build a new plant, it will be necessary
to keep the current plant operating until the new plant is up and.
running. To keep the .current plant operating successfully during
the interim would require some major repairs, including a
complete replacement of the piping, corrosion protection of all
of the tanks, and a thorough overhaul of the plant's primary
system.
The existing plant currently operates at 30 gpm with a maximum
flow rate of 150 gpm. with the potential for many more
extractions wells a new treatment plant will need a significantly
greater design flow. It will still utilize primary, s~condary, ,
and tertiary process units to treat the groundwater prior to
release into the harbor. .
A 30 year estimate (+50%,' -30%) of costs for this alternative
with a 5% discount rate is $23.8 million.
2)
The Groundwater Extraction system/Hydraulic Barrier
The current groundwater extraction system consists of seven
extraction wells. The total depth of each extraction well is 38-
feet below ground surface (bgs). Each well contains a 30-foot
screened interval with a three foot sump. Groundwater and NAPL
are extracted from each well using two separate sets of pumps.
The water pumped from each extraction well is combined in a
manifold system which is then directed to the treatment plant.
The NAPL recovered from the extraction wells is placed in drums
next to the well head. It is later pumped into a tank on the
treatment plant pad where it is stored until it is taken off site
for disposal. .
There is severe corrosion of the pumps and all along the carbon
steel piping leading from the extraction pumps. The valve
manifold where the extraction piping comes together is
extensively corroded.
-------
The hydraulic barrier created by pumping the seven existing wells
in their current locations has not been sufficient to halt flow
of contaminated groundwater and NAPL offsite.
Alternative.2a:
No Action
Alternatives la and 2a are linked. Under IInoaction,lI both the
treatment plant and the groundwater extraction system would be
abandoned; and treatment of contaminated groundwater would cease.
This action has zero capital or operations and maintenance costs.
This alternative is not protective of human health or the
environment. Abandonment of the extraction system would lead to
increased flows of LNAPL and contaminated groundwater into Eagle
Harbor.
Alternative 2b: Maintain Existing Extraction system/Hydraulic
Barrier operations.
Under this alternative, extraction of contaminated groundwater
would continue using existing wells at the current low rates of
efficiency. Limited maintenance would be conducted as necessary.
Visual monitoring of the seeps would be continued. There would
be no capital costs. Ongoing operations and maintenance costs
would be.approximately $57,000 annually.
Alternative 2c: Evaluate, Maintain, and Upgrade Existing
Extraction system/Hydraulic Barrier operations
I
(
Under this alternative, EPA would develop a quantitative
monitoring and modeling approach to evaluate how successful the
hydraulic barrier is and could be at reducing the contamination
seeping onto adjacent beaches and into the harbor.
This system evaluation would include but is not limited to the
following elements:
.
Develop quantitative measures of NAPL flow offsite,
.
Evaluate feasibility and effectiveness of differing pump
rates,
.
Determine optimum depth and screened interval of extraction
wells to improve efficiency of hydraulic barrier,
.
Determine optimum depth and screened interval of extraction
wells to improve efficiency of DNAPL and LNAPL recovery,
Eevaluate various NAPL pump/recovery schedules to optimize
DNAPL and LNAPL recovery, and
.
.
Evaluate optimum locations for additional extraction wells.
-------
If the results of this system evaluation indicates that new
extraction wells could significantly decrease the amount of
contamination entering the harbor, new wells would be .
constructed. This alternative would also allow for existing
wells to be abandoned and replaced if they are operating poorly.
Expanding the extraction system includes a number of elements
including but not limited to:
.
Design of wells,
.
Drilling and actual construction of the wells,
Installation of a pump for the extraction of groundwater,
.
.
Installation of piping to transport the groundwater to the
treatment plant,
.
Installation of a separate pump and piping to recover NAPL
from the wells, and
.
Increased O&M costs due to the increase in the number of
pumps and the number of locations which require NAPL
recovery.
The initial monitoring and evaluation of the extraction system
and the hydraulic barrier. it creates would cost approximately
$50,000. Depending on the number of new w~lls needed ~nd their I
design, expansion of the extraction system could cost up to
$42,000 per well. EPA would not put all of the wells in at one
time. It would be an iterative process to determine the optimum
placement and design. Depending on the degree of system
expansion, operations and maintenance of the extraction system
could cost up to $11,340. per year. Thorough evaluation of the
extraction system and the hydraulic barrier would begin.
immediately after the ROD is signed. It is possible that new
extraction wells could be on-line by late 1995.
Assuming installation of 24 wells for cost comparison purposes, a
30 year estimate (+50%, -30%) of costs for this alternative, with
a 5% discount rate is $1.3 million.
3)
Installation of Physical Barriers to NAPL Movement Off site
A constructed barrier or wall would serve two purposes. One
would be to physically prevent the movement of LNAPL and DNAPL
offsite. The other would to limit the amount of water needed to
be pumped to establish the hydraulic barrier. This would reduce
the amount of uncontaminated saltwater which would need to be
treated.
-------
EPA installed a 300-foot sheet pile barrier along the north side
of the transfer pit to prevent the movement of LNAPL offsite into
.the harbor while sludges were being 'removed from transfer pit.
Its location was determined by the need to control NAPL movement
during and after the removal action. This barrier is not tied'
into the clays underlying the site. It was not designed and
constructed to work with the hydraulic barrier created by the
groundwater extraction system nor to optimize the containment of
the contaminated groundwater and NAPL onsite. There, are no other
barriers onsite designed to contain the movement of the
contaminated groundwater and NAPL.
Alternative 3a:
No Action
This alternative suggests that no measures be taken in addition
to the extraction/treatment system for the containment of
contaminated groundwater. There are no capital or operations and
maintenance costs associated with this alternative.
Alternative 3b: Evaluate Performance of Current Extraction
System/Install Barriers.
If the groundwater extraction system/hydraulic barrier evaluation
(discussed under alternative 2c) indicates that the hydraulic
barrier is insufficient and inefficient at preventing
contaminants from moving into the harbor and the presence of a
physical barrier would significantly enhance the effective and
efficient containment of contaminated groundwater, a b~rrier wall
would be installed along the north and east shores of ~he Wyckoff
site. '
-
I -
At this time it is anticipated that such a barrier would either
be a slurry wall or sheet pile. A barrier designed to control
the movement of LNAPL would extend approximately 30 feet below
ground surface. To control the movement of DNAPL the barrier
would have to be anchored into the underlying clays,
approximately 70 feet below ground surface. A thorough
evaluation of the possible construction materials would need to
account for the chemical corrosive properties of both the
contaminants present and the saltwater environment and the depth
of the barrier. .
The 30 year estimate (+50%, -30%) of costs with a 5% discount
range from approximately $179 thousand to $1.0 million for a
slurry wall or sheet pile going 30 feet deep and from
approximately $746 thousand to $2.5 million for a slurry wall or
sheet pile going 70-feet deep.
It shoUld. be noted that this option would only be considered
after a thorough evaluation of the extraction system has been
conducted (alternative 2c). If it is determined that the
-------
extraction system is effectively containing contaminated
groundwater, a barrier wall would not be constructed.
4)
Seal and Abandon Drinking Water And other Water Supply Wells
The two deep drinking water supply wells located on-site, Wells B
and C, are located in the facility process area. In addition
there is evidence of 4 additional water supply wells located on-
site. Table 1, summarizes the information known about these
wells. Their locations are shown in Figure 3.
Wells Band C have provided drinking water to the facility and
the Rockaway Beach Community. A replacement source of drinking
water is being developed for the community by the City of
Bainbridge Island. The new well for this community, the South
Eagle Harbor Well, has recently been sited and installed in an
area west of the facility. This new well is expected to be
available for use in late 1994. The abandonment of wells .B and C
will not commence until the South Eagle Harbor well is on-line.
Alternative 4a:
No Action
No action, in this case, would allow on-site water supply well
structures to disintegrate at their own pace. Given the age and
type of these wells, this disintegration could happen at any
time, providing a pathway for contamination from the facility to
enter lower, uncontaminated, aquifers. This could have a very
severe impact on one of the few drinking water aquifer~ on
Bainbridge Island. . This action has zero capital or operations
and maintenance costs. However, it is not protective of human
health or the environment.
,
Alternative 4b:
Required.
No Action/perform Future Cleanup Action If .
Like the "no action" alternative, this option would allow for the
natural breakdown of the existing on-site drinking water wells.
However, unlike alternative 4a, this alternative calls for action
once the wells disintegrate. Action would include addressing
contamination of the lower aquifer, if it occurs, in addition to
sealing the disintegrated wells.
Costs for the ongoing monitoring of the quality of the water
coming from these wells would be approximately $20,000 per year.
It is anticipated that in. addition to approximately $700,000 to
properly seal and abandon these wells it would cost an additional
$500,000 for aquifer remediation. .It is unknown when these wells
will disintegrate.
-------
Alternative 4c:
Seal and Abandon Onsite Water supply Wells
Under this alternative, on-site water supply wells would be
sealed and abandoned to prevent contamination of the lower
aquifer. This action would not take place until the Rockaway
Beach community, which currently relies upon these wells for
water, is supplied by another source of water. When the new,
off-site well becomes available, the on-site wells would be
sealed to prevent any contamination of the lower aquifer. EPA
anticipates that it would cost approximately $700,000 to properly
seal and abandon these wells.
I.
summary of comparative Analysis of Alternatives
Each remedial alternative being considered must be evaluated
according to specific criteria. The purpose of this evaluation is
to promote consistent identification of the relative advantages
and disadvantages of each alternative. There are nine criteria
by which feasible remedial alternatives are evaluated. While all
nine criteria are important, they are weighted differently in the
decision making process. The nine criteria are summarized in
Table 4.
Threshold criteria
Protectiveness of Human Health and the Environment:
Alternatives lc, 2c, 3b, and4c are protective of both public
health and the environment. A complete overhaul/repla6ement of
the groundwater treatment plant and upgrade of the existing.
groundwater extraction system, Alternatives lc and 2c would help
insure that NAPL contamination does not migrate into the harbor
or onto adjacent beaches. Similarly Alternative 4c, which
involves abandoning the on-site drinking water wells as soon as
possible, would help protect the lower uncontaminated aquifer,
and prevent a more costly cleanup action. Alternative 3b, the
barrier wall contingency provision, would allow for additional
measures to be taken if it is determined that the extraction
system is not effectively containing LNAPL and groundwater
contamination.
I
The no action Alternatives la and 2a would result in the imminent
failure of the existing treatment system, thus ensuring the
continued contamination of the harbor and nearby beaches.
Limited maintenance of .the systems, Alternatives lb and 2b, may
prolong the operating life but will result in failure of the
system at some point in the future. Alternative 3a would not
provide the contingency for construction of a physical barrier if
it is determined that the hydraulic barrier alone cannot contain
the contaminants to the site. Alternatives 4aand 4b would
result in the potential migration of contaminants into deeper
currently uncontaminated aquifers.
-------
Table 4:
Evaluation Criteria
EPA uses nine criteria to identify its preferred alternative for a given site or
contaminant. With the exception of the no action alternative, all alternatives must
meet the first two "threshold" criteria. EPA uses the next five criteria as "balancing"
criteria for comparing alternatives and selecting a preferred alternative. After public
comment, EPA may alter its preference 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. Compliance with federal and state environmental standards - Does the alternative meet all
applicable or relevant and appropriate requirements (ARARs) under state and federal laws?
* Alternatives that are not protective or do not attain ARARs are not evaluated further under the
remaining criteria. .
Biilancing Criteria:
I
(
3. Long-term effectiveness and performance - How well does the alternative protect human
health and the environment after completion of cleanup? What, if any, risks will remain at the site?
4. Reduction of toxicity, mobility, 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 alternative? How fast does the alternative
reach the cleanup goals?
6. 'mplementability - Is the alternative both technically and administratively feasible? Has the
technology been used successfully on other similar 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 EPA'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
-------
Compliance with Applicable or Relevant and Appropriate
Reauirements (ARARs):
No groundwater clean~up standards are included in this "interim
ROD. They will be determined in the final Groundwater Operable
unit ROD. All alternatives are interim measures and will become
part of the final cleanup action that will attain the "applicable
or relevant and appropriate requirements II (ARARs). ARARs
relating to the discharge of treated water or other wastes
generated from the operation of the groundwater extraction and
treatment systems will apply as the interim action is .
implemented. 'Final ARAR-compliant actions will be addressed as
part of the overall Remedial Investigation, Feasibility study,
and final ROD for the Wyckoff Groundwater OU.
Primary Balancing Criteria
Lonq-Term Effectiveness and Permanence:
Alternatives lc, 2c, 3b, and 4cprovide the greatest potential
f~r minimizing risks from contaminated groundwater in the long-
term. A complete overhaul/replacement of the treatment plant,
Alternative lc, should result in a treatment plant with a longer
operating life. Alternatives'2c and 3b allow for the expansion
of the existing extraction system and the construction of a
barrier wall should additional measures prove necessary to
control the movement of contaminated groundwater. (
Sealing on-site drinking wells in the near future, as outlined in
Alternative 4c, would provide the long-term environmental benefit.
of protecting the lower aquifer from this potential route of
contamination and is a permanent solution. Allowing these wells
to collapse prior to action could result in contamination of the
lower aquifer. .
I
The other alternatives, Alternatives la, lb, 2a, 2b, 3a, 4a, and
4b, would not provide long-term effective remediation.
Alternatives la, 2a, 3, and 4a, the No Action Alternatives, do
not provide any remediation at all. Maintenance of the existing
treatment plant and groundwater extraction system, Alternatives.
lb and 2b, would provide effective remediation for a few years at
most. The further deterioration of the equipment would lead to
either abandonment or replacement of both the treatment plant and
the extractions system. Alternative 4b delays remediation
efforts until contaminant problems have worsened.
Reduction of Toxicity. Mobilitv. and Volume Throuqh Treatment:
Alternatives lb and lc, in conjunction with alternatives 2b and
2c respectively, provide for treatment. None of the other
alternatives provide for treatment.
-------
Short-Term Effectiveness:
The repair/replacement of the treatment plant (Alternative lc)
and expansion of the extraction system (Alternative 2c) could
lead to releases of contaminated soils via airborne dust during
construction. This will be mitigated by dust-control efforts.
There is also the possibility of releases of contaminated
groundwater as pipes and treatment plant units are taken offline
and replaced. This will be mitigated by repair protocols which
will require that specific units be bypassed or taken off-line
while under work is underway. There is also the possibility that
there will be a short-term increase in odors as a result of the
construction onsite.
The construction of a physical barrier (alternative 3b) could
lead to a short-term increase in the release of NAPL to the
harbor. This will be minimized by construction protocols.
Implementabilitv:
All of the alternatives being considered can be implemented with
varying degrees of difficulty and have been implemented
successfully at other similar sites. Alternatives lc, 2c, 3b,
and 4c provide reliable remediation.
Cost Effectiveness:
" "
Tbe range of costs estimated for all the alternatives evaluated I
are summarized in Table 5. Estimates of cost (+50%, -~O%) are
identified by year, as either capital expenditures or ongoing
operations and maintenance, in 1995 dollars. These estimates of
cost are also summarized using a 5%" discount rate.
Alternatives la, 2a, 3a, and 4a are the least-costly alternative
for this action. These costs, however, ignore the larger
environmental impacts on the harbor, adjacent beaches, and deep
aquifers as a result of continued contaminant migration from the
facility. They also ignore the substantial monetary costs that
would be incurred at a later date for cleanup of these migrating
contaminants. Although Alternatives lc, 2c, 3b, and 4c are more
costly they are more cost effective approaches for achieving the
remedial action objectives.
Modifying criteria
State Acceptance:
The Washington State, Department of Ecology has been involved in
the development of the focused RI/FS, supported the preferred
alternative in EPA's proposed plan, and is currently considering
concurrence with the selected remedy for this interim action.
-------
TABLE 6: Comparison 01 Costs for Interim Remedial Aliernallves
CATEGORY 1: TREATMENT PLANT
Alternatives
1.a:.- ~
1h:.. Maintain Exlstino Treatment Plan!
Assumption: Treatment plant will lail
w/in 2 years
~ BJrn.aiLfxWlna Treatment Plant
Repair & Opera Ie
Operate
or
11::.... Belililce Exlstina Treatment Plent
Assumption: Existing plant will operete
until new plant running
Design New Plant
Construct New Plant (Incl ovrsght)
Construci New Plant (incl ovrsght)'
Operate New Plant
Repair & Operate Existing Plant
Operate Existing Plant
Operate Existing Plant
Demolish Existing Plant
0911719.
gwourhlrodc:ost
s
Ongoing
O&M
Total
Costs
TOTAL
COSTS
o
o
. ,
150000 /
7 020 2 4
18 733858
22 556612
1995
1996
1997
1998
o rTOTAL
8
Ongoing TOTAL
O&M COSTS
$2,420:946 '
o $2,299,899 $0 $2,299,899
$0 $2.420,946 $2,203,061 $0 $2,203,061
$1,121,047/y $30,268,269 $0 $14,114,430 $14,114,430
$1,000,000 . $1,152,500 $2,152,500 $1,000,000 $1,152,500 $2,152,500
$0 $1,152,500 $1,152.500 $0 $1.094,875 $1,094,875
$0 $1,152,500 $1,152,500 $0 $1,048,775 $1,048,775
$500 000 0 $500 000 $430 000 $0 $430 000
6 782 064 33 725 769 40 507 833 6373 132 4 0580 23 783 12
page 1 014
,...
-------
TABLE 6: Comparison of Costs for Interim Remedial Alternatives
CATEGORY 2: EXTRACTION SYSTEM
Alternative
2a.:.... Ii2..&Ii!m
2L Maintain Existina Ex1raction S~twn
Assumption: Ex1raction System will fail
w/in 2 years
~ EYa~lain. and Upora
-------
TABLE 6: Comparison of Costs for Interim Remedial Alternatives
CATEGORY 3: PHYSICAL BARRIER
Allernative
;rn.;~
ah; Evaluate Performance or Currenl
Extraction Syslem Iinsiall Barriers
Barrier cosls depend on type, depth,
& lenglh 01 barrier,
Assumption: 801llbentonile slurry wall
3' Ihlck, 30' deep, 850' long
Evaluation occurs under Alternative 2c
Oeslgn 01 Barrier
Conslructlon 01 Barrier
Assumption: soll/benlonite slurry wall
3' Ihick, 75' deep, 850' long
Evaluation occurs under Allernative 2c
Oe81gn 01 Barrier
Construction 01 Barrier
Assumpllon: shoot pile walt
3' thick, 30' deep, 850' long
Evaluation occurs under Alternative 2c
Oeslgn 01 Barrier
Construction 01 Barrier
Assumpllon: soil/bentonite slurry wall
3' Ihick, 75' deep, 850' long
Evaluation occurs under Allernatlve 2c
Oeslgn 01 Barrier
Conslructlon 01 Barrier
Capital
Ex endltures
s
Ongoing
O&M
o
1995
1996
1997.202
o rOTA
$31,143
$155,716
$0
186 9
s
Ongoing
O&M
s
Ongoing
O&M
s
Ongoing
O&M
,0
$0
$0
$0
o
...
Tolal
Costs
Capital
Ex endltures
Ongoing
O&M
o
o
o
Tolal
Costs
Total
Cosls
Total
Cosls
Total
Costs
page 3 014
09/17/94
gwourb/rodcost
o
TOTAL
COSTS
$31,143
. $147,930
$0
90 3
TOTAL
COSTS
TOTAL
COSTS
$171,287
$813,615
$0
9
TOTAL
-------
TABLE Ii: Comparison of Costs for Interim Remedial Alternatives
CATEGORY 4: ABANDONMENT OF DRINKING WATER & OTHER WATER SUPPLY WELLS
Allernalive
~ a:.... I:io..&1l!!.O
~ ~o Aclion I Perform Future Cleanup.
Ac1l2nJlB!1.g\lir.!l!l
Olrly analysis 01 drinking water
Olrly analysis 01 drinking water
Olrly analysis 01 drinking water
Seal & Abandon Wells
Aquiler Remediation
~ Seal & Abandon On-site Water Supply
~
Seal & Abandon Wells
Fiscal Year
o r TOTAL
09117/94
gwou,WsI,odcost
Capital
Ex ndllures
s
Ongoing
O&M
TOTAL
COSTS
Total
Costs
o
o
o
o
1996
1997
1998
1999
2000 Ihru 2024
o , OT
s
Ongoing
O&M
$0
o
TOTAL
COSTS
o
$0
60
page 4 01 4
"
-------
Communitv Acceptance:
EPA considered all comments submitted during the public comment
period on the Proposed Plan. The comments have been taken into
account during the selection of the interim remedy for the
Groundwater Operable Unit.
Most comments indicated that the community is supportive of EPA's
preferred alternative, Alternatives lc, 2c, 3b, and 4c. Some
commentors supported all four categories of EPA's preferred
alternative. Most comments in opposition to EPA's preferred.
alternative were focused on the abandonment of the water supply
wells on-site. One comment was received which indicated that
there should be no action taken on the site overall. .A few
comments indicated a preference for no action with regard to the
abandonment of the drinking water wells. Others did not question
the alternative but questioned EPA's lack of financial support
for the development of alternative water supplies. One set of
comments questioned EPA's ability to manage the operations of the
plant. EPA's responses to comments received on the Proposed Plan
are included in the Responsiveness Summary.
J.
Selected Remedy
Using EPA's nine criteria, EPA's selected remedy is:
.-
Replace existing treatment plant (Alternative lC)l
Evaluate, maintain, and upgrade existing extraction
system/hydraulic barrier operations (Alternative 2c),
I
.
.
Evaluate performance of current extraction system/instal~
physical barriers (Alternative 3b), and
.
Seal on-site water supply wells (Alternative 4c).
This interim remedy has been selected because it. provides a set
of remediation actions that best combine containment, source
remediation, and treatment measures and will allow EPA to prevent
the movement of contaminants.offsite, both into Eagle Harbor and
into the underlying aquifers. A more detailed discussion of each
of the components of the selected remedy follows. The schedule
associated with each of the components to the selected remedy is
identified in Table 5.
Replace Existing Treatment Plant.
This component of the interim remedial action includes a number
of elements:
.
Operate the existing plant,
-------
.
Repair the existing plant,
.
Evaluate effectiveness of new treatment plant versus
existing plant, and
.
Select between rehabilitation of existing plant versus
construction of new plant.
EPA has already completed the analysis as to whether construction
of a.new treatment plant would be more effective than repair of
the existing plant. A determination has been made that
construction of a new plant would be more effective. Most of the
physical problems of the existing plant can be repaired, but
long-term reliability will still be questionable. The lifespan
of a repaired plant would be a gamble, with 20 years as a
probable maximum. The current plant has a maximum-flow capacity
which can not be expanded.
Implementation of this portion of the remedy includes the
following elements:
.
continue operations of the current treatment plant until the
new treatment plant is operable, performing repairs as
needed.
These repairs shall include complete replacement of the
current treatment plant's piping, a thorough overhaul of the
plant's primary system and corrosion protection for many of I
the remaining components. (
.
Design the new treatment plant.
The new plant shall be designed to handle the contaminants
in a saltwater ~nvironment, minimizing the corrosion
problems. It will have a much longer lifespan (30 - 40
years) and will be more reliable during that time frame.
The new plant shall be designed to be more efficient and
more effective at meeting rigorous effluent and emission
standards. The new plant shall be designed so that the
capacity can be expanded if a need arises for increased flow
rates. The new plant shall be designed to be less labor
intensive than the current treatment plant. The new plant
shall utilize primary, secondary, and tertiary process units
to treat the groundwater prior to release into the harbor.
.
Construct the new treatment plant.
.
Operate and maintain the new treatment plant.
.
Demolish the old treatment plant.
-------
The estimate of costs in Table 6 is based on construction of a
new treatment plant.
Evaluate, Maintain, and Upgrade Existing Extraction
system/Hydraulic Barrier Operations
Under this component of the interim remedy, EPA shall develop a
quantitative monitoring and modeling. approach to evaluate the
success of the hydraulic barrier at reducing the contamination
seeping onto adjacent beaches and into the harbor.
The system evaluation shall i~clude but is not limited to the
following elements:
.
Develop quantitative measures of NAPL flow offsite,
.
Evaluate differing pump rates,
.
Determine optimum depth and screened interval of extraction
wells to improve efficiency of hydraulic barrier, .
.
Det~rmine optimum depth and screened interval of extraction
wells to improve efficiency of DNAPL and LNAPL recovery,
.
Evaluate various NAPL pump/recovery schedules to optimize
DNAPL and LNAPL recovery, and
.-
Evaluate optimum locations for additional extraction wells.,
. (
If the results of this system evaluation indicate that new
extraction wells could significantly decrease the amount of
contamination entering the harbor, new wells shall be
constructed. This component of the preferred remedy also allows
for existing wells to be abandoned and replaced if they are
operating poorly. . .
Expanding the extraction system includes a number of elements,
including but not limited to:
.
Design of wells,
.
Drilling and actual construction of the wells,
.
Installation of pumps for the extraction 'of groundwater,
.
Installation piping to transport the groundwater to the
treatment plant,
.
Installation of separate pumps and piping to recover NAPL
from the well, and
-------
.
Increased O&M costs due to the increase in the number of
pumps and the number of locations which require NAPL
recovery.
Evaluate Performance of Current Extraction system/Install
Barriers.
If the groundwater extraction system/hydraulic barrier evaluation
indicates that the hydraulic barrier is insufficient and the
presence of a physical barrier would significantly enhance the
effective and efficient containment of contaminated groundwater,
a barrier wall shall be installed along the north and east shores
of the Wyckoff site. A decision on whether a physical barrier
should be constructed will likely occur within the next two
years.
This component of the interim remedy includes the following
elements:
.
Determine the relative effectiveness of a barrier in
controlling the movement of LNAPL,
.
Determine the relative effectiveness of anchoring the
barrier into the underlying clay layer to control the
movement of DNAPL,
.
Determine the effectiveness of possible construction
materials and configurations which could serve to physically
block the movement of NAPL offsite, (
.
Design the physical barrier, and
.
Construct the physical barrier.
At this time it is anticipated that such a barrier would either
,be a slurry wall or sheet pile. A barrier designed to control
the movement of LNAPL would extend approximately 30 feet below
ground surface. To control the movement of DNAPL, the barrier
would have to be anchored into the underlying clays,
approximately 70 feet below ground surface.
The wide range in costs indicated for the barrier wall (see Table
5) is a function of the area to be walled in and the method which
might be used.
Seal and Abandon Onsite Water Supply Wells
EPA believes that the risks associated with the uncontrolled
disintegration of the on-site water supply wells are unacceptable
and that action to sea~ these wells in the near future is
necessary. The drinking water supply wells are currently located
-------
in the center 'of an area of the Wyckoff Facility where DNAPL and
LNAPL have been observed. Collapse of the wells, which are
screened in an uncontaminated aquifer below (refer to Figure 4),
would provide a pathway for NAPL to enter the clean aquifer and
the water supply system.
This component of the interim remedy allows for the proper
sealing and abandonment of these wells before the deep aquifer is
contaminated. On-site water supply wells shall be sealed to
prevent contamination of the lower aquifer. This action will not
take place until the Rockaway Beach community, which currently
relies upon these wells for potable water, is hooked up to
another source. When the new, off-site well becomes available,
the on-site wells shall be sealed to prevent any contamination of
the lower aquifer.
This portion of the interim remedy includes the following
elements for each well:
.
Clear the site around the well head,
.
Evaluate the well to determine abandonment approach(es)
utilizing video inspection and well logging where
appropriate,
.
Select abandonment method(s), and
+-
Abandon well.
I
(
Costs of Selected Remedy
The .total 30 year estimate (+50%, -30%) of costs (using fiscal
year 1995 dollars at a 5% annual discount rate) for EPA's
selected remedy are shown in Table 6, and range from $24.7
million. to $28.2 million. The lower end of the range assumes
that: 1) no improvements are made to the extraction system
based upon the results of an extraction system evaluation, and 2)
there is no need to install physical barriers based upon the
results of the extraction system evaluation. The upper end of
the cost range assumes that: 1) twenty-four new extraction wells
and pumps are added to the existing. extraction system, and 2) a
sheetpile ba~rier is constructed along the full extent of the
facility boundary with the harbor. Construction of fewer than 24
wells and construction of a slurry wall rather than a sheetpile
barrier would give an intermediate cost range. The current
schedule for all of these interim remedial actions can be
identified in Table 5.
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TABLE 6: Costs 0' EPA's Selected Interim Remedial Alternatives
09/17/94
gwourtrslrodc:ost
CATEGORY 1: TREATMENT PLANT
Alternative 1 c:
Treatment Plant
Total
Costs
40 0 833
TOTAL
COSTS
Fiscal Year
OrO A
C:ATEGORY 2: EXTRACTION SYSTEM
Alternalive 2c: Evaluate Maintain & U
Low Eslimate - 0 'new welts construcled
High Estimate - 24 new welts constructed
Fiscat Year
o r TOTAL
r TOT]i.
Total
Costs
340 200
400 200
Capllal
Ex enditures
60 000
174 296
TOTAL
COSTS
234 296
CATEGORY 3: PHYSICAL BARRIER
Alternative 3b: Evaluta Performance of Current Extracllon S Ie
Low Esllmate - no physcial barrier conslructed
High Estimate - 75' sheetpile wall
Fiscal Year
OrOA
o rTO
Capllal
Ex endilures
Total
Cosls
Capllal
'Ex endllures
TOTAL
COSTS
o
69 004
o
o
o
69 004
o
4 1 62
o
o
o
2461 962
CATEGORY 4: ABANDONMENT OF DRINKING WATER & OTHER WATER SUPPLY WELLS
, Alternative 4c: Seal & Abandon On-site Waler Su I Welts
Total Capital TOTAL
Fiscal Year Costs Ex endllures COSTS
0 r OT 678607 67860 6 60
TOTAL COSTS
s
Capital Ongoing Total Capital TOTAL
Fiscal Year Ex endilures O&M Costs Ex endilures COSTS
Low Estimate 0 r 0 A 520 3 969 41 8 4 3 8 8 4 61
Hi9h Estimate 0 r OT 696 40 309 4 246984 3101 8 8 28 20 8 8
,..
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K.
statutory Determinations
Protection of Human Health and the Environment
The selected interim remedy combines' a number of containment"and
treatment components which are designed to be protective of human
health and the environment. None of the other alternatives
ensure long-term protection of human health or the environment.
Protection of human health and the environment is obtained by
preventing the movement of contaminated groundwater, LNAPL, and
DNAPL into deeper aquifers and offsite into Eagle Harbor. This
interim action will confine the contaminants to immediately under
the facility. This combination of actions will eliminate,
reduce, and control exposure to contaminants.
Protection of "human health during implementation of the cleanup
remedy will be obtained through compliance with OSHA
requirements, the use of personnel protective equipment, and
other safety measures and engineering controls. Short term risks
to the community during implementation of the remedy will be
minimized through dust control and other protective measures.
Long-term operations and maintenance will be required for the
selected remedy. The effectiveness of the remedy will be
evaluated as part of the final RIfFS to determine if additional
source control or groundwater treatment actions are required.
I
Compliance with ARARs
(
The selected remedy will be designed and implemented to attain
all ARARs identified in this section. Because this is "an interim
remedial action, groundwater cleanup standards are not being
established in the ROD.
Applicable Federal ARARs
Clean Air Act (42 U.S.C. 55 7401 et. seg.); Washington state Air
Pollution Control Act (RCW 70.94; WAC 173-460); Puget Sound Air
Pollution Control Agency (PSAPCA Regulations I & III)
The design and operations of the groundwater treatment plant will
meet the substantive requirements of the ambient air quality
permits.
Solid Waste Disposal Act, also known as the Resource Conservation
and Recovery Act, Subchapter III, (42 U.S.C. 55 6921-6939; 40
C.F.R. Parts 261, 264, and 268)
Off-site disposal of listed wastes resulting from operations of
the groundwater extraction system and treatment plant will meet
RCRA requirements. "
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Clean Water Act (33U.S.C. ~~ 1311; 40 C.F.R. Parts 122;
Washington state Water Pollution Control Act and Water Resources
Act (R.C.W. 90.48 & 90.54; W.A.C. 173-220)
Effluent discharge resulting from operations of the groundwater
extraction system and treatment plant will meet the substantive
requirements of a National Pollutant Discharge Elimination System
(NPDES) permit.
Applicable State ARARs
Water Well Construction Act (R.C.W. 18.104; W.A.C. 173-160)
The rehabilitation of existing extraction wells, the construction
of new extractions wells, and the sealing and abandonment of
drinking water and other water supply wells will meet the
standards set for proper construction and abandonment of water
wells.
Shoreline Management Act (R.C.W. 90.58; W.A.C. 173-14)
The siting of the replacement groundwater treatment plant will
meet the applicable substantive requirements of the Shoreline
Master Plan for Kitsap County.
Utilization of Permanent Solutions and Alternative Treatment
Technoloqies or Resource Recoverv Technoloqies to the Maximum
Extent Practicable . (
~
The extraction and treatment of contaminants from the groundwater
and abandonment of the onsite water supply wells are permanent
solutions. Overall, the interim actions selected represent the
best balance of alternatives with respect to selection criteria,
given the limited scope of the action.
Preference for Treatment as a Principal Element
Although the objective of the selected interim remedy is
containment of contaminants to the site, the creation of
hydraulic barrier includes the treatment of groundwater.
selected remedy meets the statutory preference for using
treatment as a principal element.
a
The
L.
Documentation of significant Changes
The Proposed Plan was released for public comment on June 25, .
1994. An element of the preferred alternative (Alternative lC)
was identified as "Repair or replace existing treatment plant".
However, EPA has concluded its evaluation and has made the
determination that construction of a new treatment plant will be
both more environmentally effective and over the long term, more
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cost effective than a complete overhaul of the existing plant.
This discussed in some detail in Section J.
(
47
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RESPONSIVENESS SUMMARY
PROPOSED PLAN FOR INTERIM ACTION
WYCKOFF GROUNDWATER OPERABLE UNIT
The purpose of this Responsiveness Summary is to summarize and
..respond. to comments submitted regarding the Proposed Plan for
interim action at the Wyckoff Groundwater Operable unit. The
public comment period for the Proposed Plan was held from July 26
to August 26, 1994. This Responsiveness Summary meets the
requirements of section 117 of CERCLA as amended.
EPA held a public meeting on August 10, 1994, in the city of
Bainbridge Island, Washington, to present EPA's Proposed Plan and
take public comment. The meeting was attended by approximately
15 persons.. Comments were provided at the public meeting by
eight individuals from the community and one representative of
the Bremerton-Kitsap County Health Department. Letters were
received from two individuals from the community and from a
representative of the Washington Department of Natural Resources.
The Washington Department of Natural Resources comments are
focused entirely on issues related to the operations of the
treatment plant and are discussed separately, as a set, in this
Responsiveness Summary.
Paraphrased comments and EPA responses are provided below.
Paraphrasing was used to incorporate related concerns expressed
in more than one comment.
I
(
Comment
How much money was initially set aside for the Wyckoff Superfund
project and how much has been spent to date?
EPA Response
As of August 1994, EPA has spent approximately $14.2 million
on the Wyckoff facility and groundwater operable units. The
current 30 year budget estimates a total of approximately
$43 million will be required to prevent the movement of
groundwater from the wood treating facility into the harbor.
EPA has not developed estimates of costs for final
remediation. of the Wyckoff facility operable or for final
remediation of the Wyckoff groundwater operable unit.
Comment
The human health risks associated with contamination at the
Wyckoff/Eagle Harbor site do not warrant the cost of proposed
cleanup actions.
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EPA Response
EPA has determined that existing human health and
environmental risks at the Wyckoff/Eagle Harbor Superfund
site warrant control of contaminated groundwater at the
Wyckoff facility. contamination emanating from the shallow
aquifer beneath the facility threatens fish, shellfish, and
other aquatic organisms in the harbor. People who regularly
consume contaminated fish or shellfish on a regular basis,
or who are regularly exposed to contaminated beach
sediments, may experience adverse health effects.
To assess potential human cancer and non-cancer health risks
in harbor sediments, EPA used measurements of sediments and
seafood and assumed exposure to contaminants from eating
contaminated fish, shellfish, and sediments, and from skin
contact with contaminated beach sediments. Data suggested
that regular, long-term consumption of contaminated crabs
and fish may pose a human health concern.
EFA also evaluated the potential human health ~isks from
drinking contaminated groundwater present at the Wyckoff
facility. The results of these assessments indicated that
regular consumption from the shallow aquifer beneath the
Wyckoff facility, over a long period of time, poses both"
cancer and non-cancer risks to those exposed.
More detailed information" regarding specific numbers and
factors which were used in calculating the risks lor the
Eagle Harbor portion of the site can be found in the Risk
Assessment Report which is included in the Remedial
Investigation and Field Study (RIfFS) Report for Eagle
Harbor. Groundwater risks are detailed in the Risk"
Assessment Report for the Groundwater Operable unit.
~
EPA is required under the Superfund law to select cleanup
actions that are cost effective. Cost effectiveness takes
into account the cost of the remedy and its effectiveness
over the long-term. EFA believes that the selected remedy
is cost effective because it requires a series of remedial
actions that are most likely to achieve the remedial action
objectives in a cost-effective manner. "
Comment
Given the risk at the site, there must be better things we can do
with our money.
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EPA Response
Comment Noted
Comment
What is the policy regarding financial
affected by Superfund sites? Is there
Rockaway Beach residents to soften the
system? .
~ssistance to citizens
grant money available for
blow of the new well
Response
The Superfund Program is paying for work related to site
remediation: well sealing and abandonment, increased
capacity for fire suppression, and placement of a firemain
to the site fenceline. In addition, easements are being
provided to allow the use of the property for the
community's new well, tanks, and water supply lines.
Requests for funding to deal with other "normal" water
system issues related to storage capacity, flow, condition
of pipes, etc., are more appropriately addressed via state
and local agencies. It is not appropriate for EPA to use
Superfund moneys to upgrade the Rockaway Beach community
water system, as required under other state and local
regulations. The State of washington, Department of
Ecology, has provided a grant to the City of Bainbridge
Island to defray approximately $450,000 of the expense for
the residents for the entire project, including the upgrade
of the system.
I
Comment
The two water supply wells onsite should remain on line for a
long enough period of time to adequately test the new drinking
water well.
EPA Response
EPA is not planning to seal the two drinking water supply
wells located on the Wyckoff site until after the City of
Bainbridge Island has connected the Rockaway Beach community
to the new well and has indicated to-EPA that the system is
operational. However, any indication of advanced
deterioration or failure of the existing wells may require
an emergency response to protect the underlying drinking
water aquifer. .
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Comment
Two comments received at the public meeting, one of them from a
representative of the Bremerton-Kitsap County Health District,
supported the Proposed Plan.
EPA Response
Comment Noted.
Comment
One written comment was received supporting all of the preferred
alternatives but proposing the following modification to the well
abandonment alternative. EPA should consider rehabilitating the
existing drinking water wells which supply Rockaway Beach. If
monitoring indicates that contaminants are being introduced into
the system after rehabilitation is attempted, then the wells
should be sealed and abandoned.
EPA Response
As discussed in the ROD, these wells are located in the
midst of extremely contaminated surface soils. In addition,
the upper aquifer in this area is contaminated with both
LNAPLand DNAPL. It is only a matter of time before these
wells deteriorate to point where the con.taminants are able
to use the wells as conduits to lower aquifers and also
contaminate the Rockaway Beach community water suPply
system. Rehabilitation of these wells is not a reasonable
option. Washington Department of Ecology regulations (Water
Well Construction Act, R.C.W. ~8.~04, W.A.C. ~73-180)
require that these wells be properly sealed and abandoned.
EPA's decision is therefore more focused on determining how
and when this action will be taken, not if it will be taken.
Delay only increases the risk of contamination entering the
deeper aquifers and the water supply system.
,
Comment
The site should be cleaned up quickly if it really poses a threat
to human health and the environment. constructing a barrier wall
to contain contaminated groundwater appears to be the most
effective and expedient alternative. .
Response
EPA has determined that contaminated groundwater beneath the
former Wyckoff wood-treating facility poses a hazard to
human health as well as organisms living in the harbor and
adjacent beaches. Maintenance of a viable groundwater
treatment plant and extraction system at the site. is
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essential to the effective containment of contaminated
groundwater at the site.
EPA agrees that construction of a barrier wall may be
necessary to contain contaminated groundwater if the
hydraulic barrier created by the groundwater extraction
system proves to be insufficient. However, the hydraulic
barrier created by the groundwater extraction system needs
to be improved and a more complete analysis of how the
groundwater flows at the site needs to be completed before a
successful barrier wall could be constructed. A barrier
wall. alone would not be adequate for containing contaminated
groundwater at the site. -
-Comment
If the contaminated materials present on the site are a hazard to
human health, EPA has to find a faster way to do accomplish site
clean-up. - There is already enough information to determine what
to do. The aquifer should be protected and the con?truction of
a physical barrier is a good idea.
EPA Response
EPA has applied the principals of the Superfund Accelerated
Cleanup Model to the environmental and human health problems
that exist at the Wyckoff facility. The response actions
provided for under this interim ROD represent a continued I
effort by EPA to address these problems as quickl~ as
possible. - .
Washington Department of Natural Resources (DNR) Comment.
EPA will need to secure DNR permission for use of state-owned
. aquatic lands for the effluent outfall.
EPA Response
EPA is currently working with DNR to cooperatively continue
use of the existing outfall. This outfall was installed by
the Wyckoff Company with DNR permission and under EPA
oversight. EPA has the authority to secure necessary access
to the site and areas in very close proximity necessary for
response action, including the effluent outfall.
DNR Comment
DNR expressed concerns about EPA's ability to operate the
groundwater extraction system and treatment plant in an
environmental-ly responsible manner, because of the inadequacies
with the existing extraction system and treatment plant which
-------
.
have become apparent despite EPA's oversight of the project to
date.
EPA Response
The Wyckoff Company, now known as Pacific Sound Resources,
Inc. designed and installed the existing groundwater
extraction system and treatment plant. Although the basic'
design parameters for the system addressed the need to
control the release of NAPL and contaminated groundwater to
the harbor, the Wyckoff Company was not able to comply with
all of EPA's requirements in either the 1988 Administrative
Order on Consent or the subsequent 1991 Unilateral
Administrative Order. However, since EPA takeover of the
system in November 1993, extensive improvements have been
made. .
It is EPA's determination that the groundwater treatment
system must be replaced and the extraction system expanded,
as provided for in this Interim ROD. EPAhas retained
contractors with extensive experience in .the design,
construction, and operations and maintenance of such systems
and has budgeted adequate resources to implement the
selected.
DNR Comment
EPA should conduct sediment sampling adjacent to the outfall to I
determine if a release of contaminants has occurred thfough the
improper operation and disrep~ir of the groundwater treatment
system. The sampling should be conducted in a manner that allows
comparison with baseline sediment samples collected by Wyckoff in
December 1989 (prior to the start of discharges from the
outfall). In addition, the sampling should also allow comparison
with current 'Ecology Sediment Management Standards (Chapter
173-2Q4-WAC).
EPA Response
site contaminants, at concentrations greater than the
effluent limitations, have not been released by the
groundwater treatment plant. Weekly monitoring of the
effluent has demonstrated this. It is EPA's intent, as part
of good treatment plant operating procedure, to sample
sediments adjacent to the outfall at appropriate intervals
to demonstrate that contaminants are not entering the
sediments from the effluent. This sampling will occur
during the upcoming fall/winter.
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,"
DNR Comment
The alternatives analysis for the Groundwater Treatment System
- should include an evaluation of other options for disposal of
treated effluent besides discharge to the marine environment.
other options may include:
.
.
.
.
.
Connection of the plant to a sanitary sewer,
Evaporation, -
Land disposal,
Reuse- of treated water, and
Transport to an appropriate disposal facility.
EPA should use this alternatives analysis to amend its Proposed
Plan and allow additional comment.
EPA Response
EPA examined options for treated effluent besides discharge
into the marine environment and found that they are not -
feasible. The following discussion describes potential
disposal options and qualitatively evaluates their
practicability based on cost, water quality impacts caused
by high salinity, and general implementability.
Treated effluent from the Wyckoff groundwater treatment
plant is currently being discharged via an outfall to puget
Sound. The current discharge volume is approximately 18 I
million gallons per year at current minimal extra~tion rates
rising to 100 million gallons per year or more at full
capacity. Because of the proximity of the extraction wells
to the Sound, the pumped groundwater is approximately 50
percent seawater based on a chloride content of
approximately 11,000 milligrams per liter and electrical
conductivity of 24-ohm-cm. As a result, the chloride
concentration greatly limits the disposal options of the
treated effluent.
.
Discharge to POTW - There are no sewer lines on the
south side of Eagle Harbor. Three to four miles of
line would have to be laid to the nearest sewer on
Weaver Street (or a mile of sub-harbor line to the
ferry dock). The capacity of the existing sewer lines
may be inadequate to convey the additional 18 to 100
mgy or more. Discharge of the high chloride effluent
to the sanitary sewer system would cause significant
corrosion problems to the sewer collection system,
pumps, and mechanical treatment systems. Also, the
high chloride water would likely disrupt the biological
treatment processes. -
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.
.
.
Evaporation (including passive and energy enhanced)
Because of the low pan evaporation rates for areas west
of the Cascade Range (approximately 24 inches per
year), evaporation ponds for disposal of treated.
effluent would require an extremely large surface area
(approximately 25 to 150 acres or more). Given the
site constraints (area of the property) and the lack of
additional open space with in the vicinity of the
treatment plant, it is unlikely that sufficient
property CQuld be obtained to technically and feasibly
implement passive evaporation. .
The energy requirements, capital. costs, and operating
costs associated with energy enhanced evaporation.
(incineration and dehydration) of this large volume of
water would not be feasible.
.
Land disposal (including land application and shallow
infiltration) - Ecology typically requires agro~omic
application rates for wastewater disposal to minimize
shallow groundwater contamination. Required land area
would be large (one to two times the area for
evaporation), holding tanks/ponds would be needed to
store effluent during the winter, it is unlikely that a
salt tolerant crop could be found, and .salt would
buildup in the soil to the point that infiltration
would stop. Therefore, land application is not
practicable. (
Shallow infiltration using drain field/recharge
trenches or recharge ponds would contaminate the
. shallow groundwater with high chloride water. Evenif
this were permitted, the geochemical incompatibility. of
the effluent and shallow soils and groundwater would.
create a major O&M problem for an infiltration system.
/
.
Reuse of treated water - EPA is unaware of reuse
applications requiring the use of high chloride water
mainly due to corrosion and phytotoxicity problems.
EPA is unaware of any facilities in the area that
require cooling water. If the effluent were to be used
as a saline cooling water, corrosion would be a major
problem.
Transport to an .appropriate disposal facility -
Disposal the large volumes of effluent (approximately
18 to 100 mgy) at any offsite waste disposal or
processing facility would not be economical due to high
transportation and disposal costs.
.
Another potential disposal option not listed in the DNR
letter is deep aquifer injection.
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o.
.
Deep aquifer injection - This option would require a
massive multi-year study to identify and characterize a
suitable non-potable aquifer for injection and prove
its current and long-term hydraulic isolation.. Based
on the existing water supply, wells on the injection
zone would have to be deeper than 800 feet. The cost
of the study, long-term monitoring, and O&M and the
time required to meet the substantive requirements of
the Ecology VIC permit make this option non-viable.
Even without preparing detailed cost estimates for each of
these disposal alternatives, it is apparent that any of the
options would have a significantly.higher cost than the
current method of effluent disposal (i.e., diffused
discharged to Puget Sound). The higher costs coupled with
the obvious incompatibility of the saline effluent with many
of the disposal alternatives clearly indicates that the
current method of discharge is the most appropriate.
Moreover, the adoption of any of the disposal alternatives
only moves the contaminants in potentially inadequately
treated effluent (which are DNR's major concern) from one
point .in the environment to another.
DNR Comment
Current effluent standards for discharges from the groundwater
treatment plant should be revisited given potential changes in
technology over the past six years. The current standards were I
provided as ARARs to EPA by Ecology in a letter dated August 24,.
1988, from Nigel Blakely. DNR wants assurances that any upgrades
to the treatment plant will use best available technology and
meet substantive requirements of the Clean Water Act and NPDES
programs.
EPA Response
EPA has been and is currently working very closely with
Ecology to identify effluent limitations for both the
existing treatment plant and any new treatment plant which
may be constructed. As stated in the ROD, it is EPA's
intent to meet the substantive requirements of the NPDES
program under the Clean Water Act.
DNR Comment
EPA, with Ecology oversight should conduct a sediment impact zone
evaluatiQn for the proposed discharge in accordance with the.
Sediment Management Standards WAC 173-204-400 et. seq.). Ecology
has already identified the Sediment Management Standards as an
ARAR for Eagle Harbor, and a sediment impact zone evaluat.ion is
necessary to ensure compliance with the National contingency
Plan. If a sediment impact zone is necessary, EPA's operation of
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.
the treatment plant must meet substantive provisions of the
Sediment Management Standards for this topic.
EPA Response
EPA will use the results of the upcoming effluent outfall
sediment sample collection effort discussed above to
determine if a sediment impact zone evaluation is necessary.,
It is very likely that the data will clearly indicate that
there is no sediment impact resulting from the outfall. If
the data indicates otherwise, the EPA, in consultation with
Ecology, will conduct a sediment impact zone evaluation for
the effluent outfall.
I
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